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On March 30, 2021, the United States Supreme Court heard oral argument in  Transunion LLC v. Ramirez, No. 20-297, a case that could have far-reaching implications on absent class member standing, particularly where the injuries of these absent class members would be impossible or difficult to establish.  The Court agreed to address whether Article III or Rule 23 permits a damages class action where the vast majority of the class suffered no actual injury, let alone an injury like what the class representative suffered. The Court’s analysis will no doubt build on the precedent established in Spokeo v. Robins, which held that allegations of mere procedural violations were insufficient on their own to satisfy the Article III standing requirement and, instead, plaintiffs had to allege concrete injuries they suffered from those procedural violations.  As the Court noted in

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