Antitrust Law Daily Wrap Up, ADVERTISING—N.D. Cal.: Consumer class action against Beats, Apple survives dismissal on headphone compatibility with Android, (Aug 3, 2026)

By Justin Marcus Smith, J.D.

Even assuming the consumer would have looked beyond certain representations, the court still found it facially plausible that the product page would have deceived reasonable consumers.

A consumer could proceed to discovery with California false advertising and closely-related claims against Beats Electronics, LLC (Beats) and Apple, Inc. (Apple), held the federal district court in San Francisco. The court held a reasonable consumer could have plausibly read representations on an Amazon product page and been deceived into thinking Android users would be able to use the Beats headphone “Personalized Spatial Audio” feature. Because the consumer plausibly alleged an affirmative misrepresentation, and portions of a claim could not be dismissed under R. 12(b)(6), the court did not have to reach whether the consumer also pleaded actionable omission. The consumer acknowledged she failed to plead standing to proceed with her request for injunctive relief, and only to that extent, the court dismissed in part with express leave to amend by a deadline date (Saucedo v. Beats Electronics, LLC, No. 3:26-cv-01363-RFL (N.D. Cal. Jul. 31, 2026)).

A consumer alleged that Beats Electronics, LLC (Beats) and Apple, Inc. (Apple) falsely and misleadingly advertised Beats headphones as being seamlessly compatible with Android devices, despite inaccessibility of the Beats headphone Personalized Spatial Audio feature. The consumer claimed (1) violation of the California Consumers Legal Remedies Act (CLRA), Cal. Civ. Code § 1750 et seq.; (2) violation of the California False Advertising Law (FAL), Cal. Bus. & Prof. Code § 17500 et seq.; (3); fraud, deceit, or misrepresentation; (4) violation of the California Unfair Competition Law (UCL), Cal. Bus. & Prof. Code § 17200 et seq.; and (5) unjust enrichment. The parties agreed that all of the consumer’s claims required a facial showing of likely deception of reasonable consumers.

The consumer alleged she bought Beats Solo 4 Headphones on Amazon. A footnote to the “seamless compatibility” statement allegedly did not distinguish between features except to say that headphone users would need an iCloud account and a compatible Apple device running the latest operating system software “or compatible Android device running the latest operating system software with Google Play Services enabled.” The Amazon product page also described “Personalized Spatial Audio” with dynamic head tracking as a feature of the headphones. The court deemed the Amazon product page incorporated by reference to the extent it formed the basis of the consumer’s claims. As a result, the court said it could properly consider the defendants’ exhibits. Beats and Apple moved to dismiss, but the court only granted dismissal in part, in connection with injunctive relief. The complaint otherwise survived dismissal.

The court analyzed that a reasonable consumer would have assumed, as the complaint alleged, that all material Beats headphone features would work on devices using either the Apple and Android operating systems. Even assuming the consumer would have looked beyond the representations to the rest of the Amazon product page and a separate graphic displayed there, the court still found it plausible that the product page would have deceived a reasonable consumer. It was plausible that users would not have understood a discrete graphic as an exclusive list of cross-platform features. Frequently asked questions (FAQ) addressed the Personalized Spatial Audio feature, but did not disclose it was unavailable on Android devices, despite only specifically addressing iOS devices. The same was true of a disclaimer that, in any event, was almost entirely illegible.

The consumer adequately alleged both intent to induce reliance and actual reliance to proceed with a fraud claim. The consumer pleaded reliance with the required R. 9(b) particularity to the extent she alleged the date she visited Amazon, read the compatibility representations there, and bought the headphones based on what she saw.

The unjust enrichment claim survived coextensive with survival of the other claims, and the consumer also sufficiently alleged insufficiency of legal remedies insofar as she distinguished that her equitable claims did not require proof of classwide reliance, materiality beyond the objective reasonable consumer standard, intent, recklessness, or negligence.

The consumer conceded that her complaint did not plausibly allege standing to seek injunctive relief, but amendment did not necessarily appear futile, so the court dismissed the request for injunctive relief with leave to amend.

The Case is No. 3:26-cv-01363-RFL.

Judge: Lin, R.

Attorneys: Hayley A. Reynolds (Gutride Safier LLP) for Carolina Saucedo. Christopher Chorba (Gibson, Dunn & Crutcher LLP) for Beats Electronics, LLC.

Companies: Beats Electronics, LLC

Cases: Advertising StateUnfairTradePractices CaliforniaNews