On October 3, the Eleventh Circuit Court of Appeals affirmed the
district court's approval of a class settlement, an award of
attorney's fees to class counsel, and the provision of an
incentive award for the class representative. The court affirmed in
the face of objections to the class representative's Article
III standing, the notice pursuant to Rule 23(h), the award of
attorney's fees, and the incentive award to the class
representative.
The basic background is as follows. This class action alleged
violations of the Fair and Accurate Credit Transactions Act
(FACTA). Dr. Muransky filed his class action against Godiva
Chocolatier, Inc. for allegedly violating FACTA by giving him a
receipt that showed his credit card number's first six and last
four digits (FACTA prohibits merchants from printing "more
than the last 5 digits of the card number or the expiration date
upon any receipt provided to the cardholder at the point of the
sale or transaction.")