In Van Patten v. Vertical Fitness Group, LLC, ___ F.3d ___ (9th Cir. Jan. 30, 2017), the Ninth Circuit held that the plaintiff satisfied Article III's standing requirements by alleging a "concrete injury in fact," but that he lacked Prop. 64 standing because he had not suffered an "economic injury" within the meaning of Kwikset. Slip op. at 21-23.