Aryeh v. Canon Business Solutions: Supreme Court to Resolve Statute of Limitations Questions in Unfair Competition Class Action

In Aryeh v. Canon Business Solutions (2010) 185 Cal.App.4th 1159, the Court of Appeal affirmed a judgment of dismissal in a consumer class action under the Unfair Competition Law, holding that the action was barred by the statute of limitations. The Court of Appeal's opinion is here. The Supreme Court granted the plaintiff's petition for review in October, 2010. The issues stated are as follows:

1. May the continuing violation doctrine, under which a defendant may be held liable for actions that take place outside the limitations period if those actions are sufficiently linked to unlawful conduct within the limitations period, be asserted in an action under the Unfair Competition Law (Bus. & Prof. Code section 17200 et seq.)? 
2. May the continuous accrual doctrine, under which each violation of a periodic obligation or duty is deemed to give rise to a separate cause of action that accrues at the time of the individual wrong, be asserted in such an action? 
3. May the delayed discovery rule, under which a cause of action does not accrue until a reasonable person in the plaintiff's position has actual or constructive knowledge of facts giving rise to a claim, be asserted in such an action? 

The Supreme Court's web page for Aryeh (Case No. S184929) is here. It has been fully briefed since last November, but oral argument has not been scheduled.  

I have added Aryeh to our Watch List of pending cases because it could have implications for employment actions.