Dz Reserve v. Meta Platforms, Inc., 96 F.4th 1223

Meta Platforms, Inc. (formerly Facebook) appealed the district court’s certification of two classes of advertisers: a damages class (Rule 23(b)(3)) and an injunction class (Rule 23(b)(2)).
Advertisers alleged Meta misrepresented its 'Potential Reach' metric by claiming it estimated the number of people who could see ads; in reality, it estimated the number of accounts.
Plaintiffs claimed they paid more for advertisements than they would have with accurate information, asserting common law fraud and violation of California’s UCL.
The district court certified the damages class and injunction class; Meta appealed, challenging predominance, typicality, adequacy, and standing for injunctive relief.
The Ninth Circuit affirmed the damages class certification, holding that common issues predominated, but vacated and remanded the injunction class for a determination of standing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Predominance of Common Issues	Meta’s misrepresentation about Potential Reach applied to all class members, making the issue common.	No common misrepresentation—Potential Reach varied by advertiser and disclosures changed over time.	Common issues predominated; affirmed class certification.
Typicality/Adequacy	Named plaintiffs’ claims are representative; no unique defenses or credibility issues.	Named plaintiffs aren’t typical due to alleged non-reliance/credibility problems.	No clear error in finding typicality/adequacy; affirmed.
Presumption of Reliance	Reliance can be inferred class-wide when class exposed to same material misrepresentation.	Individualized reliance issues predominate; disclosures and information varied by advertiser.	Presumption of reliance applies; reliance is common issue.
Standing for Injunctive Relief	Both named plaintiffs can seek injunctive relief under UCL.	Neither plaintiff has standing for injunctive relief; businesses ceased operations.	Vacated, remanded for district court to determine standing.

Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (test for predominance in class actions).
Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (commonality and merits overlap in class cert).
Amgen Inc. v. Conn. Ret. Plans & Tr. Funds, 568 U.S. 455 (materiality as a class-wide issue).
Erica P. John Fund, Inc. v. Halliburton Co., 563 U.S. 804 (elements inquiry for class claims).
Basic Inc. v. Levinson, 485 U.S. 224 (federal presumption of reliance standard).
Olean Wholesale Grocery Coop., Inc. v. Bumble Bee Foods LLC, 31 F.4th 651 (rule for predominance and class adjudication in the 9th Circuit).
Engalla v. Permanente Med. Grp., Inc., 15 Cal. 4th 951 (elements of fraud and presumption of reliance under California law).
Vasquez v. Superior Ct., 4 Cal. 3d 800 (California presumption of reliance for class action fraud).
Berger v. Home Depot USA, Inc., 741 F.3d 1061 (individualized issues defeating class certification in fraud claims).