Williams v. Apple, Inc.

Background

Andrea M. Williams and James Stewart filed a proposed class action against Apple, Inc. They alleged that Apple’s iCloud agreement represented that Apple provided the cloud-storage service and stored subscribers’ data, but that Apple instead sent the data to other entities, including Amazon and Microsoft, for storage. The plaintiffs alleged breach of contract, violations of California’s False Advertising Law (FAL), and violations of California’s Unfair Competition Law (UCL).

The plaintiffs sought money damages for breach of contract, restitution under the FAL and UCL, and an injunction requiring Apple to stop representing that it provided iCloud storage and to disclose which entities stored subscribers’ data. Apple’s motion addressed the request for injunctive relief and the FAL and UCL claims, but not the breach-of-contract claim.

Injunctive Relief and Standing

Apple argued that the plaintiffs lacked Article III standing to seek an injunction because they could not show a sufficient likelihood of future injury. Article III standing is the constitutional requirement that a plaintiff show an injury connected to the defendant’s conduct that a court can remedy.

The court had previously dismissed the request for injunctive relief with leave to amend because the original complaint did not allege that the plaintiffs were currently paying iCloud subscribers or intended to purchase iCloud storage again. The amended complaint alleged that both Williams and Stewart continued paying for iCloud and expected to continue doing so because they were concerned about what would happen to their stored data if they ended their subscriptions.

The court held that these allegations established standing under the Ninth Circuit’s decision in Davidson v. Kimberly-Clark Corporation. The court explained that Davidson did not limit standing to two specific categories of future harm; the categories discussed there were illustrations. A consumer who knows about an allegedly deceptive representation may still have standing to seek an injunction if the consumer is likely to continue purchasing the product and may be harmed by the inability to rely on the representation.

The court also found that the requested injunction was sufficiently related to the alleged harm. Requiring Apple to accurately disclose where the data was stored and which entity provided the storage could address the plaintiffs’ concerns about whether they could rely on the iCloud agreement. The court therefore denied Apple’s motion to dismiss the plaintiffs’ request for injunctive relief.

FAL and UCL Claims

Apple also argued that the FAL and UCL claims sought equitable relief even though the plaintiffs had an adequate remedy at law. Equitable relief is a non-monetary remedy, such as restitution or an injunction; an adequate remedy at law generally means money damages that can sufficiently address the injury.

The court agreed with Apple. It explained that FAL and UCL claims are equitable in nature and that federal courts cannot grant equitable relief when an adequate legal remedy exists. The plaintiffs conceded that their FAL and UCL claims were duplicative of their breach-of-contract claim for money damages and were based on the same factual allegations. The amended complaint also did not allege that legal remedies were inadequate or that the plaintiffs suffered irreparable injury.

The court rejected the plaintiffs’ reliance on Astiana v. Hain Celestial Group, Inc. and Davidson. It explained that Astiana concerned pleading unjust-enrichment claims in the alternative and that Davidson concerned Article III standing, not whether equitable claims could proceed when an adequate legal remedy existed. Relying in part on Sonner v. Premier Nutrition Corp., the court held that the breach-of-contract claim provided an adequate legal remedy.

The court dismissed the FAL and UCL claims with prejudice. It found amendment would be futile because the plaintiffs had previously been warned that failure to cure the identified deficiencies, including the adequate-remedy issue raised in Apple’s earlier motion, would result in dismissal with prejudice.

Disposition

The court granted in part and denied in part Apple’s motion to dismiss. It granted the motion to dismiss the FAL and UCL claims with prejudice and denied the motion to dismiss the request for injunctive relief. The motion did not challenge the breach-of-contract claim.

The opinion is signed by Lucy H. Koh, United States District Judge.