---
title: "Letter to the respondent's lawyers about communications with class members"
url: "https://ailawframework.com/precedents/class-actions-representative-proceedings/letter-on-respondent-communications-with-class-members"
type: "precedent"
site: "AI Law Framework"
id: "a7-letter-on-respondent-communications-with-class-members"
area_id: "A7"
kind: "letter"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-18"
---

# 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…

Canonical page: https://ailawframework.com/precedents/class-actions-representative-proceedings/letter-on-respondent-communications-with-class-members  
Law stated as at: 2026-10-18

Site index for agents: https://ailawframework.com/llms.txt

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.

## Key facts

- Kind: Letter. A letter or email you adapt and send.
- Practice area: [Class Actions / Representative Proceedings](https://ailawframework.com/precedents/class-actions-representative-proceedings.md)
- Jurisdictions: Australia, Commonwealth
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-18
- Status: Maintained. Checked on 2026-10-18 against the 3 authorities it cites, for Australia and Commonwealth.

## 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

## Authorities

- [Federal Court of Australia, Class Actions Practice Note (GPN-CA) paras 11.1 to 11.3 (communications with class members who are clients of the applicant's lawyers only through those lawyers; orders and protocols for non-client class members; plain-language explanation of consequences and encouragement to obtain legal advice)](https://www.fedcourt.gov.au/law-and-practice/practice-documents/practice-notes/gpn-ca)
- [Federal Court of Australia Act 1976 (Cth) s 33ZF (general power to make orders appropriate or necessary to ensure justice is done in the proceeding)](https://www.legislation.gov.au/C2004A01586/latest/text)
- [Federal Court of Australia Act 1976 (Cth) s 33X(5) (Court may order notice of any matter to be given to group members)](https://www.legislation.gov.au/C2004A01586/latest/text)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/class-actions-representative-proceedings/letter-on-respondent-communications-with-class-members and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*