Last week, on April 23, 2012, the U.S. Supreme Court denied the cert. petition in Ticketmaster et al. v. Stearns, no. 11-983.
In that case, the Ninth Circuit reversed an order denying class certification of a UCL "fraudulent" prong claim. Stearns v. Ticketmaster Corp., 655 F.3d 1013 (9th Cir. 2011).