The Ninth Circuit has handed down an important class certification decision, Stearns v. Ticketmaster Corp., ___ F.3d ___ (9th Cir. Aug. 26, 2011). The court reversed an order denying certification of a UCL "fraudulent" prong claim, holding (among other things) that certification under Rule 23 does not require proof that all unnamed class members have standing—either under Prop. 64 or Article III. Only a single named class representative need meet the standing requirements.
I will try to write more on this case in a later post.