MarketFrank v. Gaos
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Frank v. Gaos

Frank v. Gaos, 586 U.S. ___ (2019), was a per curiam decision by the Supreme Court of the United States in a case concerning the practice of cy pres settlements in class action lawsuits. Following oral argument, the court asked the parties to submit supplemental briefs addressing whether the parties had Article III standing to pursue the case in federal courts. Supplemental briefing was completed on December 21, 2018. On March 20, 2019, the court remanded the case to the Ninth Circuit to address the plaintiffs’ standing in light of Spokeo, Inc. v. Robins.

Background and lower court decisions
In 2010, several individuals, including lead plaintiff Paloma Gaos, brought a class action against Google for allegedly leaking, in violation of privacy laws, information about their search terms to third parties by including search terms in the referrer header. In response to the settlement, Ted Frank and Melissa Holyoak of the Competitive Enterprise Institute, two of the 129 million unnamed members of the class being represented in the case, intervened to challenge the settlement on the grounds that it violated a procedural rule that such cy-pres settlements be "fair, reasonable and adequate." As Brian Miller of the Center for Individual Rights, in an opinion piece for Forbes, summarized the problem: ==Supreme Court appeal==
Supreme Court appeal
Frank filed a petition of certiorari in the U.S. Supreme Court. The Center for Constitutional Jurisprudence, Cato Institute, Center for Individual Rights, and Attorney General of Arizona, in a brief joined by 15 other states, filed amicus curiae briefs urging the court to grant certiorari. The court granted certiorari on April 30, 2018. The Solicitor General filed an amicus brief in support of neither party arguing that, before reaching the merits on the question presented, there is "considerable doubt whether the Court has Article III jurisdiction to address that question, because plaintiffs’ standing in the district court depended on a theory of injury that this Court subsequently rejected in Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016)" and that the court may wish to vacate and remand the case to address the issue of standing. Oral arguments were heard on October 31, 2018, with Frank having been one of the few Supreme Court attorneys ever to argue his own case. The justices were divided along partisan lines based on observers' opinions, with the liberal justices supporting the cy pres approach used, while the conservative members felt the cy pres decision denied the class members their restitution and were critical of how much of the settlement went to legal fees. Writing for SCOTUSblog, Ronald Mann noted that at oral argument "all seemed to agree that the district court’s reasoning could not withstand scrutiny under Spokeo. The point of disagreement seemed to be whether there was any prospect that the plaintiffs could identify some new argument that would satisfy Spokeo at this late date." The following week, the court ordered the parties and the Solicitor General "to file supplemental briefs addressing whether any named plaintiff has standing such that the federal courts have Article III jurisdiction over this dispute." ==Notes==
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