In the ongoing class action litigation brought by Advertisers against Facebook (see Pay-Per-Click Advertising Case Against Facebook Survives Motion to Dismiss) the social networking site successfully moved to dismiss the Advertisers' claims of fraud under California's Unfair Competition Law. In re Facebook PPC Advertising Litigation, Nos. 5:09-cv-03043-JF, 5:09-cv-03519-JF, 5:09-cv-03430-JF, 2010 WL 5174021 (N.D. Cal. Dec. 15, 2010). The District Court for the Northern District of California found that the plaintiffs had not met the heightened pleading requirement under Federal Rule of Civil Procedure 9(b), requiring fraud claims to be plead with "particularity."