In 2001, New York’s consumer fraud statute, General Business Law Article 22-A, GBL �349 et seq. was the subject of a number of noteworthy decisions.

The Court of Appeals addressed �349 in Gaidon v. Guardian Life Ins. Co.[1]� In 1999 it had ruled that an insurer engaged in deceptive practices by promoting sales of its “vanishing premium” policies by representing that, after a specified period, the policies’ dividends would cover the premium costs.[2]