In Arias v. Superior Court, No. S155965, __Cal. 4th __ (2009), issued June 29, 2009, the California Supreme Court held that an employee who sues an employer for labor law violations on behalf of himself and others seeking civil penalties under the Private Attorneys General Act (“PAGA”) (Lab. Code § 2698 et seq.) need not meet class action requirements, while an employee who pursues the same claims under the Unfair Competition Law (“UCL”) (Bus. & Prof. Code § 17200 et seq.) must bring the representative claims as a class action.