Recent UCL public prosecutor decision addresses statute of limitations: People v. E*Poly Star, Inc.

In People v. E*Poly Star, Inc., 205 Cal.App.4th 1316 (May 14, 2012), the Court of Appeal (Second Appellate District, Division Seven) held that the trial court erred in concluding that the UCL's four-year statute of limitations barred public prosecutor claims brought under the UCL's "fraudulent" prong. 

As the opinion notees, the Supreme Court is considering whether the delayed discovery rule and the continuing violation doctrine apply to UCL claims.  Aryeh v. Canon Business Solutions, Inc., no. S184929 (review granted 10/20/10).  Aryeh has been fully briefed and is awaiting oral argument.