Washington v. Chimei Innolux Corp.

This appeal presents the question, inter alia, of whether parens patriae actions filed by state Attorneys General constitute class actions within the meaning of the Class Action Fairness Act of 2005 (“CAFA”), Pub.L. No. 109-2, 119 Stat. 4 (codified at 28 U.S.C. §§ 1332 (d), 1453, 1711-15). We conclude that they do not, and we affirm the remand order entered by the district court.

I

The Attorneys General of Washington and California filed parens patriae actions in their states’ courts alleging that Defendants engaged in a conspiracy to fix the prices of thin-film transistor liquid crystal display (“TFT-LCD”) panels, and that state agencies and consumers were injured by paying inflated prices for products containing TFT-LCD panels.

The complaints allege that between 1998 and 2006, Defendants engaged in an international conspiracy to fix the prices of TFT-LCD panels in violation of state antitrust laws, which resulted in higher prices for state agencies and citizens purchasing products containing TFT-LCD panels.

The Attorney General of Washington, in the name of the state and as parens patriae on behalf of state citizens, filed an antitrust lawsuit against Defendants in…