Proposition 64, an initiative measure adopted by the voters at the November 2004 election, worked a sea change in litigation to enforce the unfair competition law (UCL; Bus. & Prof. Code, § 17200 et seq.).1 Previously, a UCL action against one alleged to have committed an illegal, unfair, or deceptive business practice could be maintained by any one of several specified public officials, or by “any person acting for the interests of itself, its members or the general public.” (Former § 17204, as amended by Stats. 1993, ch. 926, § 2, p. 5198.) In a suit by either a public or private plaintiff, the court could order injunctive relief as well as the restoration “to any person in interest [of] any money or property, real or personal, which [might] have been acquired by means of such unfair competition.” (§ 17203.) As a result, a private individual or entity with no relationship to the alleged wrongful practice could use the statute to force a business to repay substantial sums arguably acquired through a UCL violation.
Advised that the broad power accorded to “private attorneys general” under the UCL had led to abusive “shakedown” suits, the voters, through Proposition 64, adopted crucial reforms. Proposition 64 left intact the authority of the enumerated public officials to maintain UCL actions on the public’s behalf, and therein to obtain injunctive relief and restitution of profits generally associated with the alleged unfair practice. However, the measure severely restricted the UCL enforcement powers of private persons in two ways.
First, it provided that any private person bringing a UCL suit must have suffered “injury in fact and . . . lost money or property as a result of the unfair competition.” (§ 17204, italics added.) Second, it specified that a private person may pursue representative claims on behalf of others only if he *330or she (1) personally has suffered actual injury and loss caused by the unfair practice and (2) “complies with [s]ection 382 of the Code of Civil Procedure.” (§ 17203.)
Code of Civil Procedure section 382 is the statute that authorizes class actions, and the ballot pamphlet materials for Proposition 64 leave no doubt the voters understood the reference to this statute as requiring all representative UCL suits by private persons to proceed under the rules and principles governing class actions.2 As I will discuss, those rules and principles prominently require that the representative, or named, plaintiff have a claim typical of the class, and that each class member be someone who could bring suit on his or her own behalf.
Applying these principles to the issues before us, I concur in the majority’s conclusion that, under Proposition 64’s injury-in-fact and causation requirements, the named plaintiffs in a UCL action alleging deceptive or fraudulent advertising of an injurious product must plead and prove they purchased the product in actual reliance on the false advertising. I also agree the named plaintiffs need not allege or establish that the asserted false advertising was the sole cause of the purchases. Nor, where the defendant has engaged in a pervasive campaign of false claims over a long period of time, need the named plaintiffs cite a specific advertisement or advertisements that influenced their purchases.
However, I respectfully disagree with the majority insofar as it concludes that unnamed class members in a private UCL class action need not meet the injury-in-fact and causation requirements of Proposition 64. In this UCL suit alleging that tobacco companies engaged in false advertising about the health risks of their products, the majority applies its mistaken holding to conclude, in effect, that so long as the named plaintiffs actually relied on the allegedly deceptive advertising claims when buying and smoking cigarettes, they may seek injunctive and restitutionary relief on behalf of all California smokers who simply saw or heard such ads during the period at issue, regardless of whether false claims contained in those ads had anything to do with any class member’s decision to buy and smoke cigarettes.
Even if the majority’s holding has some sympathetic appeal on the particular facts alleged here, the rule the majority announces will apply *331equally to less egregious cases, where it invites the very kinds of mischief Proposition 64 was intended to curtail. Accordingly, I cannot join the majority’s erroneous determination, which turns class action law upside down and contravenes the initiative measure’s plain intent.
As indicated above, Proposition 64 requires all UCL suits brought by private persons on behalf of others to comply with Code of Civil Procedure section 382 by proceeding as class actions. It is well settled that maintenance of a class suit requires proof, among other things, of a sufficiently numerous, ascertainable class with a well-defined community of interest. The “community of interest” requirement has three aspects: (1) predominant common questions of law and fact, (2) class representatives with claims or defenses typical of the class, and (3) class representatives who can adequately represent the class. (E.g., Fireside Bank v. Superior Court (2007) 40 Cal.4th 1069, 1089 [56 Cal.Rptr.3d 861, 155 P.3d 268]; Sav-On Drug Stores, Inc. v. Superior Court (2004) 34 Cal.4th 319, 326 [17 Cal.Rptr.3d 906, 96 P.3d 194]; Linder v. Thrifty Oil Co. (2000) 23 Cal.4th 429, 435 [97 Cal.Rptr.2d 179, 2 P.3d 27]; Richmond v. Dart Industries, Inc. (1981) 29 Cal.3d 462, 470 [174 Cal.Rptr. 515, 629 P.2d 23].) As the majority notes, these criteria are analogous to those set forth in Federal Rules of Civil Procedure, rule 23(a) (28 U.S.C.), and we look to federal decisions under that rule for guidance in matters of class action procedure.
