• On August 16, 2011, the United States Court of Appeals for the Seventh Circuit affirmed a federal trial court’s denial of class certification and grant of summary judgment for defendants in a case alleging violations of Indiana’s anti-cramming statute. Defendants included billing clearinghouses and billing aggregators for third-party service providers. Both courts rejected the entirety of plaintiffs’ claims, finding that the anti-cramming law does not apply to the defendants because they are not regulated carriers, and that, even if the law did apply, no violation occurred because the services were in fact “ordered.” As the Court of Appeals explained, “we conclude that the Indiana anticramming regulation does not apply to these defendants because they are not telephone companies and did not act in this case as billing agents for telephone companies. Second, we find that there was no unjust enrichment where the plaintiff ordered and received the services in question. Third, we find that the Deceptive Commercial Solicitation Act does not apply because the plaintiff had actually ordered the services for which it was charged.” Lady Di’s, Inc. v. Enhanced Servs. Billing, Inc., No. 10-3903 (7th Cir.).