More than a year after it was handed down, the Ninth Circuit’s blockbuster decision in Mazza v. American Honda Motor Co., 666 F.3d 581 (9th Cir. 2012), continues to have a significant influence on consumer-protection class actions. In particular, the Ninth Circuit’s narrow interpretation of the presumption of reliance under California’s consumer-protection laws has created numerous obstacles for both plaintiffs and defendants at the class-certification stage.
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