Ascertainability and typicality both require that members of a certified class themselves have causes of action against the defendant. Courts, state and federal, repeatedly have stressed that the definition of a class cannot be so broad as to include persons who would lack standing to bring suit in their own names. (E.g., American Suzuki Motor Corp. v. Superior Court (1995) 37 Cal.App.4th 1291, 1294-1295 [44 Cal.Rptr.2d 526] [class action for breach of warranty based on motorcycle design defect could not be maintained on behalf of purchasers who suffered no injury or property damage from alleged defect]; Collins v. Safeway Stores, Inc. (1986) 187 Cal.App.3d 62, 69, 72-73 [231 Cal.Rptr. 638] (Collins) [in action alleging defendant’s distribution of 20 percent contaminated and 80 percent uncontaminated eggs, randomly commingled, no class could be ascertained because it was impossible to tell whether any particular putative class member bought contaminated eggs]; Oshana v. Coca-Cola Co. (7th Cir. 2006) 472 F.3d 506, 514-515 [in statutory consumer-fraud action claiming defendant misrepresented ingredients in its fountain diet soda, requirements of ascertainability and typicality were not met where proposed class included persons who did not rely on misrepresentations when buying defendant’s fountain soda]; Denney v. Deutsche Bank AG (2d Cir. 2006) 443 F.3d 253, 264 [stating that, while class members need not make individual showings of standing at the certification stage, “no class may be certified that contains members lacking . . . standing [under U.S. Const., art. III]”]; Adashunas v. Negley (7th Cir. 1980) 626 F.2d 600, 604 [stating, in *332action on behalf of all learning-disabled Indiana public school students who allegedly had not been identified and thus were not receiving their special-education entitlement, that under article Ill’s “case or controversy” requirement, it must “be reasonably clear that the proposed class members have all suffered a constitutional or statutory violation warranting some relief’; denial of class certification affirmed]; In re Copper Antitrust Litigation (W.D.Wis. 2000) 196 F.R.D. 348, 353 [stating that “[i]mplicit in Rule 23 is the requirement that the plaintiffs and the class they seek to represent have standing”]; Clay v. American Tobacco Co. (S.D.Ill. 1999) 188 F.R.D. 483, 490 [stating, in suit against tobacco companies for wrongful youth-oriented marketing, seeking disgorgement of all profits from cigarette sales to minors, and proposing class of all United States persons who, as children, bought and smoked defendants’ cigarettes, that “[t]he definition of a class should not be so broad ... as to include individuals who are without standing to maintain the action on their own behalf’; class certification denied]; McElhaney v. Eli Lilly & Co. (D.S.D. 1982) 93 F.R.D. 875, 878 (McElhaney) [in suit claiming precancerous condition caused by in útero exposure to diethylstilbestrol (DES), proposed class could not include persons who lacked standing to sue in their own right because they were not exposed to DES and sustained no injury in fact]; see 7AA Wright et al., Federal Practice and Procedure (3d ed. 2005) § 1785.1, pp. 387-388, fn. 10.)3
In this private UCL action alleging fraudulent advertising by tobacco companies, the majority agrees the named plaintiffs could not sue without meeting Proposition 64’s standing requirement of personal loss stemming from their actual reliance on the deceptive ads. Under well-established class action rules, the putative class the named plaintiffs seek to represent may include only persons who could themselves bring similar UCL claims in their own behalves. They could do so only if they themselves met Proposition 64’s standing requirement. It follows inexorably that any UCL class certified in this action must be limited to those individuals who also actually relied on defendants’ alleged deceptive advertising campaign when purchasing and smoking cigarettes, and thereby suffered loss.
