Hernandez v. Mimi's Rock Corp.

CourtDistrict Court, N.D. California
DecidedAugust 26, 2024
Docket4:21-cv-04065
StatusUnknown

This text of Hernandez v. Mimi's Rock Corp. (Hernandez v. Mimi's Rock Corp.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hernandez v. Mimi's Rock Corp., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ALFREDO HERNANDEZ, Case No. 21-cv-04065-JST

8 Plaintiff, ORDER DENYING IN PART, 9 v. GRANTING IN PART MOTION TO DISMISS 10 DTI GMBH, Re: ECF No. 53 Defendant. 11

12 13 Before the Court is Defendant DTI GmbH’s (“DTI”) motion to dismiss. The Court will 14 deny the motion in part and grant the motion in part. 15 I. BACKGROUND 16 A. Parties 17 On June 9, 2023, Plaintiff Alfredo Hernandez filed his second amended complaint 18 (“SAC”) in this action against DTI, whom he claims fails to identify its product, Dr. Tobias 19 Omega 3 Fish Oil Triple Strength dietary supplement, by its common and usual name. Rather 20 than fish oi, Hernandez claims the product contains “a lab-synthesized solution resulting from a 21 chemical process in which an industrial solvent and ethanol are used to alter and substantially 22 transform otherwise unmarketable fish waste into a consumable product known as a fatty acid 23 ethyl ester, which Defendant deceptively pawns off on the unsuspecting public as fish oil.” ECF 24 No. 49 ¶ 6. Hernandez claims that through this obfuscation, DTI has “deceived [him] and 25 members of the class,” thereby “depriving them of a consumer’s most basic right to make an 26 informed purchasing decision.” Id. ¶ 65. 27 Hernandez filed his first amended complaint (“FAC”) in this putative class action against 1 Vitalabs subsequently moved to dismiss Hernandez’s FAC for lack of personal jurisdiction and 2 failure to state a claim upon which relief can be granted. ECF Nos. 39, 42. In granting those 3 motions to dismiss, the Court concluded that Hernandez failed to establish that MRI and Vitalabs 4 purposefully directed their activities at California, and therefore the Court lacked personal 5 jurisdiction over either Defendant. 6 B. Scientific Background 7 Before delving into the specific claims that Hernandez levies, a brief discussion concerning 8 fish oil, molecular chemistry, and Omega-3 fatty acid ethyl esters is in order.1 9 Omega-3’s “are polyunsaturated carboxylic acids that provide numerous health benefits to 10 the human body including a variety of critical organs and systems.” ECF No. 49 ¶ 23 (citing 11 Omega-3 Fatty Acids, National Institutes of Health, Office of Dietary Supplements (July 18, 12 2022), available at https://ods.od.nih.gov/factsheets/Omega3FattyAcids-Consumer) (permalink: 13 https://perma.cc/VB4N-FAXZ2) (last accessed August 23, 2024) (“Omega-3 Fatty Acids”). 14 Although 11 types of Omega-3’s exist, “the three most important to human physiology are alpha- 15 linolenic acid (“ALA”), docosahexaenoic acid (“DHA”) and eicosapentaenoic acid (“EPA”).” Id. 16 ¶ 24. The human body can only convert ALA into EPA and then to DHA in small amounts. Id. ¶ 17 23 (citing Omega-3 Fatty Acids). Therefore, the only practical way to increase one’s levels of 18 EPA and DHA is to increase the dietary intake of Omega-3 fatty acids. Id. 19 Notably, only in 2019 did the Food and Drug Administration (“FDA”) approve qualified 20 health claims relating to the consumption of EPA and DHA and its positive effect on human 21

