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Pfizer v. Superior Court (Galfano)
California published appellate decision holding that (1) All class members, not just the named plaintiff, must have been "injured in business and property" by the deception; (2) The "likelihood to deceive" standard no longer exists, because "by reason of" means that actual reliance on any deception must be proven; and that (3) Each class member must prove such actual reliance.

The court itself acknowledges that its decision would decimate private UCL litigation, but decides that Prop. 64's language compels that result.

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