*333In holding otherwise, the majority thus determines, contrary to the electorate’s clear directive, that normal class action rules do not apply to UCL private representative actions governed by Proposition 64. The majority says that under Proposition 64, as long as the named plaintiffs in a UCL action have suffered “injury in fact and loss of money or property” caused by the unfair practice alleged, they can file a representative UCL action, and even seek UCL restitutionary relief, on behalf of members of the public to whom the unfair practice caused no actual harm or loss. None of the majority’s reasons for interpreting Proposition 64 in this way is persuasive.4
The majority notes that the words of Proposition 64 say only that the “claimant”—the named plaintiff in a private representative UCL action— must “meet[] the standing requirements of [sjection 17204” (§ 17203), that is, must have suffered “injury in fact and [loss of] money or property” as a result of the unfair practice. (§ 17204.) The initiative’s language, the majority stresses, does not impose similar express limitations on the persons to be represented. However, those limitations are incorporated into the UCL by Proposition 64’s additional specification that, to maintain a representative action, a private person must “compl[y] with [sjection 382 of the Code of Civil Procedure” (§ 17203)—i.e., must satisfy the procedural rules governing class actions. As we have seen, those rules provide that the putative class cannot include persons to whom an alleged unfair practice caused no actual injury or loss, and who thus could not bring suit in their own names.
The majority insists Proposition 64 sought only to end a single, narrow form of abuse—“shakedown” suits by uninjured named plaintiffs—and did not otherwise restrict the role of private representative actions in enforcing the UCL’s prohibition of unfair business practices. However, the ballot materials for the initiative measure indicate otherwise.
*334Both the neutral descriptions of the measure and the proponents’ arguments emphasized that under Proposition 64, the government officials enumerated in the UCL would retain the right to maintain representative enforcement actions on behalf of the public generally, but private persons would not. (Voter Information Guide, supra, official title and summary of Prop. 64 by Atty. Gen., p. 38 [Prop. 64 “[authorizes only the California Attorney General or local government prosecutors to sue on behalf of general public to enforce unfair business competition laws” (italics added)]; id., analysis of Prop. 64 by Legis. Analyst, p. 39 [Prop. 64 “requires that unfair competition lawsuits initiated by any person, other than the Attorney General and local public prosecutors, on behalf of others, meet the additional requirements of class action lawsuits” (italics added)]; id., argument in favor of Prop. 64, p. 40 [Prop. 64 “[a]llows only the Attorney General, district attorneys, and other public officials to file lawsuits on behalf of the People of the State of California to enforce California’s unfair competition law” (original italics)]; id., rebuttal to argument against Prop. 64, p. 41 [Prop. 64 “[p]ermits only real public officials like the Attorney General or District Attorneys to file lawsuits on behalf of the People of the State of California” (original italics)].) The proponents urged that passage of the measure would “[stop] fee-seeking trial lawyers from exploiting a loophole in California law—A LOOPHOLE NO OTHER STATE HAS—that lets them ‘appoint’ themselves Attorney General and file lawsuits on behalf of the People of the State of California.” (Id., rebuttal to argument against Prop. 64, p. 41.)
Nothing in these statements and arguments suggested a private lawyer could sue on behalf of the public so long as he or she had a single client to whom the unfair practice had caused actual injury and loss, and who could thus serve as a named plaintiff. On the contrary, Proposition 64 clearly sought to eliminate the UCL’s former “private attorney general” enforcement feature by precluding individuals, even if themselves injured, from suing on behalf of others except under the rules normally attendant on class actions. Thus, just as Proposition 64 eliminated the right of uninjured private persons to represent those who have been injured (Californians for Disability Rights v. Mervyn’s, LLC (2006) 39 Cal.4th 223, 232 [46 Cal.Rptr.3d 57, 138 P.3d 207] (Mervyn’s)), it also eliminated any private right, even of injured persons, to represent those who have not been injured.
Indeed, the majority’s holding encourages the very sort of abusive shakedown suits that Proposition 64 was designed to curb. That holding can be applied not only to the unsympathetic facts alleged in this case—i.e., that large tobacco companies lured consumers into nicotine addiction by falsely *335claiming, over many years, that cigarettes were safe—but also to a myriad of situations in which the anticonsumer implications are far less dire.
