Danganan, J., Aplt. v. Guardian Protection Svc.

This matter presents issues of Pennsylvania law on certification from the United States Court of Appeals for the Third Circuit, centering on the reach of Pennsylvania's *10 Unfair Trade Practices and Consumer Protection Law (the "UTPCPL" or the "Law").

I. Background

The UTPCPL provides, in relevant part, that "[u]nfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce ... are ... unlawful." 73 P.S. § 201-3. The Law permits any "person" to bring a private action against any other "person" for violations of the statute. Id. § 201-9.2(a). The…