The denial of the 23(b)(3) damages class is a meaningful win for Ralph Lauren that removes the largest financial threat from this litigation. However, the 23(b)(2) injunctive class still requires monitoring as compliance costs and potential injunctive remedies are determined. Watch for any appeal by plaintiffs on the 23(b)(3) ruling and for upcoming case management conference on August 4 for next steps.
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Executive Summary
In a mixed ruling on class certification in Merrell v. Ralph Lauren, the Northern District of California granted a nationwide 23(b)(2) injunctive class over Ralph Lauren's website accessibility but denied the 23(b)(3) California subclass for statutory damages, finding that individualized issues of intent and standing predominate. The denial of the damages class materially reduces Ralph Lauren's monetary exposure, while the injunctive class primarily creates compliance cost risk. The court also partially granted and partially denied cross-motions to exclude experts.
Court Ruling Details
Key Facts
- Court denied class certification under Rule 23(b)(3) for the California subclass seeking Unruh Act damages due to predominance of individualized issues (bona fide intent, which store-linked features encountered).
- Court granted class certification under Rule 23(b)(2) for a nationwide injunctive relief class requiring Ralph Lauren to bring its website into ADA compliance.
- Ralph Lauren's motion to exclude Dr. Krosnick's expert survey was denied; motion to exclude Dr. Easttom was granted in part (legal conclusions excluded) and denied otherwise.
- Plaintiff's motion to exclude Aaron Cannon's expert testimony was granted in part (untimely rebuttal opinions struck) and denied otherwise.
- Lead plaintiff Richard Paul Merrell appointed class representative; Wilshire Law Firm appointed class counsel.
- Case management conference set for August 4, 2026.
Financial Impact
Denial of 23(b)(3) class eliminates the risk of aggregate statutory damages (potentially $4,000+ per class member for thousands of California residents) potentially saving tens of millions of dollars in monetary exposure. Injunctive relief certification creates compliance costs to bring website up to WCAG standards, which are manageable for a $23B market cap company.
Risk Factors
- Plaintiffs may appeal the denial of the 23(b)(3) class to the Ninth Circuit, which could reverse and reinstate the damages class.
- Even without a damages class, the injunctive class may result in court-ordered website modifications that could cost millions to implement.
- Adverse factual findings on ADA liability could still lead to an injunction with ongoing monitoring costs.
Market Snapshot
Investment Themes
Documents Analyzed
This report is based on 1 court opinion from CourtListener.
| Document | Accession Number |
|---|---|
| COURT-RULING Data (Synthetic) | court-22f7b6ae89-RL |
Track record builds as more directional reports settle.
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Aug 14, 2026 7w ago | Court Ruling | $388.92 $341.43 | ▼ −12.21% | ▼ −10.22% | $361.34 (−7.09%) |
Aug 12, 2026 7w ago | Court Ruling | $396.35 $336.67 | ▼ −15.06% | ▼ −13.16% | $361.34 (−8.83%) |
Aug 6, 2026 8w ago | 8-K | $395.83 $344.20 | ▼ −13.04% | ▼ −13.64% | $361.34 (−8.71%) |
Jul 9, 2026 12w ago | Court Ruling | $387.58 $395.83 | ▲ +2.13% | ▼ −0.11% | $361.34 (−6.77%) |
May 21, 2026 19w ago | 8-K | $374.90 $410.37 | ▲ +9.46% | ▲ +9.13% | $361.34 (−3.62%) |
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