Consider the following scenario: A local chain of family-owned supermarkets receives a large shipment of ground beef and puts it out for sale. The stores’ meat departments label and display the meat as “ground round,” the leanest grade. The stores’ regular price for ground round is $5.99 per pound, but the display labels offer the meat from this shipment at a “reduced price” of $4.99 per pound. The company has not intentionally misrepresented the product. However, in the exercise of due care, it should have known the meat is ground sirloin, a wholesome but slightly fattier grade. The chain is actually selling other quantities of ground sirloin, correctly labeled, at its regular $4.99 per pound price.
Customer A visits one of the stores, seeking to buy ground beef. Concerned about his fat intake, he does not intend to purchase any grade other than ground round and would not knowingly do so. Relying upon the incorrect “ground round” label, he buys a pound of the meat, so labeled, at the $4.99 price, and consumes it. A substantial number of other customers also see the incorrect “ground round” labels. However, many do not care about the grade of ground beef they eat, do not realize the significance of the label, and are not influenced by it. Nonetheless, they also buy substantial quantities of the mislabeled meat and happily consume it.
Customer A later discovers the labeling mistake. He obtains counsel and brings a UCL action alleging false advertising that caused him actual injury or loss in the amount of $4.99. He claims restitution to himself in that amount. In the suit, he further seeks to certify a class of all other customers who saw the incorrect labels and purchased the mistakenly mislabeled meat. Regardless of whether these persons relied on the incorrect description when purchasing the mislabeled product, he prays for restitution, on their behalf, of all profits the stores received from such purchases.
Under the majority’s concept of no-injury class actions, the plaintiff, Customer A, may well succeed in this endeavor if the case proceeds in court. Realizing this, the company quickly settles. That cannot be what the voters intended when they adopted the substantial reforms set forth in Proposition 64.
The majority’s reasoning contains an even more fundamental flaw. As explained above, under the majority’s construction of Proposition 64, a person may be a party to a UCL private representative action as a class member even though he or she could not sue in his or her own name. Thus, an individual whose personal effort to bring a UCL action failed because he or she could not demonstrate any personal injury or loss caused by the unfair *336practice may simply join, as an uninjured class member, in an identical class action brought by another named plaintiff who does meet the minimal injury-in-fact and causation requirements. Again, this cannot be what the electorate intended to achieve by enacting Proposition 64.
The majority insists Proposition 64 did not alter the remedies the court may order in a private representative UCL action, including injunctive relief and, of particular note, the “restoration] to any person in interest [of] any money or property, real or personal, which may have been acquired by means of [the alleged] unfair competition.” (§ 17203, italics added.) In preProposition 64 cases, the majority points out, we held that this “may have” language promotes the UCL’s purpose of ensuring that wrongdoers do not profit by their misconduct, and allows the court to order restitutionary relief under the UCL without individualized proof of deception, reliance, and injury. (E.g., Bank of the West v. Superior Court (1992) 2 Cal.4th 1254, 1267 [10 Cal.Rptr.2d 538, 833 P.2d 545]; Committee on Children’s Television, Inc. v. General Foods Corp. (1983) 35 Cal.3d 197, 211 [197 Cal.Rptr. 783, 673 P.2d 660]; Fletcher v. Security Pacific National Bank (1979) 23 Cal.3d 442, 449-454 [153 Cal.Rptr. 28, 591 P.2d 51] (Fletcher).) Hence, the majority reasons, even after Proposition 64, an individual who was actually injured and suffered the loss of money or property as a result of a defendant’s unfair practice must still be able to sue on behalf of other persons from whom the defendant merely “may” have obtained money or property by wrongful means.5
*337Again, the majority’s analysis is not convincing. As the ballot materials for Proposition 64 made clear, the public officials enumerated in the UCL still may bring broad-based injunctive and restitutionary actions on behalf of the public to redress and prevent unfair or deceptive business practices. Public enforcement suits are not constrained by Proposition 64’s class action restrictions, and in such actions, the court may order the full range of remedies specified in the statute. But by specially providing that private UCL suitors may represent others only under the rules governing class actions, Proposition 64 withdrew from these plaintiffs any authority simply to force repayment of alleged wrongful profits on behalf of persons not truly and similarly affected by the alleged unfair practice. This change in the law was impelled by a belief that certain private litigants and their counsel had abused their authority as “private attorneys general” to “shake down” undeserving businesses. Accordingly, under Proposition 64’s class action provisions, private UCL plaintiffs may represent only those other persons with similar UCL claims that could be brought individually.6
In my view, therefore, the Court of Appeal properly upheld the trial court’s order granting defendants’ motion to decertify the UCL class approved prior to the adoption of Proposition 64. That class had been defined to include all persons who, as residents of California, “smoked . . . one or more cigarettes between June 10, 1993 [and] April 23, 2001, and who were exposed to [defendants’ marketing and advertising activities in California.” (Italics added.)
