In In re Groupon Marketing and Sales Practices Litigation, No. 13-55118 (9th Cir. Feb. 19, 2015), the district court approved a settlement of a class action challenging Groupon’s marketing practices.  In an unpublished opinion, the Ninth Circuit vacated and remanded the case to the district court.  While not reaching the district court’s evaluation of the fairness of the settlement, the Ninth Circuit emphasized the need for district court judges to make detailed findings to quantify, or at least fairly estimate, the value of relief to the class and to permit a comparison of the benefit provided to the class to the fees made available to class counsel.  The court remanded the case so that these amounts could be calculated, or reliably bounded within ranges of expected values, because the Ninth Circuit was unable to evaluate the settlement on the current record.