22 1 Throughout the SAC, Hernandez includes detailed information regarding the processing of fish oils for packaging in dietary-supplement capsules. The referenced materials—a compilation of 23 published scientific journals, scientific textbooks, mass spectra, and compound summaries of various molecules, among others—are found in 38 footnotes appearing in the first 49 pages of the 24 SAC. See generally ECF No. 49 at 6–22. While the Court is neither an expert in organic chemistry nor the commercial fishing industry, it has been careful to apply its own plain-language 25 reading to the materials and to review all documents in the light most favorable to Hernandez. Where the text of the referenced material differs from the factual allegations in the SAC, the 26 Court, as it must, considers the referenced material in full. See Lazy Y Ranch Ltd. v. Behrens, 546 F.3d 580, 588 (9th Cir. 2008) (holding that courts “need not accept as true allegations 27 contradicting documents that are referenced in the complaint.”). 1 health. Id. ¶ 27 (citing FDA Constituent Update, U.S. Food and Drug Administration (June 19, 2 2019), available at https://www.fda.gov/food/cfsan-constituent-updates/fda-announces-new- 3 qualified-health-claims-epa-and-dha-omega-3-consumption-and-risk-hypertension-and3) (last 4 accessed August 23, 2024). Specifically, the FDA stated that it would not object to the use of the 5 following qualified health claims regarding EPA and DHA Omega-3 fatty acids in food or dietary 6 supplements:

7 1. Consuming EPA and DHA combined may help lower blood pressure in the general population and reduce the risk of 8 hypertension. However, FDA has concluded that the evidence is inconsistent and inconclusive. One serving of [name of the food or 9 dietary supplement] provides [ ] gram(s) of EPA and DHA.

10 2. Consuming EPA and DHA combined may reduce blood pressure and reduce the risk of hypertension, a risk factor for CHD (coronary 11 heart disease). However, FDA has concluded that the evidence is inconsistent and inconclusive. One serving of [name of the food or 12 dietary supplement] provides [ ] gram(s) of EPA and DHA.

13 3.a. Consuming EPA and DHA combined may reduce the risk of CHD (coronary heart disease) by lowering blood pressure. However, 14 FDA has concluded that the evidence is inconsistent and inconclusive. One serving of [name of the food or dietary 15 supplement] provides [ ] gram(s) of EPA and DHA.

16 3.b. Consuming EPA and DHA combined may reduce the risk of CHD (coronary heart disease) by reducing the risk of hypertension. 17 However, FDA has concluded that the evidence is inconsistent and inconclusive. One serving of [name of the food or dietary 18 supplement] provides [ ] gram(s) of EPA and DHA.

19 4. Research shows that consuming EPA and DHA combined may be beneficial for moderating blood pressure, a risk factor for CHD 20 (coronary heart disease). However, FDA has concluded that the evidence is inconsistent and inconclusive. One serving of [name of 21 the food or dietary supplement] provides [ ] gram(s) of EPA and DHA. 22 Id. 23 Fish oil—commonly found in a variety of fatty fish, including menhaden, sardines, 24 anchovies, salmon, and tuna—is one of the main sources of Omega-3 fatty acids. Id. ¶ 30. 25 Omega-3 fatty acids, which include EPA and DHA, exist naturally in a triglyceride form and can 26 be synthetically made in an ethyl ester form. Id. ¶¶ 33, 35. Standard fish oil in the triglyceride 27 1 form is “derived using a physical, rather than a chemical process,” that is typically referred to as 2 the “wet reduction” method. Id. ¶ 32 (citing Anthony P. Bimbo, Marine Oils; Edible Oil 3 Processing, AOCS Lipid Library, December 2016, available at https://lipidlibrary.aocs.org/edible- 4 oil-processing/marine-oils) (permalink: https://perma.cc/MN7K-J5WQ) (last accessed August 23, 5 2024) (“Bimbo Article”). During this process, oil is physically pressed out of cooked fish without 6 solvent extraction, yielding unrefined fish oil in the “triglyceride form.” Id. At a molecular level, 7 fish oil in the triglyceride form contains lower concentrations of EPA and DHA compared to fish 8 oil in the ethyl ester form. Id. ¶¶ 34, 38 (citing Peter Lembke, Production Techniques for Omega- 9 3 Concentrates, in Omega-6/3 Fatty Acids. Nutrition and Health (2013), 10 https://doi.org/10.1007/978-1-62703-215-5_19) (permalink: https://perma.cc/VP2W-9XLE). 11 By contrast, a chemical process of extracting fish oil, trans-esterification, was developed in 12 the 1980’s. Id. ¶ 35. At a high-level, trans-esterification removes the glycerol backbone of EPA 13 and DHA, effectively freeing EPA and DHA molecules from the glycerol. Id.

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