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Litigating to Dismiss: Triage and Posture Across No-Injury Class Actions

No-injury class actions now turn on an unresolved three-way circuit split. Learn to triage the case at intake, choose between 12(b)(1) and 12(b)(6), sequence preemptive Rule 23 attacks, and leave with a defense decision tree and an integrated motion playbook.
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JOIN PROGRAM

2026-09-09 14:30:00

Christopher Chorba

Gibson, Dunn & Crutcher LLP

Wesley Sze

Gibson, Dunn & Crutcher LLP

Erica Rutner

Cozen O'Connor

View speakers

Program Details

2026-09-09 14:30:00

2026-09-09 14:30:00

2h CLE Credits

2026-09-09 14:30:00

See credits by state

Christopher Chorba

Gibson, Dunn & Crutcher LLP

Wesley Sze

Gibson, Dunn & Crutcher LLP

Erica Rutner

Cozen O'Connor

View speakers

Program Details

2026-09-09 14:30:00

Program Details

2026-09-09 14:30:00

Over 1,000+ webinars

2026-09-09 14:30:00

Course Overview

In a no-injury class action, your forum picks your strategy before you do

2026-09-09 14:30:00

This is not the standing fight defense counsel litigated five years ago. The Supreme Court dismissed Labcorp as improvidently granted, over Justice Kavanaugh’s dissent. The three-way circuit split on uninjured class members remains unresolved. A pending certiorari petition threatens to shift the law midcase, and post-Alig decisions have raised the evidentiary showing required at certification.

The early choices carry consequences. Lead with a 12(b)(1) motion and the dismissal is jurisdictional, without preclusive reach. Lead with 12(b)(6) and an adverse ruling touches the merits. Fight standing in the wrong forum and you inflate settlement value instead of reducing exposure. Exclude uninjured members without a plan and the finality trap undercuts class-wide preclusion.

Attendees leave with a repeatable early-case decision tree for consumer products, data privacy, and statutory-damage class actions. They gain an integrated motion playbook tied to current 2025–2026 decisional law: which threshold vehicle to file, in what order, and how to embed Article III standing inside Rule 23 predominance. This is triage judgment, built for the intake call, not a doctrine walk-through.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Circuit Split Mapping
How the unresolved three-way circuit split on uninjured class members, left standing after the Labcorp DIG and Justice Kavanaugh’s dissent, drives forum-first analysis and motion sequencing strategy.
02
TransUnion Injury Assessment
How to assess named-plaintiff injury under TransUnion and its progeny, and the evidentiary showing certification now demands after Alig.
03
Injury Categorization Framework
How to categorize the plaintiff’s claimed injury at intake across data privacy and statutory damage claims to predict whether a standing motion will win.
04
Defense Decision Tree
How to weigh dismiss, settle, or fight on standing against settlement inflation risk, discovery posture, and the finality trap.
05
Threshold Vehicle Choice
How to choose between a 12(b)(1) jurisdictional motion and a 12(b)(6) merits motion, and the preclusion consequences each choice creates.
06
Preemptive Rule 23 Attack
How to force certification off the table through motions to strike class allegations and preemptive Rule 23 denial, embedding Article III standing within predominance while managing preclusion risk.

Program schedule

clock 2:30 pm - 3:30 pm EST

Triaging the No-Injury Class Action: Choosing Whether to Litigate for Dismissal

This session equips defense attorneys with a structured framework for triaging no-injury class actions at intake, before a defense strategy is locked in. Attendees will learn how to map their forum against the three-way circuit split on uninjured class members, assess named-plaintiff injury under TransUnion and its progeny, and weigh the dismiss-or-settle decision against settlement inflation risk, discovery posture, and the finality trap. Attorneys leave with a repeatable early-case decision tree applicable across consumer products, data privacy, and statutory-damage class litigation.

Christopher ChorbaChristopher Chorba
Wesley SzeWesley Sze
Erica RutnerErica Rutner
clock 3:40 pm - 4:40 pm EST

Sequencing the Threshold Motions and Driving the Early Exit

This session covers the procedural mechanics of building and sequencing an early-dismissal motion practice in no-injury class actions, from the 12(b)(1)/12(b)(6) threshold decision through preemptive Rule 23 denial motions and motions to strike class allegations. Attendees will learn how the unresolved threeway circuit split on uninjured class members shapes motion sequencing strategy, how to embed Article III standing arguments within Rule 23 predominance, and how to manage finality and preclusion risks created by jurisdictional versus merits dismissals. Attorneys leave with an integrated motion playbook tied to current 2025–2026 decisional law.

