According to a ruling issued on Monday, owners of 15-inch 2016 or newer MacBook Pros have failed to plead that the alleged product defect stemmed from fraud or unfair practices on the part of Apple Inc. Judge Edward J. Davila dismissed the consumers’ third amended complaint, partly with prejudice, after finding their California, New Jersey and other state law fraud and consumer protection claims inadequate.
The filing recounted the operative complaint’s allegations that in 2016 Apple updated its 13- and 15-inch MacBook Pro models, making them “thinner and sleeker” than preceding versions. To connect the lighting mechanism of the display screen to the display controller board, Apple reportedly used “thin, flexible backlight ribbon cables.”
The plaintiffs alleged that the cables were too short, and that the overall design caused the display cables to rub against the control board when the computer was opened and closed, eventually leading to cable tear. This reportedly triggered various problems with the display screen, in some instances causing a “stage lighting” effect, creating alternating patches of darkness along the bottom of the display, and in others, causing it to fail entirely.
Apple purportedly changed the design of newer MacBooks after the problem was reported. In the lawsuit, the plaintiffs alleged that Apple misrepresented the quality of the MacBooks.
Judge Davila first ruled that the plaintiffs failed to state a claim for fraud based on affirmative misrepresentations and on omission, noting that allegations relating to the former in the complaint’s last iteration were rejected as non-actionable puffery. The opinion considered whether the plaintiffs’ refreshed filing pleaded a design defect essential to the function and operation of the laptops, rather than one that merely denigrates the user experience.
The judge reasoned that allegations about the products’ veracity made in Apple’s marketing campaign, among other things, touting the laptop screens as the best in the industry, similarly failed to rise to the level of affirmative misrepresentation. With regard to its omission-based claims, the court held that Apple had a duty to disclose product safety hazards but not performance issues. Because the screen lighting issue complained of was unrelated to user safety, the court rejected all deceptive trade practice claims and the fraudulent concealment claim, though the court permitted leave to amend them.
Judge Davila also allowed the plaintiffs to amend their New Jersey Consumer Fraud Act claim to “plead facts suggesting that Apple knew with certainty that the Alleged Defect would occur.” The plaintiffs, represented by the Parris Law Firm, must submit their revised complaint by Aug. 2. Apple is represented by Weil, Gotshal & Manges LLP.
Notably, another product defect case pending in the Northern District of California concerns some MacBooks’ allegedly defective butterfly keyboards. In that lawsuit, Judge Davila certified a class of purchasers and several state subclasses in March.