Sarah Davis


San Francisco

Sarah Davis is an experienced and nimble litigator who focuses her practice on the defense of consumer class actions, complex commercial litigation, and regulatory enforcement matters. Sarah has represented numerous financial institutions and fintech companies in unfair and deceptive practice in actions brought by consumers, state attorneys general, the Consumer Financial Protection Bureau, and the Federal Trade Commission. Sarah is particularly adept at understanding complex financial and credit data and payment processing systems, which enables Sarah to efficiently and effectively defend her clients. Sarah routinely defends clients’ arbitration clauses, revises arbitration clauses, and has experience responding to mass arbitration demands.

Sarah has particular expertise defending challenges to overdraft fees, including challenges to authorize positive, settle negative (“APSN”) transactions, and has represented Capital One, U.S. Bank, First Hawaiian Bank, and Union Bank in putative class actions challenging APSN fees. Separately, Sarah has defended two large national banks in enforcement actions related to overdraft fees and obtained a non-public resolution of voluntary remediation.

Sarah also has a robust practice defending both small and large companies against allegations of food mislabeling. She has successfully defended or reached favorable settlement terms regarding challenges to “all natural,” “no sugar added,” and “non-GMO” claims.