; Cardenas v. Toyota Motor Corp., 2021 WL 5811741, at *13 (S.D. Fla. Dec. 6, 2021) (“[I]n view of the revision of the class definition to only those who purchased a class vehicle from an authorized dealer, ‘a permissible inference of common exposure may be drawn.'

“At bottom, if proof of the representative's claims would prove the proposed class's claims, the representative's claims are typical of the proposed class.” Cardenas v. Toyota Motor Corp., No. 18-22798-CIV, 2021 WL 5811741, at *14 (S.D. Fla. Dec. 6, 2021). Like above, this is a low bar.

. Instead, a plaintiff must simply prove that “the alleged practice was likely to deceive a consumer acting reasonably in the same circumstances.” Lewis, 530 F.Supp.3d at 1234 (citation omitted); see also Cardenas v. Toyota Motor Corp., No. 18-CV-22798, 2021 WL 5811741, at *12 (S.D. Fla. Dec. 6, 2021) (granting motion to certify class where FDUTPA plaintiff need only show that a reasonable consumer would have been harmed by defendant's conduct); Collins v. Quincy Bioscience, LLC, No. 19-CV-22864, 2020 WL 3268340, at *29 (S.D. Fla. Mar. 19, 2020)

Here, FCA's alleged conduct was uniform with respect to all class members in at least one important way—it never disclosed the Inflator Defect to consumers prior to the sale of the Class Vehicles. See Cardenas v. Toyota Motor Corporation, 2021 WL 5811741, at *13 (S.D. Fla. Dec. 6, 2021) ("all class members received the same information from defendant regarding the purported defect - which is to say, no information.") (citation omitted). And that omission is material because a reasonable factfinder could infer that if consumers knew their Class Vehicles contained defective airbags, they would not have made the purchase, or they would have paid less for their vehicles.

The dispute over how to appropriately incorporate these factors has come up in district courts across the country-often in cases involving these same two experts. See, e.g., Cardenas v. Toyota Motor Corp., No. 18-22798-CIV, 2021 WL 5811741, at *4 (S.D. Fla. Dec. 6, 2021) (summarizing dispute and collecting cases). Some courts conclude that Gaskin and Weir's methods do not adequately take into account these factors, whereas others conclude that

(S.D. Fla. 2020). “[A]bsent specific proof to the contrary, the adequacy of class counsel is presumed.” Cardenas v. Toyota Motor Corp., 2021 WL 5811741, at *15 (S.D. Fla. Dec. 6, 2021). Here, Plaintiffs' counsel has significant experience litigating class actions and other complex litigation as evidenced by the two firm resumes submitted with the Motion. DE 50-1 at 19099, 201-14.

The Court previously observed in its class certification order that Cardenas must show that the alleged deceptive conduct would have caused a reasonable person to overpay for their vehicle. See Cardenas v. Toyota Motor Corp., 2021 WL 5811741, at *12 (S.D. Fla. Dec. 6, 2021). This means Wilcox's testimony does “fit” the case-if Toyota, through Wilcox, can establish that a reasonable person would still have purchased a class vehicle at the same price in the face of a disclosure, then Cardenas cannot establish that the class suffered damages “as a result” of Toyota's deceptive conduct. Fla. Stat. § 501.211(2).

But these objections go to weight, not admissibility. See Cardenas v. Toyota Motor Corp., 2021 WL 5811741, at *4-5 (S.D. Fla. Dec. 6, 2021) (collecting cases). As other judges in this district have acknowledged: “While there will be occasions when the proffered survey is so flawed as to be completely unhelpful to the trier of fact and therefore 4 inadmissible, such situations will be rare.”

See Maiz v. Virani, 253 F.3d 641, 666 (11th Cir. 2001) (“Vigorous crossexamination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking [debatable] but admissible evidence.”); Cardenas v. Toyota Motor Corp., 2021 WL 5811741, at *5 (S.D. Fla. Dec. 6, 2021) (“[A]rguments about a consumer survey's methodology generally go to weight, not admissibility.

GM's challenges - to the soundness of certain underlying factual assumptions or to the weight of her analysis - are questions properly for the fact finder to consider. In re Arris Cable Modem Consumer Litig., 327 F.R.D. 334, 372-73 (N.D. Cal. 2018); Cardenas v. Toyota Motor Corp., No. 18-22798, 2021 WL 5811741, at *5 (S.D. Fla. Dec. 6, 2021) (collecting cases). GM has not shown that Dr. Iyengar's opinions are inadmissible.