Christopher ChorbaChristopher Chorba
Wesley SzeWesley Sze
Erica RutnerErica Rutner
Christopher Chorba

Christopher Chorba

Gibson, Dunn & Crutcher LLP

Wesley Sze

Wesley Sze

Gibson, Dunn & Crutcher LLP

Erica Rutner

Erica Rutner

Cozen O'Connor

Christopher Chorba

Christopher Chorba

Gibson, Dunn & Crutcher LLP

Chris Chorba is co-chair of Gibson, Dunn & Crutcher’s Class Actions Practice Group. He specializes in defending class actions and complex litigation and has had substantial experience litigating a broad range of complex commercial matters at the trial and appellate level in California and throughout the country, and in multi-district litigation (MDLs). His litigation and counseling experience includes work for companies in every industry, including automotive, beauty/cosmetic, consumer products, education, entertainment, financial services, food and beverage, health care, insurance, life sciences, retail, social media, sports and gaming, technology, telecommunications, and utility/energy. Chris has been recognized in Chambers USA: America’s Leading Lawyers for Business and in The Best Lawyers in America for Commercial Litigation.

Education & Credentials

Chris received his J.D. from the University of Virginia School of Law in 2001, where he served on the Editorial Board of the Virginia Law Review, after graduating cum laude from the Georgetown University School of Foreign Service in 1996. He is admitted to practice before all state and federal courts in California, the Ninth Circuit Court of Appeals, and the Supreme Court of the United States.

Recognition & Leadership

Beyond his rankings in Chambers USA and The Best Lawyers in America for Commercial Litigation, Benchmark Litigation acknowledges Chris as a "Litigation Star," Law360 named him a "Class Action MVP," The National Law Journal identifies him as a "Trailblazer" for his work defending consumer class actions, and Lawdragon recognizes him among its "500 Leading Litigators in America" and "500 Leading Global Litigators."

Professional Involvement

Chris serves as Associate Editor of the American Bar Association's A Practitioner's Guide to Class Actions, co-authoring its chapters on due process challenges to the class device and on aggregation of penalties, and wrote the chapters on Business & Professions Code sections 17200 and 17500 and the Consumers Legal Remedies Act in California Civil Procedure Before Trial: Claims and Defenses (The Rutter Group). He served as Co-Chair of the Steering Committee for the Cambridge Forum on Defense of Class Action Litigation and speaks frequently on class certification, settlement drafting, and consumer litigation trends.

Experience

Chris is a nationally recognized authority on class action defense, including claims under California's Unfair Competition and False Advertising Laws, the Consumers Legal Remedies Act, the Lanham Act, and the Class Action Fairness Act of 2005. His results include denial of Rule 23(b)(2) and (b)(3) certification in a putative class action challenging the accuracy of Facebook's ad targeting; dismissal with prejudice of all statutory and common law fraud claims in nationwide multidistrict litigation (MDL 2827) over flagship smartphone devices, followed by a negotiated nationwide class settlement; dismissal of COPPA and California privacy claims against an entertainment company over YouTube video placement; decertification of a Telephone Consumer Protection Act class against a major technology company followed by summary judgment on the automatic telephone dialing system question; defeat of certification under every prong of Rule 23 in overpayment recovery class actions against a major health insurer; dismissal with prejudice of novel "car hacking" claims against Toyota for lack of Article III standing, defended on appeal; and appellate reversals of judgments totaling $295 million in three certified class actions.
Wesley Sze

Wesley Sze

Gibson, Dunn & Crutcher LLP

Wesley Sze is a litigation partner in Gibson, Dunn & Crutcher’s Class Actions Practice Group. Wesley represents leading companies in a wide range of complex litigation, with a focus on defending technology clients in class action and multidistrict litigation. He regularly advises and represents clients in litigation involving state and federal privacy laws, consumer protection statutes, and cybersecurity incidents. Wesley has been recognized by Law360 as a 2025 “Rising Star” in Class Actions and is also featured in Best Lawyers: Ones to Watch® in America for Appellate Practice.

Education & Credentials

Wesley received his J.D. from Stanford Law School in 2015, where he served as a Technical Managing Editor and Notes Editor of the Stanford Law Review; his note received the 2016 Scribes Law-Review Award for the best student-written article in a law review or journal. He earned his B.A. in Economics from the University of British Columbia in 2011, graduating as class valedictorian, and conducted monetary policy research at the Bank of Canada before law school. He is a member of the State Bar of California and is admitted in the U.S. Courts of Appeals for the Ninth and Tenth Circuits and the U.S. District Courts for the Northern, Central, and Southern Districts of California.

