In Osborne v. Subaru of America, Inc. (1988) 198 Cal. App. 3d 646, the plaintiffs alleged reliance on the defendant auto distributor's national advertising campaign and sought class certification on their claims of breach of express warranty, fraud, and negligent misrepresentation. The trial court found "reliance was an issue that would have to be litigated as to each individual plaintiff" and denied certification. (Id. at p. 660.) On appeal, the plaintiffs contended reliance could be established by "class proof and inferences drawn therefrom." (Ibid.) The reviewing court disagreed, noting "defendants presented deposition evidence in opposition to the certification motion showing that three of the plaintiffs saw no advertisements at all before making their purchases." As such, the plaintiffs "failed to show that representations were made to each class member" and thus "there was no basis to draw an inference of classwide reliance without a showing that representations were made uniformly to all members of the class." (Osborne, supra, 198 Cal. App. 3d at p. 661.)