Robinson v. U-Haul Co. Cal. (Oct. 18, 2016, A141396, A145828).
 Section 17204 of the California Business and Professions Code requires class representatives prosecuting class actions under the UCL satisfy the class action certification criteria prescribed in section 382 of California’s Code of Civil Procedure.
 Cal. Bus. & Prof. Code § 16600 (1941) (emphases added).
 Cal. Bus. & Prof. Code § 16601 (recognizing the right of “[a]ny person who sells the goodwill of a business, or any owner of a business entity selling or otherwise disposing of all [or substantially] of his or her ownership interest [or all or substantially all of the business’ operating assets]…[to] agree to refrain from carrying on a similar business within a specified geographic area…so long as the buyer carries on a like business therein.”
 See, e.g., Metro Traffic Control, Inc. v. Shadow Traffic Network (1994) 22 Cal.App. 4th 853, 863; Muggill v. Reuben H. Donnelley Corp. (1965) 62 Cal.2d 239, 242.
 See, Farmers Ins. Exch. v. Superior Ct. (1992) 2 Cal. 4th 377, 383 (affirming that unlawful business practices in violation of other law could constitute a separately actionable claim under section 17200 of the Business and Professions Code).
 Cal. Bus. & Prof. Code § 17205 (emphasis added).
 Robinson, at 3.
 Id. at 14.
 Section 17204 of the California Business and Professions Code authorizes private plaintiffs to prosecute violations of the UCL. If successful, plaintiffs may motion to recoup the costs of litigation, including attorney’s fees, pursuant to section 1021.5 of the California Code of Civil Procedure.
 Id. at 3–4. Not only did the court charge U-Haul with actual notice of the noncompetition agreement’s illegality following the trial court’s refusal to compel specific performance of its terms, but also that case law reinforced the well-established statutory prohibition against “garden variety noncompetition covenants” (the origins of which date back to 1872 in former section 1673 of the state Civil Code) and imparted constructive notice of the agreements’ illegality. Id. at 11–12.
 Id. at 12.
CIRCULAR 230 DISCLOSURE – Pursuant to rules and regulations imposed by the Internal Revenue Service, any tax advice contained in this communication, including any attachments, is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding tax penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another person any transaction or matter addressed herein.
The summary which appears above is reprinted for information purposes only. It is not intended to be and should not be considered legal advice nor substitute for obtaining legal advice from competent, independent, legal counsel. If you would like to discuss these matters in more detail, please feel free to contact us so that we can provide the clarification and resources you need to make effective decisions.