In Kwikset Corp. v. Superior Court (2011) 51 Cal.4th 310, the California Supreme Court examined the standing requirements of the UCL in light of the 2004 approval of Proposition 64. The court explained that, "While the substantive reach of the UCL remains expansive, the electorate has materially curtailed the universe of those who may enforce its provisions. ... 'In 2004, the electorate substantially revised the UCL's standing requirement; where once private suits could be brought by "any person acting for the interests of itself, its members or the general public" citation, now private standing is limited to any "person who has suffered injury in fact and has lost money or property" as a result of unfair competition . The intent of this change was to confine standing to those actually injured by a defendant's business practices and to curtail the prior practice of filing suits on behalf of " 'clients who have not used the defendant's product or service, viewed the defendant's advertising, or had any other business dealing with the defendant . ...' " . While the voters clearly intended to restrict UCL standing, they just as plainly preserved standing for those who had had business dealings with a defendant and had lost money or property as a result of the defendant's unfair business practices.' " (Kwikset, supra, 51 Cal.4th at pp. 320-321.) Kwikset interpreted the Proposition 64 requirement that a party has "lost money or property" to mean that a party must "(1) establish a loss or deprivation of money or property sufficient to qualify as injury in fact, i.e., economic injury, and (2) show that that economic injury was the result of, i.e., caused by, the unfair business practice or false advertising that is the gravamen of the claim." (Kwikset, supra, 51 Cal.4th at p. 322.) Kwikset pointed out that " 'injury in fact' is a legal term of art" that makes reference to one of the requirements for federal standing under article III, section 2 of the United States Constitution. (Kwikset, at p. 322.) Indeed, "the text of Proposition 64 establishes expressly that in selecting this phrase the drafters and voters intended to incorporate the established federal meaning. The initiative declares: 'It is the intent of the California voters in enacting this act to prohibit private attorneys from filing lawsuits for unfair competition where they have no client who has been injured in fact under the standing requirements of the United States Constitution.' " (Ibid.) "Proof of injury in fact will in many instances overlap with proof of" loss of "money or property," as also required by Proposition 64. (Kwikset, supra, 51 Cal.4th at p. 323.) Kwikset noted that such "economic injury ... is itself a classic form of injury in fact," and "the quantum of lost money or property necessary to show standing is only so much as would suffice to establish injury in fact ... ." (Id., at pp. 323-324.) "However, because economic injury is but one among many types of injury in fact, the Proposition 64 requirement that injury be economic renders standing under Business and Professions Code section 17204 substantially narrower than federal standing under article III, section 2 of the United States Constitution, which may be predicated on a broader range of injuries." (Kwikset, at p. 324.) Nevertheless, injury in fact is "not a substantial or insurmountable hurdle"; it suffices "to '"allege some specific, 'identifiable trifle' of injury." ' " (Ibid.) "If a party has alleged or proven a personal, individualized loss of money or property in any nontrivial amount, he or she has also alleged or proven injury in fact." (Id. at p. 325.) Finally, "Proposition 64 requires that a plaintiff's economic injury come 'as a result of' the unfair competition ... . . 'The phrase "as a result of" in its plain and ordinary sense means "caused by" and requires a showing of a causal connection or reliance ... .' " (Kwikset, supra, 51 Cal.4th at p. 326.)