In In re Cipro Cases I & II, ___ Cal.App.4th ___ (Nov. 1, 2011), the Court of Appeal (Fourth Appellate District, Division One) followed Chavez v. Whirlpool Corp., 93 Cal.App.4th 363 (2001) and held that conduct not unlawful under the Cartwright Act could not be deemed "unfair" under the UCL. Slip op. at 50.
In my opinion, that holding (like the holding in Chavez) is inconsistent with the California Supreme Court's decision in Cel-Tech. In 2005, another appellate panel declined to follow Chavez for that very reason. Eddins v. Redstone, 134 Cal.App.4th 290 (2005) (discussed in this blog post).
UPDATE: On February 15, 2012, the Supreme Court granted review in this case. In re Cipro Cases I & II, no. S198616. The statement of issues mentions only the Cartwright Act claim, but as plenary review was granted, the Court may also address the above UCL issue.