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Defendant’S Memorandum

Date
2026-08-28

Summary

Defendant Bank of America, N.A.'s Memorandum of Points and Authorities in Support of its Motion for Class Decertification in In re: Bank of America California Unemployment Benefits Litigation, Case No. 3:21-md-02992-GPC-MSB, in the U.S. District Court for the Southern District of California, filed June 8, 2026 as Document 733-1, provisionally under seal. The motion is noticed for hearing on August 28, 2026 before Hon. Gonzalo P. Curiel. Bank of America argues that the certified classes of 109,414 EDD benefits cardholders include claimants it says obtained benefits through fraud, that plaintiffs bear the burden to exclude them, and that the resulting individual trials defeat predominance. It relies on Healy v. Milliman, Inc. and TransUnion LLC v. Ramirez and describes Department of Labor fraud alerts. The 31-page brief is signed by Goodwin Procter LLP, Jones Day and Meyers Nave.

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                 Case 3:21-md-02992-GPC-MSB         Document 733-1   Filed 06/08/26   PageID.61342
                                                     Page 1 of 31


                      1   JAMES W. MCGARRY (pro hac vice)
                          JMcGarry@goodwinlaw.com
                      2   GOODWIN PROCTER LLP
                      3   100 Northern Avenue
                          Boston, MA 02210
                      4   Tel.: +1 617 570 1000
                          Fax: +1 617 523 1231
                      5
                          SABRINA M. ROSE-SMITH (pro hac vice)
                      6   SRoseSmith@goodwinlaw.com
                      7   MATTHEW L. RIFFEE (pro hac vice)
                          MRiffee@goodwinlaw.com
                      8   GOODWIN PROCTER LLP
                          1900 N Street, NW
                      9   Washington, DC 20036
                  10
                          Tel.: +1 202 346 4000
                          Fax: +1 202 346 4444
                  11
                          Attorneys for Defendant
                  12      BANK OF AMERICA, N.A.
                  13      [ADDITIONAL COUNSEL LISTED IN SIGNATURE BLOCK]
                  14

                  15
                                          UNITED STATES DISTRICT COURT
                                    FOR THE SOUTHERN DISTRICT OF CALIFORNIA
                  16                           SAN DIEGO DIVISION
                  17      IN RE: BANK OF AMERICA         Case No. 3: 21-MD-02992-GPC-MSB
                          CALIFORNIA UNEMPLOYMENT
                  18      BENEFITS LITIGATION            DEFENDANT’S MEMORANDUM
                                                         OF POINTS AND AUTHORITIES IN
                  19                                     SUPPORT OF ITS MOTION FOR
                  20                                     CLASS DECERTIFICATION

                  21                                             Date:     August 28, 2026
                                                                 Time:     1:30 p.m.
                  22                                             Ctrm:     12A – 12th Floor
                                                                 Judge:    Hon. Gonzalo P. Curiel
                  23

                  24                                             FILED PROVISIONALLY UNDER SEAL
                                                                 PURSUANT TO STIPULATED PROTECTIVE
                  25                                             ORDER

                  26

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GOODWIN PROCTER LLP
   ATTORNEYS AT LAW



                          MEMO. ISO DECERT. MOT.                           CASE NO. 3: 21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB                       Document 733-1             Filed 06/08/26          PageID.61343
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                      1                                            TABLE OF CONTENTS
                      2                                                                                                                    Page
                      3   BACKGROUND ....................................................................................................... 5
                      4      A.         The Department of Labor Benefits Fraud Investigation ............................ 5
                      5      B.        The May 21, 2026 Hearing.......................................................................... 8
                      6   STANDARD OF LAW ........................................................................................... 10
                      7   ARGUMENT ........................................................................................................... 10
                      8      I.        Plaintiffs cannot carry their rule 23 burden with a
                      9                fraud-infested class. ................................................................................... 11
                  10              A.     The burden of proof remains with plaintiffs. .......................................... 11
                  11              B.     The need for                                 of individual mini-
                  12                     (or full trials) requires decertification. .................................................... 17
                  13         II.       This court did not, and cannot, certify a “bifurcated” class. ..................... 20
                  14         III.      This case cannot play out with common inquiries predominating............ 22
                  15      CONCLUSION........................................................................................................ 24
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                          MEMO. ISO DECERT. MOT.                                                     CASE NO. 3:21-MD-02992-GPC-MSB
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                      1                                        TABLE OF AUTHORITIES
                      2                                                                                                             Page(s)
                      3   Cases
                      4   In re Asacol Antitrust Litig.,
                              907 F.3d 42 (1st Cir. 2018) .......................................................................... 18, 24
                      5

                      6   Bowerman v. Field Asset Servs., Inc.,
                            60 F.4th 459 (9th Cir. 2023) ............................................................. 17, 18, 21, 24
                      7
                          Brown v. DirecTV, LLC,
                      8
                             562 F. Supp. 3d 590 (C.D. Cal. 2021) ................................................................ 12
                      9
                          Brown v. Google, LLC,
                  10         2022 WL 17961497 (N.D. Cal. Dec. 12, 2022) ................................................. 19
                  11
                          Cruz v. Dollar Tree Stores, Inc.,
                  12        270 F.R.D. 499 (N.D. Cal. 2010) ....................................................................... 10
                  13      DaimlerChrysler Corp. v. Cuno,
                  14        547 U.S. 332 (2006) ........................................................................................... 14
                  15      D.C. ex rel. Garter v. Cnty. of San Diego,
                  16
                            2018 WL 692252 (S.D. Cal. Feb. 1, 2018) ........................................................ 22

                  17      Halliburton Co. v. Erica P. John Fund, Inc.,
                            573 U.S. 258 (2014) ........................................................................................... 10
                  18

                  19
                          Healy v. Milliman, Inc.,
                            164 F.4th 701 (9th Cir. 2026) ............................................................. 4, 11, 14, 21
                  20
                          Heredia v. Eddie Bauer LLC,
                  21        2020 WL 127489 (N.D. Cal. Jan. 10, 2020) ............................................... passim
                  22
                          Hernandez v. WM Wholesale, LLC,
                  23        2025 WL 2556591 (C.D. Cal. Aug. 18, 2025) ................................................... 16
                  24
                          Herskowitz v. Apple, Inc.,
                  25        301 F.R.D. 460 (N.D. Cal. 2014) ....................................................................... 22
                  26      Mabanta v. Prime Now LLC,
                  27        2022 WL 1601415 (N.D. Cal. Feb. 28, 2022) ........................................ 14, 15, 16

                  28
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                          MEMO. ISO DECERT. MOT.                                                  CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   Officers for Just. v. Civ. Serv. Comm’n of City & Cnty. of S.F.,
                      2      688 F.2d 615 (9th Cir. 1982) .............................................................................. 10

                      3   Olean Wholesale Grocery Coop., Inc. v. Bumble Bee Foods LLC,
                             31 F.4th 651 (9th Cir. 2022) ........................................................................ passim
                      4

                      5   Pennington v. Tetra Tech, Inc.,
                            2024 WL 5213095 (N.D. Cal. Dec. 23, 2024) ................................................... 20
                      6
                          Rahman v. Mott’s LLP,
                      7
                            2014 WL 6815779 (N.D. Cal. Dec. 3, 2014) ............................................... 21, 24
                      8
                          Reitman v. Champion Petfoods USA, Inc.,
                      9      830 F. App’x 880 (9th Cir. 2020) ....................................................................... 21
                  10
                          Ries v. Ariz. Beverages USA LLC,
                  11         2013 WL 1287416 (N.D. Cal. Mar. 28, 2013) ............................................. 10, 11
                  12      Saavedra v. Eli Lilly & Co.,
                  13         2014 WL 7338930 (C.D. Cal. Dec. 18, 2014) ................................................... 20
                  14      Stearns v. Ticketmaster Corp.,
                  15
                             655 F.3d 1013 (9th Cir. 2011) ...................................................................... 12, 13

                  16      TransUnion LLC v. Ramirez,
                             594 U.S. 413 (2021) ........................................................................... 4, 11, 12, 13
                  17

                  18
                          Ugas v. H&R Block Enters., LLC,
                            2012 WL 5230297 (C.D. Cal. July 9, 2012) ................................................ 10, 23
                  19
                          Valentino v. Carter-Wallace, Inc.,
                  20         97 F.3d 1227 (9th Cir. 1996) .............................................................................. 20
                  21
                          Van v. LLR, Inc.,
                  22        61 F.4th 1053 (9th Cir. 2023) ................................................................. 11, 16, 17
                  23      Wal-Mart Stores, Inc. v. Dukes,
                  24        564 U.S. 338 (2011) ................................................................................. 3, 12, 24
                  25      Statutes
                  26
                          5 U.S.C. § 403(a) ....................................................................................................... 9
                  27
                          15 U.S.C. § 1693m(a)(2)(B) .................................................................................... 18
                  28
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   ATTORNEYS AT LAW
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                          MEMO. ISO DECERT. MOT.                                                      CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB                     Document 733-1             Filed 06/08/26         PageID.61346
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                      1   Other Authorities
                      2
                          Fed. R. Civ. P. 23(c) .................................................................................... 10, 20, 21
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                          MEMO. ISO DECERT. MOT.                                                   CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB           Document 733-1     Filed 06/08/26   PageID.61347
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                      1          Last June, this Court certified several classes comprised of 109,414 EDD
                      2   benefits cardholders alleging that Bank of America improperly denied their disputes
                      3   of allegedly unauthorized ATM transactions. In opposing class certification, Bank of
                      4   America showed that any damages award to these classes would necessarily result in
                      5   cash payments to criminal fraudsters, including
                      6

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                  14      ECF 350-8 ¶¶ 13–14.
                  15             The second group of criminals could not be identified by Bank of America at
                  16      all, because the information necessary to investigate eligibility fraud for EDD
                  17      benefits resided (and still resides) with the government authorities that actually
                  18      qualify the benefits recipients and the recipients themselves—not with Bank of
                  19      America. But we do know that there are a whole lot of them. California estimated
                  20      over $32 billion was stolen by fraudulent benefits claimants in what it called a
                  21      “criminal assault on the benefits system.” ECF 349 at 1. The Department of Labor
                  22      (DOL) estimated that more than a third of Pandemic Unemployment Assistance
                  23      benefits claims were fraudulent, amounting to losses as high as $400 billion. Id. at 6.
                  24      As to who, exactly, those criminals are, Bank of America informed the Court in its
                  25      original opposition to class treatment:
                  26         Applications and other eligibility information reside with EDD, and EDD still
                             hasn’t managed to sort it all out—as shown by the fact EDD is still
                  27         retroactively disqualifying many cardholders each month. Criminal
                             investigations continue, even with the pandemic and prepaid program behind
                  28         us. The federal government concedes it has no way to assess whether or not
                             the million or more people who defrauded EDD have or ever will be caught.
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   ATTORNEYS AT LAW
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                          MEMO. ISO DECERT. MOT.                               CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB           Document 733-1      Filed 06/08/26    PageID.61348
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                      1   Id. at 36 (citations omitted), see also Declaration of Laura G. Brys (Brys Decl.), Ex.
                      2   1 at 11, 17–18 (Jan. 17, 2025 Hr’g Tr.). Thus, “EDD continue[s] to identify fraudsters
                      3   in Plaintiffs’ proposed classes years after the fact as investigations progress.” Id. at
                      4   1.
                      5          The Court found that Plaintiffs had established predominance for class-
                      6   certification purposes because “[t]here is no evidence that many unearthed fraudulent
                      7   claims will arise.” ECF 494 at 57–58. And Plaintiffs had based their class-
                      8   certification motion on the notion that Bank of America had already identified every
                      9   case of eligibility fraud. But that wasn’t true. Bank of America never investigated
                  10      (and could not investigate) unemployment insurance (UI) benefits eligibility fraud.
                  11      And it could learn about new cases of eligibility fraud on any given day.
                  12             That day has come. As Bank of America recently informed the Court (see ECF
                  13      723, 723-1), 1 on May 8, 2026,
                                       F




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                  23             And like the claims fraud examples, this only scratches the surface of the full
                  24      extent of the eligibility fraud pervading the certified classes.
                  25

                  26

                  27
                          1
                           A newer Declaration of Jennifer Lennon addressing further developments since her
                  28      May 19, 2026 Declaration (ECF 723-1) is concurrently filed in support of this Motion
GOODWIN PROCTER LLP
                          (Lennon Decl.).
   ATTORNEYS AT LAW
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                          MEMO. ISO DECERT. MOT.                                 CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB            Document 733-1      Filed 06/08/26    PageID.61349
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                      7          This Court’s reaction to these sobering data points was appropriate:
                      8                               the Court remarked. Brys Decl., Ex. 2 at 5 (May 21, 2026
                      9   Hr’g Tr.). And the solution couldn’t be so simple as merely removing them from the
                  10      classes. For one thing, that would require Plaintiffs to proffer (and the Court to
                  11      certify) a completely new class definition. More fundamentally, resolving questions
                  12      over exactly whom to remove would itself be a daunting exercise. “The easy case,”
                  13      the Court questioned Plaintiffs, “is the situation where a fraudster is identified; both
                  14      sides agree that he is a fraudster, and he is gone.” Id. at 15. But the “ongoing process”
                  15      was likely to “identif[y] individuals who it is not that clean, and those are then the
                  16      ones that Bank of America will say, ‘We have the right to have the jury decide
                  17      whether or not they are in fact a fraudster,’” requiring “enough mini trials where the
                  18      predominance can no longer be found to exist with respect to these claims.” Id.
                  19             That was the appropriate question to pose. “[A] class cannot be certified on the
                  20      premise that [the defendant] will not be entitled to litigate its [] defenses to individual
                  21      claims.” Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 367 (2011). For the same
                  22      reason, the certification of the classes here cannot stand. Bank of America does have
                  23      the right to have a jury decide who among the                         of likely fraudsters
                  24      are indeed fraudsters.
                  25             And this issue is not a peripheral one—it is “central to the validity of each one
                  26      of the claims.” Id. at 350. It goes, first of all, to standing—which will be Plaintiffs’
                  27      burden to prove. Criminal fraudsters who had no legal right in the first place to the
                  28      funds in dispute cannot possibly claim an Article III injury from the temporary loss
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                          MEMO. ISO DECERT. MOT.                                  CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   of access to those funds at issue here. But Supreme Court and Ninth Circuit precedent
                      2   firmly establish that “[e]very class member must have Article III standing in order to
                      3   recover individual damages,” and so the Court may not “order relief to any uninjured
                      4   plaintiff, class action or not,” unless Plaintiffs carry their burden of making this
                      5   showing. TransUnion LLC v. Ramirez, 594 U.S. 413, 431 (2021) (internal quotations
                      6   omitted). Thus, if these criminals are part of a class, they must be “winnow[ed] out”
                      7   from it. Olean Wholesale Grocery Coop., Inc. v. Bumble Bee Foods LLC, 31 F.4th
                      8   651, 669 (9th Cir. 2022) (internal quotations omitted).
                      9          Separately, Plaintiffs cannot litigate their claims without carrying their burden
                  10      on the essential element of actual damages. At the recent hearing, Plaintiffs made
                  11      much of the fact that Bank of America’s pending summary-judgment motion does
                  12      not “seek summary judgment as to its liability under EFTA. It challenges damages.”
                  13      Brys Decl., Ex. 2 at 7. That is not the winning argument Plaintiffs think it is, as it
                  14      confirms the centrality of the damages disputes to this case, which make up           of
                  15      the relief Plaintiffs seek on behalf of the classes (excluding an alternative claim for a
                  16      $500,000 EFTA penalty),
                  17

                  18             That is not “a de minimis number.” ECF 494 at 59. The resulting mini-trials
                  19      would necessarily predominate. But they wouldn’t necessarily be mini-trials. An
                  20      adjudication of criminal fraud calls for a full-blown trial. And there is no way around
                  21      them. Plaintiffs have never proposed any way to do this. Their best idea—which they
                  22      concede is a “facile” one—is to postpone the winnowing-out exercise for after trial.
                  23      Brys Decl., Ex. 2 at 16. But recent Ninth Circuit precedent, issued after the Court
                  24      certified the classes (and after Bank of America moved for summary judgment),
                  25      forecloses that idea. “TransUnion . . . requires unnamed members of a certified class
                  26      for money damages to demonstrate standing at summary judgment,” not merely “at
                  27      the end of the life cycle of a class action” or “the time that individual money damages
                  28      are awarded.” Healy v. Milliman, Inc., 164 F.4th 701, 705–06 (9th Cir. 2026).
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                          MEMO. ISO DECERT. MOT.                                 CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB            Document 733-1     Filed 06/08/26       PageID.61351
                                                         Page 10 of 31


                      1          Based on the new facts, and this new binding precedent, Bank of America
                      2   respectfully submits that the winnowing-out process that would be required here
                      3   warrants decertification of the classes.
                      4                                      BACKGROUND
                      5          A.    The Department of Labor Benefits Fraud Investigation
                      6          On February 22, 2021, the Department of Labor’s Office of Inspector General
                      7   for Audit issued an Alert Memorandum informing the Department (and the public)
                      8   that it had identified “$5.4 billion of potentially fraudulent UI benefits paid to
                      9   individuals with social security numbers filed in multiple states, to individuals with
                  10      social security numbers of deceased persons and federal inmates, and to individuals
                  11      with social security numbers used to file for UI claims with suspicious email
                  12      accounts” from March 2020 through October 2020.2 It urged the Department “to take
                                                                               F




                  13      immediate action and increase its efforts to ensure [state workforce agencies]
                  14      implement effective controls to mitigate fraud” and cautioned that it had “only
                  15      capture[d] a subset of the potential fraudulent UI activities,” and “expects that the
                  16      actual amount of potential fraud is much larger.” Id. at 1–2. It cited reports estimating
                  17      that California had “paid at least 10 percent ($11 billion) of its UI benefits to
                  18      fraudulent claims since the pandemic began and believes the amount could be as high
                  19      as 27 percent ($29 billion).” Id. at 2.
                  20             Subsequent alerts continued ratcheting up the fraudulent payment estimates.
                  21      On September 21, 2022, the DOL-OIG issued an alert stating its estimate of payments
                  22      to potentially ineligible recipients now stood at $45.6 billion.3 And it again warned
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                  23
                          2
                             Brys Decl., Ex. 3 (Alert Memorandum: The Employment and Training
                  24      Administration (ETA) Needs to Ensure State Workforce Agencies (SWA) Implement
                          Effective Unemployment Insurance Program Fraud Controls for High Risk Areas,
                  25      Report No. 19-21-002-03-315, at 1, U.S. Dep’t of Labor, Office of Inspector General
                          (Feb. 22, 2021), available at https://www.oig.dol.gov/public/reports/oa/2021/19-21-
                  26      002-03-315.pdf).
                          3
                            Lennon Decl., Ex. B (Alert Memorandum: Potentially Fraudulent Unemployment
                  27      Insurance Payments in High-Risk Areas Increased to $45.6 Billion, Report No. 19-
                          22-005-03-315, at 1 U.S. Dep’t of Labor, Office of Inspector General (Sept. 21,
                  28      2022), available at https://www.oig.dol.gov/public/reports/oa/2022/19-22-005-03-
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                          315.pdf).
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                          MEMO. ISO DECERT. MOT.                                   CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   that this was only one small part of the full scope of the fraud. “Despite the OIG’s
                      2   continued efforts to identify potentially fraudulent payments to ineligible claimants,”
                      3   it stated, “we continue to experience delays in obtaining the needed UI data” from
                      4   the state workforce agencies, “imped[ing] our ability to perform our statutory duty to
                      5   effectively and timely conduct audits and investigations of the UI program.” Id. at 2.
                      6          A January 30, 2026 alert from the DOL-OIG warned that state workforce
                      7   agencies were continuing to fail at “fulfilling their programmatic responsibilities to
                      8   prevent and detect improper payments,” estimates of which had again risen
                      9   considerably: “According to Inspector General Congressional Testimony, of the
                  10      $888 billion in UI benefits, at least $191 billion could have been improper payments,
                  11      including more than $76 billion paid to fraudsters.” 4 The specific concern of the
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                  12      memorandum was a vast sum of unspent UI benefits still vulnerable to being
                  13      “targeted by capable adversaries” or “escheated (surrendered) to state unclaimed
                  14      property administrators, . . . further complicating potential overpayment recovery.”
                  15      Id.                 —labeled in the memorandum as “Financial Institution 1”—was
                  16      identified as one of four institutions still holding unspent funds in beneficiary
                  17      accounts. Id. ¶ 4 & Ex. A at 3. The memorandum stated that the four institutions had
                  18      been subpoenaed to produce records on “(1) all prepaid cards with remaining UI
                  19      balances and (2) prepaid card balances already escheated to state unclaimed property
                  20      administrators,” and that                      had complied with a records production
                  21      in “late September 2025.” Id., Ex. A at 3. That production encompassed “more than
                  22      5 million prepaid card accounts” and over a billion dollars in affected funds, over
                  23      $738 million of which had “not yet escheated.” Id. at 3–4. The DOL-OIG found that
                  24      the vast majority of that amount consisted of “potentially fraudulently obtained
                  25
                          4
                  26        Lennon Decl., Ex. A (Alert Memorandum: The Employment and Training
                          Administration Needs to Ensure State Workforce Agencies Take Action to Recover
                  27      Significant Unemployment Insurance Holdings Still Held by Financial Institution 1’s
                          Prepaid Card Program, at 1–2, U.S. Dep’t of Labor, Office of Inspector General
                  28      (Jan. 30, 2026), available at https://www.oig.dol.gov/public/reports/oa/2026/50-26-
GOODWIN PROCTER LLP
                          001-03-315.pdf).
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                          MEMO. ISO DECERT. MOT.                                 CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   funds,” totaling $714,626,297 across nearly 2.7 million prepaid card accounts, and
                      2   across twelve state UI programs. Id. at 3–5; see Lennon Decl. ¶¶ 6, 12.
                      3                                                                               The alert
                      4   memorandum and subpoenas weren’t concerned with clawing back fraudulent
                      5   benefits payments that were already spent (
                      6        ). They were concerned exclusively with funds still held in beneficiaries accounts
                      7   at risk of escheatment and recently escheated funds that could still be recoverable
                      8   from the respective state unclaimed-property agencies.
                      9

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                  22             Bank of America promptly notified the Court of this development with a May
                  23      19, 2026 Notice of New Evidence Concerning Class Members (ECF 723) supported
                  24      by a declaration from Bank of America executive Jennifer Lennon
                  25

                  26                 (ECF 723-1). The Court in response vacated a planned hearing on pending
                  27      summary-judgment and Daubert motions to convene a status conference to address
                  28      the effect of the Notice of New Evidence on the pending motions. ECF 725 at 1.
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                          MEMO. ISO DECERT. MOT.                                CASE NO. 3:21-MD-02992-GPC-MSB
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                      1   to prevent the permanent loss of funds by escheatment. That was not “triggered” by
                      2   former Secretary of Labor Chavez-DeRemer, either. The alerts came from the DOL-
                      3   OIG. Federal OIG offices are independent of the agencies they oversee with
                      4   independent leadership appointed “without regard to political affiliation and solely
                      5   on the basis of integrity and demonstrated ability in accounting, auditing, financial
                      6   analysis, law, management analysis, public administration, or investigations.” 5
                      7   U.S.C. § 403(a).
                      8

                      9

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                  15                            See Lennon Decl. ¶¶ 8, 14 & Exs. B & C.
                  16             Politics aside, the Court then questioned Plaintiffs’ counsel how they proposed
                  17      to handle the situation where “it is not that clean” who is a fraudster, where “Bank of
                  18      America will say, ‘We have the right to have the jury decide whether or not they are
                  19      in fact a fraudster,’” with the result of “having enough mini trials where the
                  20      predominance can no longer be found to exist with respect to these claims.” Brys
                  21      Decl., Ex. 2 at 15. Plaintiffs gave two responses. First, they said, “[t]he facile
                  22      response is you can easily bifurcate a case like this and have any individual
                  23      adjudications as to damages resolved later, once you determine the class-wide
                  24      liability.” Id. at 16. Second, they doubled down on the claim that “the bank has an
                  25      affirmative burden that it doesn’t satisfy merely by showing that there’s a potential
                  26      that certain class members are fraudsters.” Id.
                  27             But that is not where the burden lies.
                  28
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                      1                                 STANDARD OF LAW
                      2          Class-certification orders are “inherently tentative” procedural orders that
                      3   “may be altered or amended” at any time “before entry of a final judgment.” Officers
                      4   for Just. v. Civ. Serv. Comm’n of City & Cnty. of S.F., 688 F.2d 615, 633 (9th Cir.
                      5   1982); FED. R. CIV. P. 23(c)(1)(C). “The Court has a continuing duty to ensure
                      6   compliance with class action requirements pursuant to Rule 23, and therefore may
                      7   decertify a class at any time.” Ugas v. H&R Block Enters., LLC, 2012 WL 5230297,
                      8   at *2 (C.D. Cal. July 9, 2012). Motions to decertify are reviewed under “the same . . .
                      9   standard used in evaluating a motion to certify; namely, whether the requirements of
                  10      Rule 23 are met.” Cruz v. Dollar Tree Stores, Inc., 270 F.R.D. 499, 502 (N.D. Cal.
                  11      2010). “On a motion for decertification, the burden remains on the plaintiffs to
                  12      demonstrate ‘that the requirements of Rule 23(a) and (b) are met.’” Ries v. Ariz.
                  13      Beverages USA LLC, 2013 WL 1287416, at *3 (N.D. Cal. Mar. 28, 2013) (quoting
                  14      Marlo v. UPS, 639 F.3d 942, 947 (9th Cir. 2011)); see also, e.g., Halliburton Co. v.
                  15      Erica P. John Fund, Inc., 573 U.S. 258, 275 (2014) (plaintiff must “prove—not
                  16      simply plead—that their proposed class satisfies each requirement of Rule 23”).
                  17                                         ARGUMENT
                  18

                  19

                  20

                  21                                                     “[A] court must consider whether the
                  22      possible presence of uninjured class members means that the class definition is fatally
                  23      overbroad. When ‘a class is defined so broadly as to include a great number of
                  24      members who for some reason could not have been harmed by the defendant’s
                  25      allegedly unlawful conduct, the class is defined too broadly to permit certification.’”
                  26      Olean, 31 F.4th at 669 n.14 (quoting Messner v. Northshore Univ. HealthSystem, 669
                  27      F.3d 802, 824 (7th Cir. 2012)). That is because the exercise of “winnow[ing] out” the
                  28      uninjured cannot possibly occur without individual mini-trials where individual
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                      1   issues would predominate. Id. at 669. Plaintiffs’ inability to propose any alternative
                      2   requires decertification of their classes.
                      3   I.     Plaintiffs cannot carry their Rule 23 burden with a fraud-infested class.
                      4          As this Court has recognized, the “plaintiff bears the burden of proving that
                      5   the class meets all four requirements of Rule 23(a) . . . by a preponderance of the
                      6   evidence.” ECF 494 at 37 (citing Ellis v. Costco Wholesale Corp., 657 F.3d 970,
                      7   979–80 (9th Cir. 2011); Olean, 31 F.4th at 665). That does not, under current Ninth
                      8   Circuit law, require them to prove that their class is entirely free of criminal
                      9   fraudsters. But it does require Plaintiffs to prove that their class can be made entirely
                  10      free of criminal fraudsters before trial. See TransUnion, 594 U.S. at 431; Olean, 31
                  11      F.4th at 669; Healy, 164 F.4th at 705 (holding that “the logic of TransUnion . . .
                  12      requires unnamed members of a certified class for money damages to demonstrate
                  13      standing at summary judgment”). Plaintiffs have neither done so, nor proposed any
                  14      Rule 23-compliant method for doing so.
                  15             A.     The burden of proof remains with Plaintiffs.
                  16             Plaintiffs’ argument that “the bank has an affirmative burden that it doesn’t
                  17      satisfy merely by showing that there’s a potential that certain class members are
                  18      fraudsters,” (Brys Decl., Ex. 2 at 16), is wrong and misconceived on multiple levels.
                  19      The “affirmative burden” here rests with the Plaintiffs, not the bank. See Ries, 2013
                  20      WL 1287416, at *3. And the “potential that certain class members are fraudsters” is
                  21      exactly the kind of showing that would impose on Plaintiffs the burden of proving
                  22      that those class members can be identified and removed from the class with common
                  23      evidence and no prospect of individualized inquiries predominating. See, e.g., Van v.
                  24      LLR, Inc., 61 F.4th 1053, 1068–69 (9th Cir. 2023). As the Ninth Circuit explained in
                  25      Van, once the defendant “invoked an individualized issue . . . and provided evidence
                  26      that at least some class members lack meritorious claims because of this issue,” “the
                  27      spectre of class-member-by-class-member adjudication” required vacating class
                  28      certification. Id. at 1069.
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                      1          Plaintiffs appear to conflate the burden of proof applicable to Bank of
                      2   America’s affirmative defenses to the burdens of proof that fall on them when it
                      3   comes to standing, actual damages, and class certification. It is true that the Court has
                      4   held that Bank of America will carry the burden of proof on its EFTA defenses to
                      5   Plaintiffs’ liability claims if this case goes to trial. See ECF 494 at 46–47. But it is
                      6   not true that Bank of America will need to carry the burden of disproving actual
                      7   damages on Plaintiffs’ damages claims. Supreme Court precedent, Ninth Circuit law,
                      8   and EFTA itself are all clear: it is Plaintiffs’ burden to prove their standing and
                      9   “actual damages” to recover any monetary damages on behalf of the classes—
                  10      including the EFTA treble damages that make up over                of the relief they seek.
                  11      See, e.g., TransUnion, 594 U.S. at 431 (“plaintiff must demonstrate standing”)
                  12      (emphasis added); Stearns v. Ticketmaster Corp., 655 F.3d 1013, 1026 (9th Cir.
                  13      2011) (“plaintiff must show that the claimed actual damages were ‘as a result of the
                  14      violation’”) (emphasis added), abrogated on other grounds by Comcast Corp. v.
                  15      Behrend, 569 U.S. 27 (2013). And it is not true, as Plaintiffs contend, that “the bank
                  16      has an affirmative burden” at the certification (or decertification) stage—much less
                  17      that this “affirmative burden” extends to requiring Bank of America “to demonstrate
                  18      who is in fact a criminal” at the certification stage (or at any other point before trial)
                  19      in order to defeat Plaintiffs’ liability case. Brys Decl., Ex. 2 at 8, 16. That is true for
                  20      at least two reasons.
                  21             First is the principle that “a class cannot be certified on the premise that [the
                  22      defendant] will not be entitled to litigate its [] defenses to individual claims.” Wal-
                  23      Mart, 564 U.S. at 367. So, regardless which side has the burden of proof on one issue
                  24      or another, the burden of showing that issue will not present predominating individual
                  25      inquiries rests on Plaintiffs, not Bank of America. See, e.g., Brown v. DirecTV, LLC,
                  26      562 F. Supp. 3d 590, 612 (C.D. Cal. 2021) (“And on a class certification motion, the
                  27      Court does not necessarily have to assess the merits of the affirmative defenses to the
                  28      underlying claim. It assesses whether common questions predominate, whether a
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                      1   class action is superior, etc. If [Defendant] did raise the statute of limitations defense
                      2   at class certification, the question would not be whether the defense has merit, but
                      3   whether it involves a common question for class adjudication.”). (Bank of America,
                      4   as noted, will never have the burden to prove who is or is not a criminal to defeat
                      5   Plaintiffs’ damages claims. It is indisputably Plaintiffs’ burden to establish “actual
                      6   damages” under EFTA to recover any of the damages they seek. See Stearns, 655
                      7   F.3d at 1026.)
                      8          Second, the issue of which class members are criminal fraudsters does not
                      9   merely implicate Bank of America’s EFTA statutory defenses. As this Court
                  10      recognized when it ordered a stay of this case pending the Supreme Court’s ruling in
                  11      Lab’y Corp. of Am. Holdings v. Davis, No. 24-0304, “criminals who defrauded the
                  12      EDD with fraudulent benefits claims” have no Article III standing. ECF 448 at 5, 7.
                  13      Plaintiffs effectively conceded the same, when they told the Court at the recent status
                  14      hearing that “the existence or nonexistence of fraudsters is not a question of whether
                  15      there’s a violation of EFTA. It is really a question of, what is the class size? Who
                  16      does this affect? Who is in and who is out?” Brys Decl., Ex. 2 at 7. Consistent with
                  17      this, TransUnion and Olean establish the least of what Plaintiffs must accomplish:
                  18      “winnow out” the “non-injured subset of class members.” Olean, 31 F.4th at 669.
                  19      And if they cannot propose some method for doing so that satisfies Rule 23
                  20      predominance, the class must be decertified. See id. at 668 (“When individualized
                  21      questions relate to the injury status of class members, Rule 23(b)(3) requires that the
                  22      court determine whether individualized inquiries about such matters would
                  23      predominate over common questions.”).
                  24             Plaintiffs cannot shift this burden back to Bank of America by arguing that
                  25      Bank of America has not done enough at the current stage
                  26                                                                         As a threshold matter,
                  27      “because ‘[Article III] presume[s] that federal courts lack jurisdiction unless the
                  28      contrary appears affirmatively from the record,’ the party asserting federal
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                      1   jurisdiction when it is challenged has the burden of establishing it.” DaimlerChrysler
                      2   Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006) (quoting Renne v. Geary, 501 U.S. 312,
                      3   316 (1991). Bank of America has challenged the Article III standing of the criminals
                      4   in this class and the consequent existence of subject-matter jurisdiction over their
                      5   claims. That puts the burden on Plaintiffs to show who is injured, not on Bank of
                      6   America to show who is not. And they must do it now, not merely “at the end of the
                      7   life cycle” of the case. Healy, 164 F.4th at 705–06.
                      8          The constitutional issue aside, the same result follows by application of the
                      9   standard Rule 23 burdens. The case of Mabanta v. Prime Now LLC, 2022 WL
                  10      1601415 (N.D. Cal. Feb. 28, 2022), is apropos. Mabanta was a wage-and-hour case
                  11      alleging that Amazon workers were entitled to be paid for time spent scheduling their
                  12      shifts. Id. at *1. The plaintiff proffered the workers’ alleged entitlement to be “on the
                  13      clock” while scheduling shifts as the common question purportedly justifying class
                  14      treatment, but the defendants argued that the putative class necessarily included
                  15      workers who were “on the clock” when they scheduled their shifts (and were
                  16      therefore uninjured). Id. at *3-4. The plaintiff made precisely the same protest as
                  17      Plaintiffs here: “Plaintiff submits that ‘there is no reason or evidence to believe that
                  18      any class member only scheduled shifts while on the clock’” and that
                  19      “‘defendants . . . have not pointed to one example of a class member that only
                  20      scheduled shifts on the clock.’” Id. at *5 (brackets omitted). The Court rejected that
                  21      argument, ruling:
                  22
                             Plaintiff’s assertions neglect that it is his burden, on a motion for class
                  23         certification, to demonstrate compliance with Rule 23’s requirements. As
                             such, he, not defendants, must show ‘that the class members have suffered the
                  24         same injury.’ He has not done so here. Thus, contrary to plaintiff’s belief, it is
                             not defendants’ burden to disprove plaintiff’s theory that class members
                  25         commonly selected shifts off the clock.

                  26      Id. (quoting Wal-Mart, 564 U.S. at 349–50; citations omitted). It was immaterial that
                  27      the defendant could not show which class members had no claim. It was sufficient
                  28      for the defendant to establish that there were some. And the fact that there were some,
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                      1   coupled with the fact “it is impossible to know, without individual inquiries,” who
                      2   they were, defeated commonality and predominance. Id. (quoting Heredia v. Eddie
                      3   Bauer LLC, 2020 WL 127489, at *1 (N.D. Cal. Jan. 10, 2020)) (decertifying class on
                      4   the same ground).
                      5            Heredia is also instructive, especially given the decertification context. There,
                      6   the plaintiff had achieved certification of a class of Eddie Bauer retail employees
                      7   claiming a right to be “on the clock” during security inspections when they left the
                      8   stores. 2020 WL 127489, at *1. The court had been satisfied that the existence and
                      9   legality of an offending policy were common questions, and rejected Eddie Bauer’s
                  10      protests that the class included members who had been on the clock during security
                  11      checks, because Eddie Bauer “presented the Court with ‘no evidence of any of these
                  12      “on-the-clock” employees.’” Id. at *2. But then the record “significantly developed.”
                  13      Id. Eddie Bauer had an expert capture video footage of 620 employee exits, 137 of
                  14      which “captured all aspects of the exit inspection,” including the security check and
                  15      the employee’s clocking out. Id. “Of those 137 fully-observed exits, 80.3% were on
                  16      the clock.” Id. The Court then decertified the class because “the class includes
                  17      employees who did not suffer any harm or injury,” and it was “impossible to know,
                  18      without individual inquiries, which employees” were unharmed, even though it knew
                  19      there were plenty. Id. at *5–6. Further, the record furnished no way to do those
                  20      inquiries short of “ask[ing] each employee individually” about their experiences. Id.
                  21      at *5. The Court concluded that “the jury would necessarily have to decide whether
                  22      each employee experienced uncompensated exit inspections. Class actions are not
                  23      appropriate where the resolution of the case would require numerous mini trials.” Id.
                  24      at *6.
                  25               The instant case is directly analogous, except that the record here is even more
                  26      decisively in Bank of America’s favor. Plaintiffs do not deny “that there’s a potential
                  27      that certain class members are fraudsters.” Brys Decl., Ex. 2 at 16. Nor could they:
                  28
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                      1   various [class members] are resolved,” even though “the applicability . . . to the core
                      2   dispute has not been determined”) (internal quotations omitted).
                      3          B.    The need for                         of individual mini- (or full trials)
                      4                requires decertification.
                      5          Bank of America has provided evidence that constitutional standing defenses
                      6   and statutory actual damages defenses bar recovery for
                      7                                                                  See Lennon Decl. ¶ 9 &
                      8   Ex. D. Perhaps this evidence
                      9

                  10      will not conclusively resolve those claims, but it is, at the least, evidence—evidence
                  11      that could only be parried (or corroborated) with more individual evidence, like
                  12      written discovery, deposition, and cross-examination testimony. Perhaps those
                  13      individual inquiries would show that the actual proportion of criminal fraudsters is
                  14      less (or perhaps more). But it is already more than just “some,” and it is more than
                  15      “mere speculation.” Van, 61 F.4th at 1068.
                  16

                  17                                                     And Plaintiffs have proposed no way to
                  18      litigate those cases with common evidence.
                  19             That is dispositive. In Van, the Ninth Circuit deemed the defendant’s evidence
                  20      of “13,680 discounts [] provided to class members” sufficient to show that “some
                  21      class members [were] uninjured.” Id. at 1069. Even though the evidence “consisted
                  22      of only a small number of invoices, [it] was sufficient to prove that an inquiry into
                  23      the circumstances and motivations behind each of the 13,680 discounts might be
                  24      necessary,” and that inquiry “could potentially involve up to 13,680 depositions and
                  25      months of trial.” Id. That was enough to warrant vacating the class certification order
                  26      in Van. The evidence is far greater and stronger here                                 ,
                  27      and would require              depositions and months of trial here.
                  28             Similarly, in Bowerman v. Field Asset Servs., Inc., 60 F.4th 459 (9th Cir.
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                      1   2023), the Ninth Circuit decertified a class on finding “the damages phase of this
                      2   class action [] far messier than promised by plaintiffs’ counsel when the case was
                      3   certified,” because “proof by the testimony of individual [class members] is
                      4   necessary.” Id. at 469 (alterations omitted); see also, e.g., Heredia, 2020 WL 127489,
                      5   at *5 (decertifying the class because identifying class members “who did not suffer
                      6   any harm” required testimony from “each [class member] individually”). That is
                      7   exactly the problem here. Plaintiffs cannot deny they will bear the burden to prove
                      8   Article III standing and “actual damages” in order to recover the EFTA treble
                      9   damages and other money damages that make up              of the relief they seek. 8 But
                                                                                                            F




                  10      Plaintiffs have offered no way to prove their standing and actual damages classwide
                  11      without resorting to bifurcation and mini-trials that would descend into full-blown
                  12      trials and require discovery and testimony from                     of individual class
                  13      members.
                  14             The necessary discovery and testimony by itself defeats predominance.
                  15      Confronted with a scenario where statistical evidence indicated that “approximately
                  16      ten percent of class members had not been injured,” the First Circuit rejected the
                  17      feasibility of relying on “testimony” from class members to satisfy predominance:
                  18          The aim of the predominance inquiry is to test whether any dissimilarity
                              among the claims of class members can be dealt with in a manner that is not
                  19          “inefficient or unfair.” Inefficiency can be pictured as a line of thousands of
                              class members waiting their turn to offer testimony and evidence on individual
                  20          issues. Unfairness is equally well pictured as an attempt to eliminate
                              inefficiency by presuming to do away with the rights a party would
                  21          customarily have to raise plausible individual challenges on those issues.
                  22      In re Asacol Antitrust Litig., 907 F.3d 42, 46–47, 51–52 (1st Cir. 2018) (citation
                  23      omitted). The evidence here, of course, is more than just statistical.
                  24                                                                                            But
                  25      Plaintiffs have given the Court that same choice between inefficiency and unfairness.
                  26      The first offends Rule 23. The second offends due process.
                  27
                          8
                           Without proof of actual damages, the most Plaintiffs can recover on behalf of their
                  28      EFTA classes, if they prove their liability case, is the capped statutory penalty of
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                      1          This Court expressed the concern that “we are still left with generalities and
                      2   the lack of something more individualized”                               . Brys Decl., Ex.
                      3   2 at 32.                         is already far more individualized and less generalized
                      4   than the evidence courts have found sufficient to destroy the cohesion of a class in
                      5   the above cases. See also, e.g., Brown v. Google, LLC, 2022 WL 17961497, at *19
                      6   n.2 (N.D. Cal. Dec. 12, 2022) (finding that “Google’s evidence . . . establishes that
                      7   individual and subjective interactions require individualized inquiries” even though
                      8   its “data is not connected to any particular class member, but general data that shows
                      9   that class members have differing experiences”).
                  10

                  11                                       Lennon Decl. ¶ 13 & Ex. D.
                  12             Thus, this Court was correct to apprehend why the inefficient course of
                  13                 of individual mini- or full-blown trials is unavoidable. There will be no
                  14      “easy case” where “a fraudster is identified; both sides agree that he is a fraudster,
                  15      and he is gone.” Brys Decl., Ex. 2 at 15.
                  16                                                                             , and they do not
                  17      concede that any of them are “gone.” Rather, they have proposed the mini-trial route.
                  18      See id. at 16. And they have maintained that if these mini-trials “can prove actual
                  19      fraud, then the person is out” of the class, because their “class definition expressly
                  20      excludes class members who commit fraud.” Id. at 8, 18. They consider that class
                  21      definition “a mechanism in place” for ensuring that “fraudsters . . . are out of the
                  22      class.” Id. at 8. But it is not a “mechanism” that satisfies Rule 23 predominance.
                  23             There is, in fact, a name for such a “mechanism.” It is called a fail-safe class,
                  24      and it is unlawful in this Circuit (and most others). “A court may not . . . create a ‘fail
                  25      safe’ class that is defined to include only those individuals who were injured by the
                  26      allegedly unlawful conduct. ‘Such a class definition is improper because a class
                  27      member either wins or, by virtue of losing, is defined out of the class and is therefore
                  28      not bound by the judgment.’” Olean, 31 F.4th at 669 n.14 (quoting Messner, 669 F.3d
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                      1   at 825) (citation omitted).
                      2          The other problem is that the class definition is not actually a “mechanism” for
                      3   removing anyone from the class. Class definitions are not self-executing. Defining
                      4   uninjured cardholders out of the class does not actually accomplish it; it simply begs
                      5   the question of how to identify the uninjured cardholders to remove from the class.
                      6   And Plaintiffs still carry the burden of doing so without “individualized inquiries
                      7   about such matters.” Olean, 31 F.4th at 668. But as Plaintiffs admitted via their self-
                      8   confessed “facile” proposal to “bifurcate [the] case . . . and have any individual
                      9   adjudications as to damages resolved later,” they have no mechanism for carrying
                  10      their burden. Brys Decl., Ex. 2 at 16.
                  11      II.    This Court did not, and cannot, certify a “bifurcated” class.
                  12             Plaintiffs’ proposal to “bifurcate [the] case” implicitly invokes Rule 23(c)(4).
                  13      They had previously made the suggestion in a footnote in their class-certification
                  14      motion with no elaboration. See ECF 324-1 at 4 n.2. The Court did not accept the
                  15      invitation then, and should not now.
                  16             Rule 23(c)(4) provides that “[w]hen appropriate, an action may be brought or
                  17      maintained as a class action with respect to particular issues.” That merely prompts
                  18      the question of when it is “appropriate.” See, e.g., Saavedra v. Eli Lilly & Co., 2014
                  19      WL 7338930, at *10 (C.D. Cal. Dec. 18, 2014) (noting that while “[t]he Ninth Circuit
                  20      has approved the use of issue classes,” “neither the Ninth Circuit nor the Supreme
                  21      Court has established when certification of an issue class is appropriate”). The Ninth
                  22      Circuit has established that “Rule 23(c)(4) certification is not a consolation prize” to
                  23      be given regardless whether it “advance[s] the litigation as a whole.” Pennington v.
                  24      Tetra Tech, Inc., 2024 WL 5213095, at *6 (N.D. Cal. Dec. 23, 2024). Nor is it a
                  25      magic bullet for eliminating predominance problems on the premise that every
                  26      individual issue can be dealt with separately. See Valentino v. Carter-Wallace, Inc.,
                  27      97 F.3d 1227, 1229–30 (9th Cir. 1996) (vacating class-certification grant bifurcating
                  28      liability issues from individual damages determinations because “the court did not
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                      1   discuss whether the adjudication of the certified issues would significantly advance
                      2   the resolution of the underlying case, thereby achieving judicial economy and
                      3   efficiency”).
                      4          Thus, “a district court is not bound to certify a liability class merely because it
                      5   is permissible to do so under Rule 23(b)(3). The language of Rule 23(c)(4) speaks of
                      6   certifying as to particular issues ‘when appropriate,’ meaning that courts should use
                      7   Rule 23(c)(4) only where resolution of the particular common issues would
                      8   materially advance the disposition of the litigation as a whole.” Rahman v. Mott’s
                      9   LLP, 2014 WL 6815779, at *9 (N.D. Cal. Dec. 3, 2014) (internal quotations and
                  10      alterations omitted). A class trial on Plaintiffs’ liability theories would not
                  11      “materially advance the disposition of the litigation as a whole.” The overwhelming
                  12      majority of what Plaintiffs hope to recover here presupposes proof of standing and
                  13      actual damages, and for the “disposition” of these issues to “advance,”
                  14                 of mini- or full-blown trials to determine class membership, injury, and
                  15      Article III standing must still follow. Rahman, 2014 WL 6815779, at *9; see also,
                  16      e.g., Bowerman, 60 F.4th at 470 (Ninth Circuit decertifying class because “proof by
                  17      the testimony of individual [class members] is necessary” for damages); Heredia,
                  18      2020 WL 127489, at *5–6 (decertifying class because identifying class members
                  19      “who did not suffer any harm” required testimony from “each [class member]
                  20      individually”). And it would violate Healy’s rule that “the standing inquiry for
                  21      unnamed class members” cannot “wait until the final stage of a damages action.” 164
                  22      F.4th at 708.
                  23             And, lastly, Rule 23(c)(4) certification is not warranted just because a plaintiff
                  24      asks for it. The burden is on Plaintiffs “to show that Rule 23(c)(4) certification was
                  25      ‘appropriate.’” Reitman v. Champion Petfoods USA, Inc., 830 F. App’x 880, 882 (9th
                  26      Cir. 2020). The “vague” suggestion that the “Court should reserve the question of
                  27      how damages should be adjudicated until the liability phase is complete” does not
                  28      carry that burden when doing so “would simply postpone [tens of thousands of] jury
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                                      21
                          MEMO. ISO DECERT. MOT.                                 CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB            Document 733-1       Filed 06/08/26   PageID.61368
                                                         Page 27 of 31


                      1   trials on damages, not eliminate the need for them.” D.C. ex rel. Garter v. Cnty. of
                      2   San Diego, 2018 WL 692252, at *3-4 (S.D. Cal. Feb. 1, 2018) (denying certification
                      3   because “Plaintiff has not devised a plan to resolve this case after the liability phase”),
                      4   aff’d, 783 F. App'x 766 (9th Cir. 2019). The same is true of the                        of
                      5   trials needed here.
                      6   III.   This case cannot play out with common inquiries predominating.
                      7          “Under the predominance inquiry, a district court must formulate some
                      8   prediction as to how specific issues will play out in order to determine whether
                      9   common or individual issues predominate in a given case.” Herskowitz v. Apple, Inc.,
                  10      301 F.R.D. 460, 469 (N.D. Cal. 2014) (internal quotation marks omitted). This is how
                  11      standing issues will play out here.
                  12             Plaintiffs will argue, as they have, that the fact that
                  13                                                       to all of the class members” is evidence
                  14      that they all had an injury warranting compensation. Brys Decl., Ex. 2 at 16. And
                  15      Bank of America will argue otherwise, as it has also done. Plaintiffs concede that
                  16      “[t]here is a question as to the legal significance”                                  . Id.
                  17      As Bank of America has shown,
                  18

                  19                                   . See ECF 349 at 3–5, 13–14.
                  20                                                                                         . Bank
                  21      of America “never attempted to sort out eligible benefits recipients from every person
                  22      who defrauded EDD” because all the “eligibility information reside[s] with EDD”
                  23      and the beneficiaries themselves, not the bank, “and EDD still hasn’t managed to sort
                  24      it all out—as shown by the fact EDD is still retroactively disqualifying many
                  25      cardholders each month.” Id. at 35–36.
                  26

                  27

                  28
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                                      22
                          MEMO. ISO DECERT. MOT.                                  CASE NO. 3:21-MD-02992-GPC-MSB
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                      1

