In re Samsung Galaxy Smartphone Marketing and Sales Practices Litigation.
5:16-cv-06391
| N.D. Cal. | Mar 30, 2018Background
- Plaintiffs (consumers) brought a putative class action alleging Galaxy S7, S6, S6 Edge, and Note5 phones are defective and risk overheating/explosion, citing Samsung’s Note7 recall as related evidence.
- Claims asserted under California, Massachusetts, and Maryland consumer-protection statutes and for unjust enrichment.
- Samsung moved to compel arbitration for some plaintiffs; this order addresses Samsung’s motion to dismiss claims for plaintiffs whose phones are not subject to arbitration.
- Court found personal jurisdiction lacking as to Maryland plaintiff Robison (bought phone and was injured in Maryland) and dismissed his claims for lack of jurisdiction.
- Court held several plaintiffs lack Article III standing (Jesus Vega lacked standing; no plaintiff sufficiently alleged an injury supporting injunctive relief).
- Court also dismissed consumer-protection and unjust-enrichment claims for failure to plead a specific, model-linked defect and that Samsung knew of the defect at sale; unjust enrichment additionally failed for not pleading choice of governing law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over Samsung for Maryland plaintiff Robison | Robison contends California court may hear claims despite purchase and injury occurring in Maryland | Samsung argues no general or specific jurisdiction exists because corporate domicile is outside California and suit-related conduct did not occur in California | Dismissed for lack of personal jurisdiction; Robison must satisfy Bristol-Myers standards for named out-of-forum plaintiff |
| Article III standing — Jesus Vega | Vega asserts injury from possession of a Note5 | Samsung argues Vega did not purchase the phone and thus lacks concrete injury | Vega dismissed for lack of Article III standing |
| Article III standing — injunctive relief | Plaintiffs seek prospective relief based on alleged defect and misleading conduct | Samsung argues plaintiffs lack a concrete, imminent risk of future harm per Davidson and Summers | Dismissed: plaintiffs failed to allege circumstances supporting future injury or inability to rely on labeling |
| Failure to plead consumer-protection claims | Plaintiffs allege phones are ‘‘unsafe’’ and cite various reports and Note7 recall to show defect and Samsung’s knowledge | Samsung argues allegations are conclusory, fail to identify a particular defect per model, and fail to plead Samsung’s prior knowledge at time of sale | Dismissed: claims fail for lack of specific defect allegations and insufficient facts showing Samsung knew of defect at time of sale |
| Unjust enrichment — governing law | Plaintiffs assert unjust enrichment as a common-law claim | Samsung notes plaintiffs did not identify which state law applies to unjust enrichment | Dismissed: failure to plead applicable state law governing unjust enrichment |
Key Cases Cited
- Daimler AG v. Bauman, 134 S. Ct. 746 (general jurisdiction requires affiliations rendering defendant at home in forum)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (general jurisdiction principles)
- Bristol-Myers Squibb Co. v. Superior Court of California, 137 S. Ct. 1773 (limits specific jurisdiction for out-of-forum plaintiffs in mass actions)
- Walden v. Fiore, 134 S. Ct. 1115 (specific jurisdiction requires suit-related conduct creating substantial connection to forum)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (Article III standing requires concrete injury in fact)
- Davidson v. Kimberly-Clark Corp., 873 F.3d 1103 (9th Cir.) (standing for injunctive relief in false-advertising cases requires risk of future harm or inability to rely on labeling)
- Wilson v. Hewlett-Packard Co., 668 F.3d 1136 (9th Cir.) (plaintiff must plead defendant’s knowledge of defect at time of sale to survive dismissal)
- Summers v. Earth Island Inst., 555 U.S. 488 (Article III requires actual and imminent, not conjectural, threat of future harm)
- In re TFT–LCD (Flat Panel) Antitrust Litig., 781 F. Supp. 2d 955 (N.D. Cal.) (requirement to specify governing state law for common-law claims)