Several wireless companies sued Georgia’s Department of Revenue for refunds of sales taxes they said had been charged unlawfully on exempt wireless Internet services. The trial court dismissed the action on multiple grounds, including standing and class-action concerns, after an earlier appellate ruling about refund prerequisites had been reversed by the Supreme Court of Georgia. The Court of Appeals vacated its earlier opinion, adopted the Supreme Court’s ruling on the first issue, and addressed the remaining claims. It held that the companies’ refund claims raised standing and statutory questions that required analysis under the governing tax provisions. The court also examined whether the plaintiffs could pursue refunds for the relevant periods and whether the action was a statutory class action. The decision preserved the Supreme Court’s controlling interpretation while remanding the unresolved issues for proper treatment under Georgia tax and civil-procedure law.