The California Court of Appeal recently confirmed, in case there was any doubt, that plaintiffs must allege (and ultimately prove) actual reliance to adequately state a fraudulent prong Unfair Competition Law claim (Cal. Bus. & Prof. Code 17200). In Goonewardene v. ADP, LLC, the plaintiff brought a variety of claims related to her alleged wrongful termination, both against her former employer, and the employer’s payroll services provider. The Court of Appeal determined, among other things, that plaintiff lacked standing to bring the fraudulent prong UCL claim against the payroll services provider.