Mealey's (October 25, 2021, 1:26 PM EDT) -- SAN FRANCISCO — A class settlement by a massage and skin care franchisor accused of violating its membership agreement by periodically increasing membership fees was a coupon settlement under the Class Action Fairness Act (CAFA), a Ninth Circuit U.S. Court of Appeals panel ruled Oct. 20, first vacating approval of the attorney fee award and remanding for reconsideration based on the value of the redeemed vouchers and then vacating approval of the settlement for failure to adequately investigate the warning signs of implicit collusion, a process necessary for pre-certification settlements pursuant to In re Bluetooth Headset Products Liability Litigation....