‘Pay-Per-Click’ Facebook Claims Fail Tests For Class Certification; Too Much Individuality

Numerous questions demanding individualized inquiry related to both liability and damages arising out of Facebook’s alleged improper tabulation of “billable clicks” rendered breach of contract and unfair-business-practices claims of pay-per-click advertisers unsuitable for class certification, a federal district court ruled April 13 (In re Facebook Inc., PPC Advertising Litigation).

“[P]laintiffs have no classwide method to parse the millions of clicks in this case,” into valid, invalid, or fraudulent ones, Judge Phyllis J. Hamilton of the U.S. District Court for the Northern District of California held.

The plaintiffs in this case were customers of Facebook’s automated “self-service” advertising process, ...