In Rynasko v. New York University, 63 F.4th 186 (2nd Cir. 2023), the U.S. Court of Appeals for the Second Circuit potentially revived a putative class action against NYU seeking a partial refund of tuition fees due to NYU's response to the COVID pandemic. In an opinion authored by Circuit Judge Beth Robinson, and joined-in-part by Circuit Judges Michael Park and Barrington Parker, the majority affirmed the district court's dismissal of Christina Rynasko's complaint, but reversed the district court's refusal to grant leave to amend the complaint, finding that the proposed amendment—to add another lead plaintiff who had standing—would not be futile. In so doing, the Second Circuit joined the Seventh, Ninth, and D.C. circuits in recognizing the plausibility of implied breach of contract claims brought by students seeking partial tuition reimbursements in the COVID-19 context.