Hall

Introduction

A plaintiff must have suffered an “injury in fact” and have “lost money or property as a result of the unfair competition” (Bus. & Prof. Code, § 17204) to have standing to pursue either an individual or a representative claim under the California unfair competition law (UCL; Bus. & Prof. Code, § 17200 et seq.) We hold the phrase “as a result of’ in the UCL imposes a causation requirement; that is, the alleged unfair competition must have caused the plaintiff to lose money or property.

Because plaintiff Jeffrey R. Hall alleged neither injury in fact nor causation, he lacked standing to pursue a UCL claim against Time Inc., Time Warner Inc., and Time Inc. Home Entertainment (collectively, Time). Thus, the trial court correctly granted Time Inc. and Time Warner Inc.’s motion for judgment on the pleadings and sustained Time Inc. Home Entertainment’s demurrer to Hall’s first amended complaint. We affirm the resulting judgment.

Allegations

The first amended complaint (the complaint) alleged Time engaged in a scheme by which it induced consumers to purchase books by offering a “ ‘free preview period’ ” during which the consumer had 21 days in which to review the…