Recognition & Leadership

Law360 named Wesley a 2025 "Rising Star" in Class Actions, and Best Lawyers: Ones to Watch in America features him for Appellate Practice. At Gibson Dunn he practices in the Litigation Department as a member of the Class Actions; Privacy, Cybersecurity, and Data Innovation; and Securities Litigation Practice Groups.

Professional Involvement

Wesley maintains an active pro bono practice focused on immigrant rights and constitutional litigation. He has represented asylum seekers at every stage of the immigration process, won a preliminary injunction ordering the immediate reunification of an asylum seeker and her three-year-old son separated at the U.S.-Mexico border, and obtained an appellate order reversing the illegal seizure of veteran disability benefits from an inmate trust account.

Experience

Wesley's representations include defending a technology company in multidistrict class action litigation over its flagship mobile device; defending technology companies in class actions arising from alleged data security incidents; representing a cloud software provider in the first putative securities class action based on a direct listing on the New York Stock Exchange; and representing a cryptocurrency exchange in cryptoasset recovery litigation. He obtained a published California Court of Appeal opinion affirming dismissal of a putative "trespass to chattels" class action, secured decertification of a Telephone Consumer Protection Act class of more than 320,000 individuals, and won multiple orders quashing subpoenas that sought to unmask an anonymous blogger in violation of the First Amendment.
Erica Rutner

Erica Rutner

Cozen O'Connor

As a highly experienced commercial litigator, Erica focuses her practice primarily on the defense of consumer class actions. Erica has successfully managed and defended large scale class actions in federal and state jurisdictions across the country, ranging from claims involving consumer protection and privacy, data breach, products liability, health care, and discrimination. Drawing on her extensive experience defending both publicly traded and private companies in numerous “bet the company” cases, Erica has gained a steadfast track-record of securing dismissals, defeating class certification, obtaining summary judgment, and negotiating highly favorable class settlements for her clients. Erica is also intimately familiar with strategies for litigating complex class actions in an efficient and economical manner, ensuring that clients benefit from both cost-effective and high-quality representation. In addition, Erica proactively advises clients on long term risk mitigation strategies and works with companies to minimize future class action exposure.

Education & Credentials

Erica earned her B.A., summa cum laude, from Columbia University in 2006 and her J.D., summa cum laude, from the University of Miami School of Law in 2009, where she graduated Order of the Coif and was a member of the University of Miami Law Review. She is admitted to the Florida and California bars, the U.S. District Courts for the Middle, Northern, and Southern Districts of Florida and the Central, Southern, Northern, and Eastern Districts of California, and the U.S. Courts of Appeals for the Ninth and Eleventh Circuits.

Recognition & Leadership

Erica serves as the office managing partner of Cozen O'Connor's Fort Lauderdale office. Florida Trend's Legal Elite has named her among its Notable Women Leaders in Law from 2023 through 2025, the South Florida Legal Guide listed her among its Top Lawyers in 2021, and the Daily Business Review has featured her in Profiles in Law and On the Rise.

Professional Involvement

Erica serves as co-chair of a subcommittee to the American Bar Association's Mass Torts Committee and chaired the committee's Young Lawyers Division. She is a Fellow of the American Bar Foundation, a former member of the executive editorial board of the Florida Bar Journal, and a member of the Broward County Bar Association and the Florida Association for Women Lawyers.

Experience

Erica has managed and defended large-scale class actions in federal and state jurisdictions across the country, spanning consumer protection and privacy, data breach, products liability, health care, and discrimination claims, for both publicly traded and private companies. She regularly presents and publishes on key issues in consumer class action defense, including consumer standing, defect manifestation, ascertainability, and successive class action litigation, and advises clients on long-term strategies to minimize future class action exposure.
Christopher Chorba

Christopher Chorba

Gibson, Dunn & Crutcher LLP

Chris Chorba is co-chair of Gibson, Dunn & Crutcher’s Class Actions Practice Group. He specializes in defending class actions and complex litigation and has had substantial experience litigating a broad range of complex commercial matters at the trial and appellate level in California and throughout the country, and in multi-district litigation (MDLs). His litigation and counseling experience includes work for companies in every industry, including automotive, beauty/cosmetic, consumer products, education, entertainment, financial services, food and beverage, health care, insurance, life sciences, retail, social media, sports and gaming, technology, telecommunications, and utility/energy. Chris has been recognized in Chambers USA: America’s Leading Lawyers for Business and in The Best Lawyers in America for Commercial Litigation.

