In re Samsung Galaxy Smartphone Marketing and Sales Practices Litigation.
5:16-cv-06391
N.D. Cal.Dec 24, 2020Background
- Plaintiffs sued Samsung over alleged overheating/fire risks in four models (Galaxy S6, S6 Edge, S7, Note5), claiming those phones shared defects with the recalled Note7 lithium‑ion batteries.
- Plaintiffs alleged omission‑based consumer claims (CLRA, FAL, UCL) and unjust enrichment based on nondisclosure of the alleged defect; they did not allege any thermal‑runaway events in their own devices.
- The case had earlier pleadings dismissed and some plaintiffs compelled to arbitration; the court allowed a final amendment after a stay and warned this would be plaintiffs’ last chance.
- SAC relied on consumer complaints, CPSC/saferproducts reports, and Note7 root‑cause materials; the court took judicial notice of limited external materials (Note7 recall page, a giffgaff article, and a Consumer Reports piece).
- Defendants moved to dismiss under Rule 9(b) and Rule 12(b)(6); the court found plaintiffs failed to plead a plausible common defect or pre‑sale knowledge and dismissed all claims with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of a common defect in Subject Phones | Subject Phones share Note7 design/manufacturer battery characteristics causing overheating | Similarities are general (non‑removable batteries are industry standard); different suppliers/specs undermine common defect | Dismissed — plaintiffs failed to plead the specific defect or a plausible common causal mechanism |
| Pre‑sale knowledge / duty to disclose | Samsung knew of battery problems based on consumer reports and post‑Note7 measures (Eight‑Point Check) | Complaints are few, often post‑purchase or concern other models/chargers; no plausible pre‑sale knowledge | Dismissed — insufficient pre‑sale knowledge pleaded; consumer reports do not show notice of defect before purchases |
| Statutory claims (CLRA, FAL, UCL) based on omissions/partial representations | Omissions actionable because Samsung had a duty to disclose defects and marketed phones as "durable/reliable" | No duty to disclose absent knowledge; durability statements are puffery; FAL requires knowledge of falsity | Dismissed with prejudice — omission claims fail because plaintiffs did not plead defendant knowledge or duty to disclose |
| Unjust enrichment / restitution remedy | Samsung was unjustly enriched by charging premium for phones with undisclosed defects | Claim requires plausible underlying fraud/defect; warranties and contract principles may preclude restitution | Dismissed with prejudice — no viable theory because plaintiffs failed to plead defect/knowledge; restitution unavailable on pleaded facts |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard and evaluating factual allegations)
- Cafasso v. Gen. Dynamics C4 Sys., Inc., 637 F.3d 1047 (Rule 9(b) "who, what, when, where, how" standard)
- United States v. United Healthcare Ins. Co., 848 F.3d 1161 (knowledge need not be pled with particularity)
- In re Gilead Scis. Sec. Litig., 536 F.3d 1049 (court need not accept conclusory allegations)
- Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988 (incorporation‑by‑reference and judicial notice principles)
- Wilson v. Hewlett‑Packard Co., 668 F.3d 1136 (duty to disclose and CLRA standards)
- Daugherty v. American Honda Motor Co., 144 Cal. App. 4th 824 (omission actionable only when duty to disclose exists)
- Cel‑Tech Commc'ns, Inc. v. Los Angeles Cellular Tel. Co., 20 Cal. 4th 163 (UCL framework: unlawful, unfair, fraudulent prongs)