*338However, as the trial court and the Court of Appeal correctly concluded, Proposition 64, as applicable to this pending action, requires that class members in a UCL action, like the named plaintiffs, must have suffered actual injury and loss of money or property caused by defendants’ alleged deceptive advertising and marketing campaign. In turn, both courts concluded, because the necessary element of causation created so many potential issues of individual proof, there was no predominant commonality in the proposed class. Finding this reasoning entirely sound, I would affirm the judgment of the Court of Appeal.7
Chin, J., and Corrigan, J., concurred.
The petition of all respondents for a rehearing was denied August 12, 2009. George, C. J., did not participate therein. Baxter, J., Chin, J., and Corrigan, J., were of the opinion that the rehearing should be granted.
All unlabeled statutory references are to the Business and Professions Code.
(See Voter Information Guide, Gen. Elec. (Nov. 2, 2004) official title and summary of Prop. 64 by Atty. Gen., p. 38 (Voter Information Guide) [measure “[Requires private representative claims [under unfair competition statutes] to comply with procedural requirements applicable to class action lawsuits”]; id., analysis of Prop. 64 by Legis. Analyst, p. 39 [“measure requires that unfair competition lawsuits initiated by any [private] person ... on behalf of others, meet the additional requirements of class action lawsuits”].)
For purposes of California law, Collins expressly states that “ *[t]he definition of a class cannot be so broad as to include individuals who are without standing to maintain the action on their own behalf. Each class member must have standing to bring the suit in his own right.’ ” (Collins, supra, 187 Cal.App.3d 62, 73, quoting McElhaney, supra, 93 F.R.D. 875, 878.) The majority attempts to distinguish both Collins and McElhaney on grounds those cases simply present problems in certifying a class when the circumstances make it impossible, in the first instance, to ascertain if anyone was injured., and if so, who. But the purported distinction is unpersuasive. The premise upon which the “ascertainability” conclusions in Collins and McElhaney proceed is that the class may include only those persons who have suffered injury and could thus bring suit in their own behalves. This is equally true of the cases cited by McElhaney and discussed by the majority in footnote 15 of its opinion. (Maj. opn., ante, at p. 323.)
The majority’s error may stem, in part, from the fact that it largely misframes the issue. The majority repeatedly implies the question is whether each unnamed class member must “affirmatively demonstrate” (maj. opn., ante, at p. 315) or “individually show” (id., at p. 318) he or she has the same “standing” as the named plaintiff or plaintiffs before a class can be certified. The majority suggests this is “[o]ur reading” of the trial court’s decertification order. (Id., at p. 318, fn. 12.) However, as the majority briefly acknowledges (ibid.), defendants make no such argument. Indeed, class action principles include no such requirement; the identification of individual class members and their entitlement to personal recovery is determined only after a class has been certified and issues common to the class have been litigated.
As defendants contend, and as a fair reading of the trial court’s order indicates it understood, the true “class standing” issue at the certification stage is simply one of class definition. As applied under Proposition 64, this means only that any class to be certified in a private UCL action must be defined or described to include only those (as yet unidentified) persons who, like the named plaintiffs, have suffered actual injury and loss of money or property as a result of the alleged unfair business practice. That limitation may lead, in turn, as it did here, to a determination that individual issues of proof ultimately would predominate over common ones, thus negating the benefits of a class proceeding.
