The Eastern District of Pennsylvania decertified a class in a suit brought by a homeowner who alleges her insurer, Chicago Title Insurance Company (Chicago Title), overcharged her and others similarly situated for title insurance obtained when refinancing her mortgage. In Pennsylvania, a Rate Manual provides three different rate tiers for title insurance, with discounted rates for purchasers who refinance their homes within a few years after obtaining a previous title policy. April 2007, the court certified the class, but Chicago Title filed a renewed motion to decertify the class, citing a decision by the Third Circuit, Hunt v. United States Tobacco Company, 538 F.3d 217 (3d Cir. 2008), that came down after the initial certification ruling. Chicago Title argued Hunt requires plaintiffs to prove justifiable reliance in order to succeed on a claim brought under Pennsylvania’s unfair trade practices and consumer protection law. The court agreed, granting Chicago Title’s motion to decertify, reasoning that finding the justifiable reliance requirement would make individual issues predominate over issues common to the class.