According to the blog Federal Civil Practice Bulletin, Judge Wilken's decision in Bahramipour v. Citigroup Global Markets, Inc., 2006 WL 449132 (N.D. Cal. 2006) was soon followed by a $98 million classwide settlement. In that case, Judge Wilken held that by asserting their Fair Labor Standards Act (29 U.S.C. §§200 et seq.) claim as a UCL "unlawful" prong violation, rather than as a direct violation of the Act, plaintiffs enjoyed a longer statute of limitations and an "opt-out" (rather than an "opt-in") class. My original post on Bahramipour is here; see also this post on Harris v. Investor's Business Daily, Inc., ___ Cal.App.4th ___ (Mar. 29, 2006), in which the California Court of Appeal reached a similar conclusion. UPDATE: As an alert reader pointed out in the comments, the California Supreme Court denied review in Harris today (06/28/06).