Two recent appellate decisions—Noohi v. Johnson & Johnson Consumer Inc., 146 F.4th 854 (9th Cir. 2025), petition for cert. filed, No. 25-874 (U.S. Jan. 16, 2026), which affirmed class certification, and In re Folgers Coffee Marketing, 159 F.4th 1151 (8th Cir. 2025), which reversed class certification—address the role that varying consumer perceptions of challenged representations can play in the class certification analysis required under Rule 23.