Defendants’ efforts to sway the Court that adjudication of claims under UCL would splinter into a multitude of individualized issues failed. As reasoned by the Court, the solicitation materials “all are alleged to contain the same, or almost the same, combination of deceptive features.” See id., at 10, 12. Moreover, defendants’ claim that individualized inquiry would be required to determine whether each class member’s credit score increased was also rejected, as the Court deemed that this fact bore no relation to the plaintiffs’ claimed misrepresentations. See id., at 10. As reasoned by the Court, common issues predominated insfar as Defendants' liability would be adjudicated based on common proof without inquiry into the individual circumstances of each class member:
[I]n In re Tobacco II Cases, the California Supreme Court held that only the named plaintiff in a UCL class action need demonstrate injury and causation.
Here, Plaintiffs may prove with generalized evidence that Defendants' conduct was "likely to deceive" members of the public. The individual circumstances of each class member's credit card application need not be examined because the unnamed class members are not required to prove reliance and damage. Common issues will thus predominate on the UCL claim.See Greenwood, 2010 U.S. Dist. LEXIS 3839, at 20-21.