Hughes v. Apple, Inc., 3:22-cv-07668

Plaintiffs sued Apple, Inc. alleging design and negligence-based defects in the AirTag device, focusing on harms caused by stalking incidents facilitated by AirTag's alleged safety flaws.
Plaintiffs consist of both California and non-California residents, with varying connections to Apple's Software License Agreement (SLA) and iOS devices.
The lawsuit challenges not only product defects but also Apple's business practices under California's Unfair Competition Law (UCL) and other state product liability and tort theories.
Apple moved to dismiss, arguing improper choice of law, lack of standing, failure to plead certain claims, and absence of proximate cause.
The court reviewed both previously dismissed claims and new or amended claims from an updated complaint.
The opinion rules on whether California law governs, the sufficiency of each claim, and the standing and causation aspects for various plaintiffs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of California law	Claims covered by SLA, substantial relationship to California	Other states' laws should apply, especially for non-California plaintiffs	California law applies to iOS plaintiffs and non-iOS plaintiffs with ties to California, unless Apple shows fundamental policy conflict
Product liability claims (non-CA plaintiffs)	No need to address choice of law at this stage	Some states materially differ (no strict liability, alternative design requirement)	Product liability claims dismissed for certain states due to material legal differences; negligence claims remain
UCL and standing	Plaintiffs lost money/property, incurred legal fees, or lost income	Legal fees or unearned wages do not confer standing	Most plaintiffs have UCL standing; legal fees and lost wages can establish standing for injunctive relief
Proximate cause	Product defects in AirTag/iOS caused injuries even if stalker known or police conduct contributed	Plaintiffs' injuries not caused by Apple; safety features worked	Most plaintiffs plausibly allege causation; one claim dismissed where safety features worked as intended
Unjust enrichment	Sought restitution as remedy	Remedy at law adequate; no need for restitution	Unjust enrichment claim dismissed without leave to amend
Article III standing for class	All plaintiffs harmed or at risk of harm	No injury for class members not stalked	Named plaintiffs have standing, but nationwide class is unlikely to be certified

Nedlloyd Lines v. Superior Court, 3 Cal. 4th 459 (Cal. 1992) (standard for enforcing contractual choice-of-law clauses)
Washington Mutual Bank v. Superior Court, 24 Cal. 4th 906 (Cal. 2001) (choice-of-law burdens and government interest test)
Mazza v. American Honda Motor Co., 666 F.3d 581 (9th Cir. 2012) (place of the wrong and competing state interests for consumer claims)
Kwikset Corp. v. Superior Ct., 51 Cal. 4th 310 (Cal. 2011) (UCL standing and definition of economic injury)
Sullivan v. Oracle Corp., 51 Cal. 4th 1191 (Cal. 2011) (extraterritorial reach of UCL)
Nationwide Biweekly Administration, Inc. v. Superior Court, 9 Cal. 5th 279 (Cal. 2020) (tests for unfairness under UCL)
Modisette v. Apple, 30 Cal. App. 5th 136 (Cal. Ct. App. 2018) (proximate cause as a fact question)
Hartford Casualty Insurance Co. v. J.R. Marketing, L.L.C., 61 Cal. 4th 988 (Cal. 2015) (restitution/unjust enrichment as an equitable claim where no adequate remedy at law)