Fletcher, the pre-Proposition 64 case most on point, did hold, in a UCL action for restitution of illegal bank overcharges on short-term commercial loans, that an overcharged plaintiff who alleged he was unaware of the illegal practice could maintain a class action on behalf of some 50,000 other overcharged customers without any need for individualized proof that each class member was aware of the overcharge. Of course, the gravamen of that action was the illegality of the overcharge itself, regardless of any associated deception. Thus, all overcharged customers had suffered loss as a result of the unfair practice, the representative plaintiff did have a typical claim, and unnamed class members could have sued in their own names. Moreover, to the extent Fletcher and its progeny broadly suggested, under the UCL’s “may have acquired” language, that a private UCL action, individual or representative, could force disgorgement of unfair profits without strict regard to the persons from whom those profits actually were wrongfully obtained, we had, even before Proposition 64, rejected any such notion. (See Kraus v. Trinity Management Services, Inc. (2000) 23 Cal.4th 116, 126-137 [96 Cal.Rptr.2d 485, 999 P.2d 718] [UCL authorizes not general “disgorgement,” but only restitution to specific persons from whom money was obtained by means of unfair practice; hence, in representative UCL action, statute does not authorize defendant’s payment of profits into fluid recovery fund]; Korea Supply Co. v. Lockheed Martin Corp. (2003) 29 Cal.4th 1134, 1143-1152 [131 Cal.Rptr.2d 29, 63 P.3d 937] [in individual UCL action, plaintiff who alleges injury or loss from unfair business practice is entitled only to restitution, not “disgorgement,” and thus may not recover money not taken directly from him or her as a result of the unfair practice]; but see Massachusetts Mutual Life Ins. Co. v. Superior Court (2002) 97 Cal.App.4th 1282, 1288-1292 [119 Cal.Rptr.2d 190].)
Proposition 64 confirmed these principles. It expressly requires both (1) that a private person may sue under the UCL only if money or property was taken from him or her by means of an *337unfair business practice and (2) that he or she may represent others only under the rules generally pertaining to class actions. The measure thus made clear that all UCL class members must have suffered actual loss of money or property caused by the unfair practice. Where, as here, the gravamen of the complaint is fraudulent inducement, all class members in a private UCL suit must therefore meet the standard of actual reliance upon which such a claim depends. In such an action, a smoker who may have been “exposed” to, but was not deceived by, the alleged false advertising claims is not entitled to restitution of the money he or she paid for cigarettes.
Contrary to plaintiffs’ and the majority’s suggestion, a conclusion that both the named, or representative, plaintiff and the UCL class he or she seeks to represent must include only persons who satisfy Proposition 64’s injury-in-fact and causation requirements does not contravene our determination in Mervyn’s that the initiative measure made no change in “the substantive rales governing business and competitive conduct.” (Mervyn’s, supra, 39 Cal.4th 223, 232.) As Mervyn’s explained, “[n]othing a business might lawfully do before Proposition 64 is unlawful now, and nothing earlier forbidden is now permitted.” (Ibid.) Now, as before, damages are unavailable, and “a private person may recover restitution only of those profits that the defendant has unfairly obtained from such person . . . .” (Ibid.) Now, as before, enumerated public officials may enforce the UCL by means of litigation seeking broad forms of injunctive and restitutionary relief. The only changes wrought by Proposition 64 are that uninjured private persons cannot seek restitution on behalf of others (Mervyn’s, supra, at p. 232), and that private persons, even if themselves injured, may not represent a class of persons who suffered no injury and loss caused by the alleged unfair practice.
Plaintiffs argue that even if UCL class members must, like the named plaintiffs themselves, be persons who actually relied on defendants’ alleged disinformation campaign when deciding to buy and smoke cigarettes, the previously certified class of “exposed” smokers met this standard, without creating undue problems of individual proof, under the doctrine of presumed reliance. (See, e.g., Vasquez v. Superior Court (1971) 4 Cal.3d 800, 815 [94 Cal.Rptr. 796, 484 P.2d 964].) The Court of Appeal correctly rejected this contention. The duration and diversity of the alleged campaign of deception, the myriad of different statements to which various members of the putative class were exposed over time, the prominent, long-standing private and governmental countercampaign to alert the public to the dangers of smoking, and the many cultural and psychological factors that influence individual decisions to smoke all militate against a presumption that every smoker who merely saw or heard deceptive cigarette advertising and marketing statements believed and relied on those statements in deciding to consume tobacco products.