In re Tobacco Cases II just held that the reforms of California's UCL require only named plaintiffs, not all class plaintiffs, to show that they had lost money or property as a result of a UCL violation. There is an actual reliance requirement, but (at least in the case of a long-term ad campaign) it should not be interpreted so stringently as to require a showing of individualized reliance on specific misrepresentations, and there's a presumption of reliance once a material falsehood has been shown.
Highlights from the UCL Practitioner blog.
I think this is good news. But that is because I think Prop 64 was a mistake. I'm not sure the court wasn't being somewhat disingenuous in its interpretation of the intent of Prop. 64.
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