In January the California Supreme Court in Aryeh v. Canon Business Solutions, 55 Cal.4th 1185, ruled that equitable exceptions can be applied to the four-year statute of limitations under the state’s unfair competition law, Business & Professions Code §17200. The decision resurrected the plaintiff’s UCL claim, which lower courts had dismissed as time-barred. It also potentially opened the door to UCL claims in other cases asserting unfair acts that fall under common-law equitable exceptions that either delay accrual of claims or toll the statute of limitations. Most significantly, Aryeh may signal a new course for California antitrust jurisprudence in general, and UCL jurisprudence in particular, that could diverge from prior interpretations of analogous federal statutes.
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