Consumer Protection Litigation and Enforcement Update and Compliance Management Strategies - March 23, 2022
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Consumer Protection Litigation and Enforcement
Update and Compliance Management Strategies
March 23, 2022
Disclaimer All information, content, and materials contained in this publication/program are for informational purposes only. This publication/program is intended to be a general overview of the subjects discussed and does not create a lawyer-client relationship. Statements and opinions are those of the individual speakers, authors, and participants and do not necessarily reflect the policies or opinions of DLA Piper LLP (US). The information contained in this publication/program is not, and should not be used as, a substitute for legal advice. No reader should act, or refrain from acting, with respect to any particular legal matter on the basis of this publication/program and should seek legal advice from counsel in the relevant jurisdiction. This publication and the program may qualify as “Lawyer Advertising,” requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome. DLA Piper LLP (US) accepts no responsibility for any actions taken or not taken as a result of this publication/program. www.dlapiper.com 2
Welcome and Speakers
Keara Gordon Isabelle Ord
Partner
Austin Brown Partner
Co-Chair Class Action Group Partner Co-Chair Class Action Group
Financial Regulatory Co-Chair Financial Services
Sector US
www.dlapiper.com 3
Consumer Class Actions ▪ Consumer class actions trends ▪ Class action risk can create regulatory and reputational risk ▪ Key and emerging issues ▪ Privacy and Biometric Information Privacy Act (“BIPA”) ▪ Global class actions are here www.dlapiper.com 4
Government Enforcement ▪ Overview of key enforcement agencies ▪ Unfair, Deceptive or Abusive Acts or Practices legal framework (UDAAP) ▪ Key and emerging issues ▪ Regulatory action produces class action risk ▪ Practical tips www.dlapiper.com 5
Class Action Litigation Trends www.dlapiper.com 6
Class Actions – Increasing risk in 2022
Stats Class action spending predicted for 2022: Class actions will grow for the 7th year in
a row, spending per class action will also
$3.64 B increase
Consumer Retail is a “top growth
2021 class action spending: prospect”
$3.37B Source: BTI Consulting Practice Outlook
for 2022
www.dlapiper.com
Class Actions – Trends and Developments
Key Areas ▪ Consumer goods ▪ Financial Services
‒ Naturals/healthy ▪ Insurance
‒ Consumer protection challenges ▪ Food and Beverage
‒ Price premium ▪ Employment
‒ ESG ▪ CBD
▪ ESG – organic, pure, etc. ▪ Antitrust
▪ Privacy (BIPA, CCPA, data breach) ▪ Covid-19 (decreasing)
▪ Securities ▪ WATCH: AI, inequities, lasting harm
www.dlapiper.com
Class Action Risk for Consumer Goods Manufactures
Class actions in the consumer good space
▪ Class action bar has targeted
consumer goods companies.
▪ Multiple “copycat” class actions across
the country.
▪ Brought on behalf of nationwide and
state classes.
▪ Multiple state class actions.
▪ Increased number of filings in 2021.
▪ Litigation funding is becoming more
mainstream.
www.dlapiper.com 9
Causes of Action in Class Actions
Class actions in the consumer goods space
▪ Violations of state consumer protection laws
▪ Advertising
▪ Unfair business practices
▪ Negligence
▪ Breach of express and implied warranty
▪ Magnuson-Moss Warranty Act
▪ Fraud (misrepresentation and omission)
▪ Unjust enrichment
▪ Breach of contract
▪ Terms and conditions
www.dlapiper.com 10Defense Philosophies Most class actions settle. www.dlapiper.com 11
Class Action Key and Emerging Issues www.dlapiper.com 12
Article III Standing
A First Line of Defense
Under Article III of the U.S. Constitution “the judicial power of the United States” extends only
to “cases” or “controversies.”
A party has a “case” or “controversy” sufficient to obtain standing in Federal Court when the plaintiff:
(1) Suffered an injury in fact;
(2) that is traceable to the challenged conduct of the defendant; and
(3) that is likely to be redressed by a favorable judicial decision.
