This post is from the non-Reed Smith side of the blog.
We
posted last week about In re Valsartan, Losartan, &
Irbesartan Products Liability Litigation, 2020 WL 7418006
(D.N.J. Dec. 18, 2020), a decision that came in just time to take a
sport on our Worst of 2020 post. Just as we were
expressing our displeasure with that decision, the court entered
another ruling. This time on standing and this time far from
all bad.
Last week's decision - In re Valsartan, Losartan, &
Irbesartan Products Liability Litigation, 2021 U.S. Dist.
LEXIS 5908 (D.N.J. Jan. 12, 2021) ("VLI 2") -
focused on 2 putative class actions: one for economic loss
and one for medical monitoring. Defendants moved to dismiss
on the grounds that plaintiffs lack standing. Specifically,
that plaintiffs failed to allege an injury in fact and/or an injury
that was traceable to each defendant and that plaintiffs improperly
assert claims under the laws of states in which they do not reside
or were
