Fairbanks

Plaintiffs and appellants Pauline Fairbanks and Michael Cobb appeal from an order denying their motion for class certification in their action against Farmers New World Life Insurance Company and Farmers Group, Inc. (collectively, Farmers). Plaintiffs’ action alleges violations of the unfair competition law (Bus. & Prof. Code, § 17200; henceforth UCL) 1 in connection with Farmers’s marketing and sale of universal life insurance policies. The trial court denied the motion for class certification on the basis that common issues did not prevail, specifically concluding that Farmers did not use a common marketing strategy with respect to the policies. As such, the trial court concluded that whether any proposed class member actually heard any alleged misrepresentation was an issue incapable of common proof, requiring denial of the class certification motion.

As substantial evidence supports the trial court’s factual finding, we affirm. On appeal, plaintiffs argue that the order denying class certification can be *547 reversed on bases other than those argued to the trial court below. Specifically, although they argued before the trial court that a class action should be…