An injury in fact requires:
(a) an invasion of a legally (b) that is concrete and (c) actual or imminent, not
protected interest; particularized; and conjectural or hypothetical.
www.dlapiper.com 13Round I: Spokeo v. Robins (2016)
Spokeo, Inc. v. Robins 136 S. Ct. 1540 (2016)
Justice Alito:
Question presented was whether Congress may
confer Article III standing upon a plaintiff who
suffers no concrete harm and who therefore could
not otherwise invoke the jurisdiction of a federal
court by authorizing a private right of action based
on a bare violation of a federal statute.
www.dlapiper.com 14Spokeo: Bare Procedural Violations Not Enough
A plaintiff does not “automatically satisf[y] the injury-in-fact requirement whenever
a statute grants a person a statutory right and purports to authorize that person to
sue to vindicate that right.”
Plaintiffs cannot “allege a bare procedural violation, divorced from any concrete
harm, and satisfy the injury-in-fact requirement of Article III.”
www.dlapiper.com 15Spokeo: Risk of Harm
Plaintiff must show a “material risk
An injury can also be “concrete”
of harm.” There must be “a degree
if a plaintiff demonstrates a “real
of risk sufficient to meet the
risk of harm.”
concreteness requirement.”
A real risk must be:
▪ Actual or imminent, which means “the [alleged] injury is certainly impending” (Clapper)
▪ Allegations of possible or speculative future injury are not sufficient
www.dlapiper.com 16Round 2: TransUnion v. Ramirez (2021)
TransUnion v. Ramirez 141 S. Ct. 2190 (2021)
Justice Kavanaugh:
Question presented was whether either Article III or Rule 23
permits a damages class action where the vast majority of
the class suffered no actual injury, let alone an injury
anything like what the class representative suffered.
www.dlapiper.com 17TransUnion: What happened?
▪ Mr. Ramirez could not buy a car when he
potentially matched two entries in the OFAC
database of criminals and terrorists, got allegedly
conflicting reports from TransUnion
▪ TransUnion argued class members lacked
standing and Mr. Ramirez’s situation was not
typical
‒ Plaintiffs agreed 75% of putative class did not
have a credit report given to a third party.
‒ Mr. Ramirez only person turned down for a loan
because of the errant terror list flag.
▪ N.D. Cal. jury awarded the class $8.1 million in
statutory damages and $52 million in punitive
damages.
▪ Ninth Circuit reduced the damages award to
approximately $40 million but held that all class
members had standing.
www.dlapiper.com 18TransUnion: Main Takeaways
Makes clear that allegations that a statute was violated do not, by themselves, create standing and that
courts must separately consider whether a plaintiff suffered a concrete harm to have standing.
Clarifies that prior statements that a risk of future harm could be sufficiently concrete were predicated on a
claim for injunctive relief, but the test for evaluating claims of future harm in damages cases will require
more.
Does not address the issue, on which the circuit courts are split, of whether a class may be certified that
includes uninjured plaintiffs.
‒ But: “Every class member must have Article III standing in order to recover individual damages.
‘Article III does not give federal courts the power to order relief to any uninjured plaintiff, class
action or not.’”
Does not address the lower court’s ruling on typicality, which was also at issue on appeal, given its
resolution of the standing issues.
www.dlapiper.com 19TransUnion: Violation of a statute not enough
“Congress’s creation of a statutory prohibition or obligation and a cause of action
does not relieve courts of their responsibility to independently decide whether a
plaintiff has suffered a concrete harm under Article III ….”
“For standing purposes, therefore, an important difference exists between (i) a
plaintiff’s statutory cause of action to sue a defendant over the defendant’s
violation of federal law, and (ii) a plaintiff’s suffering concrete harm because of the
defendant’s violation of federal law.”
www.dlapiper.com 20TransUnion: What is concrete harm?
“[C]ourts should assess whether the alleged injury to the plaintiff has a ‘close
relationship’ to a harm ‘traditionally’ recognized as providing a basis for a lawsuit
in American courts.”
“That inquiry asks whether plaintiffs have identified a close historical or common-
law analogue for their asserted injury. Spokeo does not require an exact duplicate
in American history and tradition. But Spokeo is not an open-ended invitation for
federal courts to loosen Article III based on contemporary, evolving beliefs about
what kinds of suits should be heard in federal courts.”
www.dlapiper.com 21TransUnion: Claims of future harm
The Court found “persuasive” the “argument that in a suit for damages, the mere
risk of future harm, standing alone, cannot qualify as a concrete harm….”
