context: Zuckman also seeks restitution on behalf of himself and the general public for their purchases of Monster Energy drinks. See Compl. at 11; Pl.'s Mot. for Remand at 13. Restitution claims, like claims for statutory damages or attorney fees, generally cannot be aggregated for purposes of satisfying the amount-in-controversy requirement.
citation_a.signal: see also
citation_a.parenthetical: "Separate and distinct claims, regardless of whether they share a community of interest or originate in a single transaction or event, may not be aggregated...."
citation_a.sentence: See Snyder, 394 U.S. at 335, 89 S.Ct. 1053 (holding that the “separate and distinct claims of two or more plaintiffs cannot be aggregated” to establish jurisdiction); see also Georgiades v. Martin-Trigona, 729 F.2d 831, 833 (D.C.Cir.1984) (“Separate and distinct claims, regardless of whether they share a community of interest or originate in a single transaction or event, may not be aggregated....”). However, there is an exception to this rule in cases where “two or more plaintiffs unite to enforce a single title or right in which they have a common and undivided interest,” Snyder, 394 U.S. at 335, 89 S.Ct. 1053, such as when claimants seek disgorgement of money obtained through unlawful trade practices.
citation_b.signal: see
citation_b.identifier: 394 U.S. 335, 335
citation_b.parenthetical: holding that the "separate and distinct claims of two or more plaintiffs cannot be aggregated" to establish jurisdiction
citation_b.sentence: See Snyder, 394 U.S. at 335, 89 S.Ct. 1053 (holding that the “separate and distinct claims of two or more plaintiffs cannot be aggregated” to establish jurisdiction); see also Georgiades v. Martin-Trigona, 729 F.2d 831, 833 (D.C.Cir.1984) (“Separate and distinct claims, regardless of whether they share a community of interest or originate in a single transaction or event, may not be aggregated....”). However, there is an exception to this rule in cases where “two or more plaintiffs unite to enforce a single title or right in which they have a common and undivided interest,” Snyder, 394 U.S. at 335, 89 S.Ct. 1053, such as when claimants seek disgorgement of money obtained through unlawful trade practices.