Education & Credentials

Chris received his J.D. from the University of Virginia School of Law in 2001, where he served on the Editorial Board of the Virginia Law Review, after graduating cum laude from the Georgetown University School of Foreign Service in 1996. He is admitted to practice before all state and federal courts in California, the Ninth Circuit Court of Appeals, and the Supreme Court of the United States.

Recognition & Leadership

Beyond his rankings in Chambers USA and The Best Lawyers in America for Commercial Litigation, Benchmark Litigation acknowledges Chris as a "Litigation Star," Law360 named him a "Class Action MVP," The National Law Journal identifies him as a "Trailblazer" for his work defending consumer class actions, and Lawdragon recognizes him among its "500 Leading Litigators in America" and "500 Leading Global Litigators."

Professional Involvement

Chris serves as Associate Editor of the American Bar Association's A Practitioner's Guide to Class Actions, co-authoring its chapters on due process challenges to the class device and on aggregation of penalties, and wrote the chapters on Business & Professions Code sections 17200 and 17500 and the Consumers Legal Remedies Act in California Civil Procedure Before Trial: Claims and Defenses (The Rutter Group). He served as Co-Chair of the Steering Committee for the Cambridge Forum on Defense of Class Action Litigation and speaks frequently on class certification, settlement drafting, and consumer litigation trends.

Experience

Chris is a nationally recognized authority on class action defense, including claims under California's Unfair Competition and False Advertising Laws, the Consumers Legal Remedies Act, the Lanham Act, and the Class Action Fairness Act of 2005. His results include denial of Rule 23(b)(2) and (b)(3) certification in a putative class action challenging the accuracy of Facebook's ad targeting; dismissal with prejudice of all statutory and common law fraud claims in nationwide multidistrict litigation (MDL 2827) over flagship smartphone devices, followed by a negotiated nationwide class settlement; dismissal of COPPA and California privacy claims against an entertainment company over YouTube video placement; decertification of a Telephone Consumer Protection Act class against a major technology company followed by summary judgment on the automatic telephone dialing system question; defeat of certification under every prong of Rule 23 in overpayment recovery class actions against a major health insurer; dismissal with prejudice of novel "car hacking" claims against Toyota for lack of Article III standing, defended on appeal; and appellate reversals of judgments totaling $295 million in three certified class actions.
Wesley Sze

Wesley Sze

Gibson, Dunn & Crutcher LLP

Wesley Sze is a litigation partner in Gibson, Dunn & Crutcher’s Class Actions Practice Group. Wesley represents leading companies in a wide range of complex litigation, with a focus on defending technology clients in class action and multidistrict litigation. He regularly advises and represents clients in litigation involving state and federal privacy laws, consumer protection statutes, and cybersecurity incidents. Wesley has been recognized by Law360 as a 2025 “Rising Star” in Class Actions and is also featured in Best Lawyers: Ones to Watch® in America for Appellate Practice.

Education & Credentials

Wesley received his J.D. from Stanford Law School in 2015, where he served as a Technical Managing Editor and Notes Editor of the Stanford Law Review; his note received the 2016 Scribes Law-Review Award for the best student-written article in a law review or journal. He earned his B.A. in Economics from the University of British Columbia in 2011, graduating as class valedictorian, and conducted monetary policy research at the Bank of Canada before law school. He is a member of the State Bar of California and is admitted in the U.S. Courts of Appeals for the Ninth and Tenth Circuits and the U.S. District Courts for the Northern, Central, and Southern Districts of California.

Recognition & Leadership

Law360 named Wesley a 2025 "Rising Star" in Class Actions, and Best Lawyers: Ones to Watch in America features him for Appellate Practice. At Gibson Dunn he practices in the Litigation Department as a member of the Class Actions; Privacy, Cybersecurity, and Data Innovation; and Securities Litigation Practice Groups.

Professional Involvement

Wesley maintains an active pro bono practice focused on immigrant rights and constitutional litigation. He has represented asylum seekers at every stage of the immigration process, won a preliminary injunction ordering the immediate reunification of an asylum seeker and her three-year-old son separated at the U.S.-Mexico border, and obtained an appellate order reversing the illegal seizure of veteran disability benefits from an inmate trust account.