“Consider an example. Suppose that a woman drives home from work a quarter
mile ahead of a reckless driver who is dangerously swerving across lanes. The
reckless driver has exposed the woman to a risk of future harm, but the risk does
not materialize and the woman makes it home safely. As counsel for TransUnion
stated, that would ordinarily be cause for celebration, not a lawsuit. ”
www.dlapiper.com 22TransUnion: Early reactions
Maddox v. Bank of New York Mellon Tr. Co., N.A., 19 F.4th 58, 65 (2d Cir. 2021)
▪ Claim that the Bank didn’t file a satisfaction of mortgage in a timely way allegedly in
violation of a NY statute.
▪ “[R]isk [of future harm], which was not alleged to have materialized, cannot not form the
basis of Article III standing.” Reversing the suggestion in McMorris v. Carlos Lopez &
Assocs., LLC, 995 F.3d 295, 303 (2d Cir. 2021)
▪ “TransUnion established that in suits for damages plaintiffs cannot establish Article III
standing by relying entirely on a statutory violation or risk of future harm: No concrete
harm; no standing.”
www.dlapiper.com 23TransUnion: Early reactions
Lupia v. Medicredit, Inc., No. 20-1294, 2021 WL 3627103 (10th Cir. Aug. 17, 2021)
▪ Tenth Circuit held plaintiff had standing after receiving one unanswered phone call in
violation of FDCPA because “intrusion upon seclusion” is harm traditionally recognized by
American courts.
▪ “Though a single phone call may not intrude to the degree required at common law, that
phone call poses the same kind of harm recognized at common law—an unwanted
intrusion into a plaintiff's peace and quiet.”
▪ Found TransUnion distinguishable because the plaintiff in Lupia had asserted harm with
close relationship to common-law tort, which was not the case in TransUnion.
www.dlapiper.com 24TransUnion: Early reactions
Ward v. National Patient Account Services Solutions, Inc., 9 F.4th 357 (6th Cir. 2021)
▪ Consumer brought putative class action under the FDCPA, alleging that debt collector
failure to properly identify itself and the true meaning of its business when making calls
to consumers.
▪ The Sixth Circuit held that under TransUnion, the plaintiff “must show that [the debt
collector’]s failure to disclose its full identity in voice messages resembles a harm
traditionally regarded as providing a basis for a lawsuit.”
▪ Court rejected the plaintiff’s theory that the defendant’s conduct closely resembled the
harm of invasion of privacy, and thus, without an injury-in-fact, the plaintiff could not
demonstrate standing based on the statutory violations.
www.dlapiper.com 25TransUnion: Early reactions
Association of American Physicians & Surgeons v. United States Food and Drug
Association,No. 20-1784, 2021 WL 4097325 (6th Cir. Sept. 9, 2021)
▪ Nonprofit physician association brought suit against FDA alleging constitutional and
statutory violations under the Administrative Procedures Act for allowing the use of
hydroxychloroquine to treat COVID-19.
▪ The Sixth Circuit emphasized that under TransUnion, the plaintiffs must establish
standing by showing “an injury caused by another party’s invasion of its rights.” Thus,
merely alleging associational standing based on “disagreement” with the FDA’s action
would not be sufficient to establish an injury-in-fact.
www.dlapiper.com 26TransUnion: Early reactions
Mastel v. Miniclip SA, No. 221CV00124WBSKJN, 2021 WL 2983198
(E.D. Cal. July 15, 2021)
▪ Court found that the plaintiff in putative class action had standing to pursue claims under
California Constitution based on allegations smartphone app collected users’ personal
information.
▪ Defendants argued that, like in TransUnion, plaintiff had to show that personal
information was published to have standing.
▪ Court disagreed because “the closest historical analogue to plaintiff's invasion of privacy
claim under the California Constitution is not defamation, but other ‘invasion of privacy’
torts such as intrusion upon seclusion,” which required only allegations of “collecting
personal information without the plaintiff's consent.”
www.dlapiper.com 27Impact – State court litigation
Strategic use of remand motions
Proliferation of state court filings? Should you remove?
by plaintiffs
Award of the plaintiffs’ attorneys’ fees where the defendant removed, and
then argued lack of standing. Because there was no standing, the
defendant lacked an “objectively reasonable basis for seeking removal.”
www.dlapiper.com 28Privacy and Biometric Information Privacy Act (“BIPA”) www.dlapiper.com 29
Statutory Overview of BIPA (740 ILCS 14/1, et seq.)
