Letter · Class Actions / Representative Proceedings
Letter to the respondent's lawyers about communications with class members
Letter from the applicant's lawyers reminding the respondent that communications with class members who are the firm's clients must go through the firm, and setting expectations for non-client class members under GPN-CA para 11.
- Kind
- Letter. A letter or email you adapt and send.
- Where it applies
- Australia, Commonwealth
- AI use
- Yellow AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at
- 18 October 2026
- Status
- Maintained. Checked on 18 October 2026 against the 3 authorities it cites, for Australia and Commonwealth.
- Version
- 1
- Source
- Written for this library
When to use it
Use when the respondent or its agents contact, or are about to contact, class members about the proceeding, for example with individual settlement offers, releases, surveys or product remediation that touches the claims. Send it early, and keep a copy for any application for orders about communications.
How AI may be used
AI may assemble the letter and the schedule of affected class members from the client and registration records; a lawyer decides what is asked for and whether orders will be sought.
AI may
- Compile the list of class members who are clients of the firm, with retainer dates, from the client register
- Summarise the respondent's communication that prompted the letter, quoting it exactly and attaching it
- Fill the letter from the approved template with the proceeding details and response date
AI must not
- Must not disclose client class members' names or details to the respondent beyond what the lawyer approves
- Must not allege that the respondent breached the practice note or acted improperly without the lawyer's decision
- Must not threaten an application to the Court unless the client has instructed it
The lawyer checks
- The client status of each class member named is confirmed from signed retainers, and disclosing it is authorised
- The request is limited to communications "in relation to the proceeding" and does not try to stop ordinary business communications (para 11.1)
- Whether to seek orders or a protocol now, and what notice to class members might be needed
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Class Actions / Representative Proceedings
- Opt-out notice, notice distribution plan and settlement-notice checklist (Federal Court class action)
- Retainer letter and conditional costs agreement for a representative applicant (Federal Court class action)
- Litigation funding agreement and costs review checklist (including common fund orders and Victorian group costs orders)
- Pre-filing memo: Part IVA threshold requirements and class definition
- Settlement approval application checklist (Federal Court class action, s 33V and GPN-CA)
- Settlement distribution scheme (with safeguards for technology-assisted claims assessment)
- Periodic update letter to group members (clients and registered group members)
- Group member registration and intake protocol (including AI triage of registrations)
- Prompt template with guardrails: reconciling registrations to the class definition
All precedents for Class Actions / Representative Proceedings · Tasks and AI use in this area