On April 30, 2009, the Court of Appeal issued a decision in which it held that attorneys and their plaintiff, who never suffered an injury in fact from an alleged unfair act, never had standing to assert a class claim under California's Unfair Competition Law (the "UCL"), and was essentially a complete stranger to the action, could nevertheless use the discovery process to attempt to locate an actual plaintiff with standing under the UCL. [A copy of the opinion, Safeco v. Superior Ct., 173 Cal. App. 4th 814 (2004), can be found here.]

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