Experience

Wesley's representations include defending a technology company in multidistrict class action litigation over its flagship mobile device; defending technology companies in class actions arising from alleged data security incidents; representing a cloud software provider in the first putative securities class action based on a direct listing on the New York Stock Exchange; and representing a cryptocurrency exchange in cryptoasset recovery litigation. He obtained a published California Court of Appeal opinion affirming dismissal of a putative "trespass to chattels" class action, secured decertification of a Telephone Consumer Protection Act class of more than 320,000 individuals, and won multiple orders quashing subpoenas that sought to unmask an anonymous blogger in violation of the First Amendment.
Erica Rutner

Erica Rutner

Cozen O'Connor

As a highly experienced commercial litigator, Erica focuses her practice primarily on the defense of consumer class actions. Erica has successfully managed and defended large scale class actions in federal and state jurisdictions across the country, ranging from claims involving consumer protection and privacy, data breach, products liability, health care, and discrimination. Drawing on her extensive experience defending both publicly traded and private companies in numerous “bet the company” cases, Erica has gained a steadfast track-record of securing dismissals, defeating class certification, obtaining summary judgment, and negotiating highly favorable class settlements for her clients. Erica is also intimately familiar with strategies for litigating complex class actions in an efficient and economical manner, ensuring that clients benefit from both cost-effective and high-quality representation. In addition, Erica proactively advises clients on long term risk mitigation strategies and works with companies to minimize future class action exposure.

Education & Credentials

Erica earned her B.A., summa cum laude, from Columbia University in 2006 and her J.D., summa cum laude, from the University of Miami School of Law in 2009, where she graduated Order of the Coif and was a member of the University of Miami Law Review. She is admitted to the Florida and California bars, the U.S. District Courts for the Middle, Northern, and Southern Districts of Florida and the Central, Southern, Northern, and Eastern Districts of California, and the U.S. Courts of Appeals for the Ninth and Eleventh Circuits.

Recognition & Leadership

Erica serves as the office managing partner of Cozen O'Connor's Fort Lauderdale office. Florida Trend's Legal Elite has named her among its Notable Women Leaders in Law from 2023 through 2025, the South Florida Legal Guide listed her among its Top Lawyers in 2021, and the Daily Business Review has featured her in Profiles in Law and On the Rise.

Professional Involvement

Erica serves as co-chair of a subcommittee to the American Bar Association's Mass Torts Committee and chaired the committee's Young Lawyers Division. She is a Fellow of the American Bar Foundation, a former member of the executive editorial board of the Florida Bar Journal, and a member of the Broward County Bar Association and the Florida Association for Women Lawyers.

Experience

Erica has managed and defended large-scale class actions in federal and state jurisdictions across the country, spanning consumer protection and privacy, data breach, products liability, health care, and discrimination claims, for both publicly traded and private companies. She regularly presents and publishes on key issues in consumer class action defense, including consumer standing, defect manifestation, ascertainability, and successive class action litigation, and advises clients on long-term strategies to minimize future class action exposure.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

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MCLE Credits

Alabama
Approved
2 General
Alaska
Approved
2 General
iOur programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Arizona
Approved
2 General
Arkansas
Approved
2 General
California
Approved
2 General
Colorado
Pending
2 General
Connecticut
Approved
2 General
Delaware
Pending
2 General
District of Columbia
No Required
No MCLE Required
Florida
Approved
2 General Hours
iReceive CLE credit in Florida via attorney submission.
Georgia
Approved
2 General
Hawaii
Approved
2 General
Idaho
Pending
2 General
Illinois
Approved
2 General
Indiana
Approved
2 General
Iowa
Pending
2 General
Kansas
Pending
2 Substantive
Kentucky
Pending
2 General
Louisiana
Pending
2 General
Maine
Pending
2 General
Maryland
No Required
2 CLE Hour(s)
Massachusetts
No Required
2 CLE Hour(s)
Michigan
No Required
2 CLE Hour(s)
Minnesota
Pending
2 General
Mississippi
Pending
2 General
Missouri
Approved
2.4 General
Montana
Pending
2 General
Nebraska
Pending
2 General
imyLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
Nevada
Approved
2 General
New Hampshire
Approved
120 General minutes
iAs of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey
Approved
2 General
iOur programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico
Approved
2 General
New York
Approved
2 General
iOur programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
North Carolina
Pending
2 General
North Dakota
Approved
2 General
iOur programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Ohio
Approved
2 General
Oklahoma
Pending
2.5 General
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Pending
2 General
Pennsylvania
Approved
2 General
Rhode Island
Pending
2.5 General
South Carolina
Pending
2 General
South Dakota
No Required
2 CLE Hour(s)
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Approved
2 General
Texas
Approved
2 General
Utah
Pending
2 General
Vermont
Approved
2 General
Virginia
Not Eligible
2 General Hours
Washington
Approved
2 Law & Legal Hours
iReceive CLE credit in Washington via attorney submission.
West Virginia
Pending
2.4 General
Wisconsin
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2 General
Wyoming
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2 General

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs