In Conroy v. Fresh Del Monte Produce Inc. et al., California First District Court of Appeal upheld the denial of class certification in a case filed by direct and indirect purchasers, accusing Fresh Del Monte Produce Inc. of securing a patent for a variety of pineapple that it knew to be unpatentable and subsequently using patent litigation to gain a stranglehold and raise prices in the market for extra-sweet pineapple violating California’s Unfair Competition Law. In upholding the lower court’s decision, the appeals court ruled that the indirect purchaser plaintiffs had failed to show that the trial court abused its discretion in denying class certification. The lower court had adequately determined that (1) individual questions would need to be resolved to establish injury to proposed class members who purchased pineapples from different direct purchasers in different competitive markets, and (2) class members could not be notified in a cost-effective manner.