Abuse of Discretion Class Certification.

Byline: Derek Hawkins

7th Circuit Court of Appeals

Case Name: Christine Dancel v. Groupon, Inc.,

Case No.: 19-1831

Officials: BAUER, BRENNAN, and ST. EVE, Circuit Judges.

Focus: Abuse of Discretion Class Certification

Is a person's username a part of her identity? That is a complex question, but one that Christine Dancel proposes can be resolved categorically for all usernames and all people. The district court thought otherwise and declined to certify a class because it would have to be decided username-by-username whether each one is an aspect of a given class member's identity, at least as that word is defined by the Illinois Right of Publicity Act (IRPA), 765 ILCS 1075/5. Dancel contends this rejection of her theory was an improper decision on the merits of her and the class's claims, and the court therefore abused its...

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