On January 13, 2017, the Ninth Circuit vacated the lower court's decision to decertify a class and dismissed a plaintiff's case against a large furniture retailer, finding that the plaintiff failed to plead the concrete harm necessary under Spokeo for standing to bring suit. This case stemmed from allegations that the retailer illegally collected customer zip code data. The appellate panel based its decision on the plaintiff's own concession that she lacked standing in federal court because she had failed to allege more than a bare procedural violation.

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