Class-action lawyers might have to search beyond the U.S. Court of Appeals for the Eleventh Circuit after it ordered the U.S. District Court for the Southern District of Florida to scrap a multimillion-dollar class-action settlement reached by Godiva Chocolatier and the class action representative.

The settlement involved a lawsuit in which a violation of the Fair and Accurate Credit Transactions Act of 2003 was implicated. And Scott N. Wagner, a partner in Bilzin Sumberg’s litigation group who was not involved in the case, said it is significant because class-action defense attorneys can now breathe a sigh of relief with the Eleventh Circuit’s latest ruling requiring actual damages as a predicate to seeking relief under the statute.