740 ILCS 14/20 – Private right of action
▪ Any person aggrieved by a violation of this Act shall have a right of action in a State circuit court or as a
supplemental claim in federal district court against an offending party. A prevailing party may recover for
each violation:
1. against a private entity that negligently violates a provision of this Act, liquidated damages of $1,000
or actual damages, whichever is greater;
2. against a private entity that intentionally or recklessly violates a provision of this Act, liquidated
damages of $5,000 or actual damages, whichever is greater;
3. reasonable attorneys’ fees and costs, including expert witness fees and other litigation
expenses; and
4. other relief, including an injunction, as the State or federal court may deem appropriate.
www.dlapiper.com 30Privacy Class Actions
▪ Data Breaches and Article III Standing
‒ Actual injury verses potential risk of future harm (identity theft, etc.)
▪ Drivers Privacy Protection Act (DPPA))
▪ California Consumer Privacy Act (CCPA)
▪ Other state and federal privacy statutes
‒ Computer Fraud and Abuse Act (CFAA)
‒ Wiretap Act
‒ Intrusion on seclusion/privacy
▪ Illinois Biometric Information Privacy Act (BIPA)
www.dlapiper.com 31The BIPA Litigation Landscape
▪ Skyrocketing litigation in the last couple years
▪ Statutory damages potential plus attorneys’ fees
▪ Facebook case settled for $650 million
▪ Early cases involved employers and biometric timeclocks
▪ Increasingly, tech companies have become targets
▪ Mainly fingerprints, some face geometry but expanding rapidly
‒ Voiceprints (e.g., voice-controlled devices)
‒ Face geometry (e.g., phone apps, social networking sites, testing software)
‒ Fingerprints (e.g., the providers of biometric timeclocks)
▪ Open question of per transaction or one violation
▪ Courts typically unwilling to dispose of claims early
▪ No BIPA case has gone to trial
www.dlapiper.com 32Global Class Action Threats www.dlapiper.com 33
The Rise of Global Class Actions Jurisdictions with class actions/collective redress proceedings Argentina Japan Australia Lithuania Austria Mexico Brazil Netherlands Bulgaria New Zealand Canada Norway Chile Peru China Portugal Colombia Romania Costa Rica South Africa Czech Republic South Korea Finland Spain France Sweden Germany Switzerland Greece Taiwan Hungary Thailand India Turkey Ireland United Kingdom Israel United States Italy Uruguay www.dlapiper.com 34
A few notable themes
The global economy The intersection Consumer privacy and The growing expansion
and the emergence of of technology and data breaches are of litigation funding and
cost-effective traditional tort law recurring issues. GDPR its global implications
manufacturing and has local and global and US lawyers moving
supply hubs implications into Europe
www.dlapiper.com 35Collective Redress Directive
European
Reflects Third party
collective
"mass funding is Adverse
redress
harm" permitted costs
system –
scandals but framework
harmoni-
e.g. VW transparent
sation
Early stage
Damages dismissal for No scope for
Breaches of
and “manifestly retrospective
EU law
injunctions unfounded” claims
cases
www.dlapiper.com 36Timetable for Implementation
November 2020: Commencement
EU Parliament
authorized 24 months
to “transpose” Late 2022:
(introduce) into First actions
domestic law of under CRD
Members anticipated
States
www.dlapiper.com 37Government Enforcement Considerations www.dlapiper.com 38
Government Agencies ▪ A number of government agencies regulate and enforce consumer protection in the consumer goods, retail, and financial services industries, many with overlapping authority. ▪ Outside of financial services, the primary federal regulator is the Federal Trade Commission (“FTC”). ▪ For financial services issues relating to consumers, the Consumer Financial Protection Bureau (“CFPB”) has assumed the role of primary federal regulator, although the prudential bank regulators and the FTC also have enforcement authority in this space. www.dlapiper.com 39
Government Agencies ▪ The key consumer protection tool that applies to nearly all industries that touch consumers is the prohibition against unfair or deceptive acts or practices (“UDAP”). In the financial services space, federal law also prohibits “abusive” acts or practices (adding another “A” to UDAAP). ▪ State authorities, such as attorneys general, may also regulate and enforce the conduct of companies that touch consumers under state UDAP laws. ▪ Regulators may coordinate enforcement efforts. www.dlapiper.com 40
Overview of UDA(A)P
With the exception of the What is a deceptive act or What is an unfair act or
prohibition against practice? practice?