                      2

                      3          Plaintiffs will protest that it is too late, and this evidence should have been
                      4   presented earlier. Bank of America will point out that the evidence did not exist until
                      5   last month—
                      6        —and it doesn’t matter anyway, because the Court “may decertify a class at any
                      7   time.” Ugas, 2012 WL 5230297, at *2. It is not Bank of America’s fault that
                      8

                      9   and no justification to prejudice Bank of America just because material evidence
                  10      arose later than might have been maximally convenient. More might still arise.
                  11                                                                        , and on May 28, 2026,
                  12      subsequent to the status conference, the DOL-OIG issued another fraud alert
                  13      “assess[ing] that an opportunity exists . . . to[] ensure SWAs finalize and remit their
                  14      fraud findings for all [BANA] UI prepaid card accounts” to the DOL. Lennon Decl.
                  15      ¶¶ 4, 13; Brys Decl., Ex. 5.
                  16             Regardless, at this point, there is either no competent evidence of the suspected
                  17      fraudsters’ Article III standing (destroying the cohesion of the class, and warranting
                  18      decertification on that basis alone), or there is disputed evidence of the suspected
                  19      fraudsters’ standing, with only a jury capable of deciding whom to believe—
                  20      Plaintiffs, or Bank of America (and the DOL-OIG).
                  21             From there, perhaps the Court accepts Plaintiffs’ proposal “to reopen
                  22      discovery,” so they “can respond factually” to the DOL-OIG’s conclusions. Brys
                  23      Decl. Ex. 2 at 6. If so, Bank of America would have the same opportunity in reopened
                  24      discovery to adduce evidence supporting the DOL-OIG’s conclusions as Plaintiffs
                  25      would to seek evidence rebutting them. Disputes will inevitably follow about what
                  26      written discovery and how many absent class member depositions Bank of America
                  27      should be allowed to take.
                  28             Regardless, Bank of America will remain “entitled to litigate its [] defenses to
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                                     23
                          MEMO. ISO DECERT. MOT.                                CASE NO. 3:21-MD-02992-GPC-MSB
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                                                          Page 29 of 31


                      1   individual claims”—if not through depositions, written discovery, and subpoenas,
                      2   then at least at trial. Wal-Mart, 564 U.S. at 367. And if the testimony of individual
                      3   class members will help resolve the factual dispute
                      4

                      5             , then Bank of America will be entitled to take that testimony,
                      6                 . See Bowerman, 60 F.4th at 470; Asacol, 907 F.3d at 51–52; Heredia,
                      7   2020 WL 127489, at *5–6. And the jury will be entitled to evaluate the plausibility
                      8   of each suspected fraudster’s story one-by-one. Whether this occurs in the course of
                      9   a class trial, or after one, is immaterial. It will still have to occur, and the class portion
                  10      would not “materially advance the disposition of the litigation as a whole” with all
                  11      the individual hearings on standing still to come. Rahman, 2014 WL 6815779, at *9.
                  12                                           CONCLUSION
                  13             The Court certified Plaintiffs’ claims for class treatment on the premise, argued
                  14      by Plaintiffs, that Bank of America “has cited only a de minimis number of uninjured
                  15      class members which does not defeat predominance.” ECF 494 at 55. Bank of
                  16      America disagrees, but even if that were so, the “de minimis” examples Bank of
                  17      America cited last year were just that—examples, not exhaustive: the mere tip of the
                  18      proverbial iceberg. Now, much more of the iceberg is in sight.
                  19                                                                                 , and the
                  20                  more who will likely follow upon further investigation, are not a “de
                  21      minimis” number, and the exercise of adjudicating which are criminal fraudsters
                  22      cannot occur without individual inquiries predominating. Bank of America thus
                  23      respectfully submits that the Court should de-certify the Plaintiff classes.
                  24

                  25      Dated: June 8, 2026                  Respectfully submitted,
                  26                                           By: /s/ Sabrina M. Rose-Smith_________
                  27                                                 SABRINA M. ROSE-SMITH (pro hac vice)
                                                                     SRoseSmith@goodwinlaw.com
                  28                                                 MATTHEW L. RIFFEE (pro hac vice)
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                                        24
                          MEMO. ISO DECERT. MOT.                                    CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB       Document 733-1   Filed 06/08/26   PageID.61371
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                      1                                     MRiffee@goodwinlaw.com
                                                            KEITH LEVENBERG (pro hac vice)
                      2                                     KLevenberg@goodwinlaw.com
                                                            GOODWIN PROCTER LLP
                      3                                     1900 N St. NW
                                                            Washington, DC 20036
                      4                                     Tel: +1 202 346 4000
                                                            Fax: +1 202 346 4444
                      5
                                                            JAMES W. MCGARRY (pro hac vice)
                      6                                     JMcGarry@goodwinlaw.com
                                                            GOODWIN PROCTER LLP
                      7                                     100 Northern Avenue
                                                            Boston, MA 02210
                      8                                     Tel.: +1 617 570 1000
                                                            Fax: +1 617 523 1231
                      9
                                                            LAURA G. BRYS (SBN 242100)
                  10                                        LBrys@goodwinlaw.com
                                                            GOODWIN PROCTER LLP
                  11                                        601 S Figueroa St., Suite 4100
                                                            Los Angeles, CA 90017
                  12                                        Tel.: +1 213 426 2500
                                                            Fax: +1 617 346 4444
                  13
                                                            YVONNE W. CHAN (pro hac vice)
                  14                                        YChan@jonesday.com
                                                            JONES DAY
                  15                                        100 High Street
                                                            Boston, MA 02110
                  16                                        Tel.: +1 617 960 3939
                                                            Fax: +1 617 449 6999
                  17
                                                            JANICE P. BROWN (SBN 114433)
                  18                                        jbrown@myersnave.com
                                                            MATTHEW B. NAZARETH (SBN
                  19                                        278405)
                                                            mnazareth@myersnave.com
                  20                                        MEYERS NAVE
                                                            600 B Street, Suite 1650
                  21                                        San Diego, CA 92101
                  22                                        Attorneys for Defendant
                                                            BANK OF AMERICA, N.A.
                  23

                  24

                  25

                  26

                  27

                  28
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                              25
                          MEMO. ISO DECERT. MOT.                         CASE NO. 3:21-MD-02992-GPC-MSB
                  Case 3:21-md-02992-GPC-MSB           Document 733-1     Filed 06/08/26   PageID.61372
                                                        Page 31 of 31


                      1                             CERTIFICATE OF SERVICE
                      2          I hereby certify that I electronically filed the foregoing with the clerk of the
                      3   court for the United States District Court for the Southern District of California by
                      4   using the CM/ECF system on June 8, 2026. I further certify that all participants in
                      5   the case are registered CM/ECF users and that service will be accomplished by the
                      6   CM/ECF system. I certify under penalty of perjury that the foregoing is true and
                      7   correct.
                      8

                      9

                  10       Executed:    June 8, 2026                          s/ Sabrina M. Rose-Smith
                  11                                                            SABRINA M. ROSE-SMITH
                  12

                  13

                  14

                  15

                  16

                  17

                  18

                  19

                  20

                  21

                  22

                  23

                  24

                  25

                  26

                  27

                  28
GOODWIN PROCTER LLP
   ATTORNEYS AT LAW
                                                                    26
                          MEMO. ISO DECERT. MOT.                                CASE NO. 3:21-MD-02992-GPC-MSB


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