In In Re Subway Footlong Sandwich Marketing and Sales Practices Litigation, 869 F.3d 551 (7th Cir. 2017) (No. 16-1662), plaintiff claimed he was deceived by a Subway sandwich marketed as a foot-long sandwich that was actually only 11 inches long.  Discovery showed that all Subway sandwiches were identical – the unbaked breadsticks were uniform, the meat, cheese, and other ingredients were standardized – and the variation in sandwich size was attributable to the baking process.  With no compensable injury, the parties reached an injunctive settlement and agreed to fees of $525,000.  Frequent objector Ted Frank objected, arguing the settlement enriched only the lawyers and provided no meaningful class benefit.  The district court approved the settlement and the Seventh Circuit reversed.  As a class member, Frank had standing to challenge class certification and the approval of the settlement, even though reversal only unwound the attorneys’ fees.  As to the merits, the court found the class representative was not adequate.  A settlement that results only in a benefit for class counsel and no meaningful relief for the class “is no better than a racket.”  The court found it was cynical to suggest the injunction – “a set of procedures designed to achieve better-bread length uniformity” – provided value.  The district court should have dismissed the case “out of hand.”