“abusive” practices that ▪ A deceptive act or ▪ An act or practice is unfair
the CFPB enforces, the practice is a when causes or is likely to
FTC and CFPB UDAP representation, cause substantial injury to
prohibitions are omission or practice that consumers that (i) is not
effectively the same. (i) is likely to mislead reasonably avoidable by
consumers acting consumers; and (ii) is not
reasonably under the outweighed by countervailing
circumstances; and (ii) benefits to consumers or to
is material. competition.
▪ Examples include small ▪ Example could include a failure
font disclaimers or to maintain reasonable and
omission of material appropriate data security. See
information. FTC v. Wyndham Worldwide,
799 F.3d 236 (3d Cir. 2015).
www.dlapiper.com 41Overview of UDA(A)P
What is an abusive act or practice? Recent example: Use of predominantly
▪ An abusive act or practice is one that English-language agreements to enroll
materially interferes with the ability of a clients in a financial product, when
consumer to understand a term or company knows that many of its clients
condition of a consumer financial product do not understand English, combined
or service; with omission and misrepresentation of
materials terms in the written agreement
▪ OR takes unreasonable advantage of:
during the enrollment process.
‒ (i) A lack of understanding on the part of Complaint, CFPB v. Nexus Services,
the consumer of the material risks, W.D. Va. (Feb. 22, 2021).
costs, or conditions of the product or
service; (ii) the inability of the consumer
to protect its interests in selecting or
using a consumer financial product or
service; or (iii) the reasonable reliance
by the consumer on a covered person to
act in the interests of the consumer.
www.dlapiper.com 42FTC UDAP Authority
FTC has the authority A recent Supreme Court FTC and Congress have
to bring a UDAP action decision, AMG Capital implemented a number of rules
administratively or in Mgmt., LLC v. FTC, under UDAP, including:
court, depending on stripped the FTC of the ▪ Telemarketing sales rule
the relief sought, authority to obtain
equitable relief (e.g., ▪ Endorsements and testimonials
among other things.
restitution) in many cases, rule
unless an FTC “rule” is ▪ Covid-19 Consumer Protection
violated. Act
▪ Prenotification Negative Option
Rule
▪ Advertising of Warranties of
Guarantees
www.dlapiper.com 43CFPB Authority
▪ CFPB has become the primary enforcement authority for UDAAP against consumer
financial services providers.
‒ The CFPB’s authority is broader than just banks and purely financial services
providers.
▪ The CFPB has been extremely active in enforcing UDAAP against financial services
providers.
▪ Significantly greater flexibility for obtaining equitable relief and restitution relating to
UDAP violations than does the FTC.
‒ Civil Money Penalties range from $5,953 to $1,190,546 per violation.
www.dlapiper.com 44Key and Emerging Issues
Equity
▪ Discrimination has historically been enforced by the FTC and CFPB under the Equal Credit Opportunity
Act (“ECOA”). However, there is momentum behind enforcing discrimination through UDAP.
▪ On March 16, the CFPB expanded its manual for examining UDAAP to include instances where
consumers are unfairly denied services on the basis of their race or other prohibited basis factors.
▪ New criteria to assess UDAAP compliance, including:
‒ “The entity has a process to prevent discrimination in relation to all aspects of consumer financial
products or services the entity offers or provides, which includes the evaluation of all policies,
procedures and processes for discrimination prior to implementation or making changes, and continued
monitoring for discrimination after implementation. “
‒ “The entity’s compliance program includes an established process for periodic analysis and monitoring
of all decision-making processes used in connection with consumer financial products or services, and
a process to take corrective action to address any potential UDAAP concerns related to their use,
including discrimination.”
‒ The entity has established policies and procedures to review, test, and monitor any decision-making
processes it uses for potential UDAAP concerns, including discrimination.
