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Within a month, the 9th Circuit denied class certification when it refused to presume that an entire class relied on a product’s advertisements, but a small claims court awarded an individual plaintiff nearly $10,000 after she opted out of a similar class action. The two outcomes illustrate the effect of companies’ pleas for case-by-case relief: Consumers may heed recent decisions in Mazza and Wal-Mart and seek individual adjudication, but if they keep winning awards that are faster and more lucrative than a class action coupon, class settlement hearings may see more pushback from courts and objections by attorneys general.

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