▪ 2021 FTC bulletin: the prohibition against UDAP “would include the sale or use of … racially biased
algorithms.”
www.dlapiper.com 45Key and Emerging Issues
Equity
▪ In April 2021, the CFPB and the bank regulatory agencies issued a request for information
(“RFI”) relating to the use of artificial intelligence (AI) and alternative data by financial
institutions.
▪ Relevant considerations include:
‒ Explainability (i.e., ability to explain how data leads to a specific outcome)
‒ Overfitting (i.e., where a model “learns” from patterns that are not representative of the
population as a whole)
‒ Dynamic Updating (i.e., model evolution as it learns from new data)
‒ Third Party Oversight
▪ In February 2022, CFPB issued an outline of proposals to prevent algorithmic bias in home
valuations.
www.dlapiper.com 46Key and Emerging Issues Technology ▪ Digital contracting: Regulators are increasingly focused on the adequacy of disclosures delivered via app. Recent judicial decisions have made clear that improperly designed online contracting processes may be deceptive under UDAAP, even where all other applicable requirements have been met. ▪ Data privacy: Regulators are particularly concerned about the security of consumer information, the bases for which such data is obtained, and whether consumers understand how and when their data will be used. ▪ Payment processing: Payment services are governed by targeted laws at the federal and state levels. However, practices and disclosures regarding fees and the ability to cancel and claw back transactions could trigger UDAAP concerns. www.dlapiper.com 47
Key and Emerging Issues Subscription Services ▪ FTC has issued a warning that it is ramping up its enforcement “in response to a rising number of complaints about the financial harms caused by deceptive sign up tactics, including unauthorized charges or ongoing billing that is impossible to cancel.” ▪ Expects institutions to “provide clear, up-front information,” regarding the sign-up process, obtain consumers’ informed consent, and “make cancellation easy.” ▪ California Automatic Renewal Law (ARL) amendments effective July 2022. Testimonials and Endorsements ▪ Fashion Nova recently entered into a $4.3 million settlement with the FTC to resolve allegations that it blocked negative reviews of its products from being posted to its website. ▪ Allegedly misrepresented that the product reviews on its website reflected the views of all purchasers who submitted reviews, when in fact it suppressed reviews with ratings lower than four stars out of five. ▪ On March 22, 2022, the CFPB issued guidance stating that it is generally deceptive to include a “gag clause” in contracts. Likewise potentially deceptive to limit the posting of negative reviews or manipulate reviews to trick or confuse customers. www.dlapiper.com 48
Key and Emerging Issues Junk Fees ▪ In January 2022, the CFPB issued a Request for Information seeking input on exploitative junk fees. ▪ Fees identified by the CFPB include overdraft fees, late fees, bill-pay fees, prepaid card fees, and closing cost and homebuying fees. ▪ Key issues include whether the fees were expected, whether consumers assumed the relevant service was covered by the baseline price, and fees that seemed too high for the services rendered. Covid-19 Practices ▪ Enforcement agencies are looking at everything from how PPP lenders processed loan applications to the relief provided by lenders in connection with Covid-19 hardships. www.dlapiper.com 49
Compliance Management Strategies and Mitigation of Class Action Risk www.dlapiper.com 50
Practical Tips
▪ The overall “net impression” that institutions create will remain a point of emphasis for
enforcement agencies.
‒ Disclosures to consumers should be clear and conspicuous and provide appropriate
information for consumers to make informed decisions.
‒ Would you want to know that information?
▪ Expect to see enforcement actions that push the envelope in terms of findings of “deception”
to consumers.
‒ SettleIt Consent Order (CFPB, April 13, 2021) (SettleIt “deemphasized” the costs of its
services).
▪ Identify and evaluate “hidden” practices.
‒ Issues that may not seem relevant to consumers are emerging as priority issues. E.g., use
of alternative data to market products or services.
www.dlapiper.com 51Practical Tips
▪ Monitor complaints closely
‒ Complaints often trigger investigations and civil litigation.
‒ What are the emerging trends, and can something be done to address customer concerns?
▪ Conduct periodic UDAAP risk assessments, to identify areas where hidden risks may exist.
▪ Ensure good customer service.
▪ Review product labels, warnings, customer disclosures, and advertisements carefully for
litigation and regulatory risk.
▪ Review public disclosures and promises regarding ESG - guarantees?
▪ Evaluate arbitration agreements and class action waivers.
www.dlapiper.com 52Thank you www.dlapiper.com 53
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