In re: Dial Complete Marketing

2013 DNH 043
CourtDistrict Court, D. New Hampshire
DecidedMarch 26, 2013
DocketCase No. 11-md-2263-SM
StatusPublished

This text of 2013 DNH 043 (In re: Dial Complete Marketing) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re: Dial Complete Marketing, 2013 DNH 043 (D.N.H. 2013).

Opinion

In r e : Dial Complete Marketing 11-MD-2263-SM 3/26/13 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

In r e : Dial Complete Marketing Case N o . 11-md-2263-SM and Sales Practices Litigation Opinion N o . 2013 DNH 043

O R D E R

This consolidated, multi-district litigation is brought by

consumers in Arkansas, California, Florida, Illinois, Louisiana,

Missouri, New Hampshire, New York, Ohio, and Wisconsin, on behalf

of themselves and similarly situated consumers in those states.

Plaintiffs accuse defendant, The Dial Corporation (“Dial”), of

falsely advertising the antibacterial properties of its “Dial

Complete” branded soaps. They advance claims under their

respective state consumer protection/unfair trade practices

statutes, as well as statutory and common law causes of action

for breach of warranty and unjust enrichment. Dial moves to

dismiss all counts of plaintiffs’ Consolidated Amended Complaint,

saying none adequately pleads a viable claim. See Fed. R. Civ.

P. 12(b)(6). Plaintiffs object.

For the reasons discussed, Dial’s motion to dismiss is

denied. Standard of Review

When ruling on a motion to dismiss under Fed. R. Civ. P.

12(b)(6), the court must “accept as true all well-pleaded facts

set out in the complaint and indulge all reasonable inferences in

favor of the pleader.” SEC v . Tambone, 597 F.3d 436, 441 (1st

Cir. 2010). Although the complaint need only contain “a short

and plain statement of the claim showing that the pleader is

entitled to relief,” Fed. R. Civ. P. 8(a)(2), it must allege each

of the essential elements of a viable cause of action and

“contain sufficient factual matter, accepted as true, to state a

claim to relief that is plausible on its face.” Ashcroft v .

Iqbal, 556 U.S. 6 6 2 , 678 (2009) (citation and internal

punctuation omitted).

In other words, “a plaintiff’s obligation to provide the

‘grounds’ of his ‘entitlement to relief’ requires more than

labels and conclusions, and a formulaic recitation of the

elements of a cause of action will not do.” Bell Atl. Corp. v .

Twombly, 550 U.S. 5 4 4 , 555 (2007). The facts alleged in the

complaint must, if credited as true, be sufficient to “nudge[]

[plaintiff’s] claims across the line from conceivable to

plausible.” Id. at 570. I f , however, the “factual allegations

in the complaint are too meager, vague, or conclusory to remove

2 the possibility of relief from the realm of mere conjecture, the

complaint is open to dismissal.” Tambone, 597 F.3d at 442.

Background

Accepting the allegations set forth in the Consolidated

Amended Complaint as true, the relevant facts are as follows.

Dial manufactures, markets, and sells a line of antibacterial

hand-washing products under the name “Dial Complete.” The active

ingredient in Dial Complete is a compound known as triclosan - a

product originally patented as an herbicide and currently

registered with the Environmental Protection Agency as a

pesticide. Because of its antibacterial properties, triclosan

has been used in some soaps and other household products since

the 1960’s.

According to plaintiffs, Dial markets Dial Complete

employing numerous misleading and deceptive claims, which include

the following: that Dial Complete “kills 99.99% of germs;” that

it kills 99.9% of illness-causing bacteria; that it is “doctor

recommended;” that it “kills more germs than any other liquid

hand soap;” and that it has been “shown to help reduce disease

transmission by 50% compared to washing with a plain soap.”

Consolidated Amended Complaint (document n o . 32) at paras. 47-51.

Plaintiffs also take issue with Dial’s claim that Dial Complete

3 delivers a “100 to 1,000 fold increase in germ-killing activity

compared to washing with just plain soap and water.” Id. at

para. 6 0 .

According to plaintiffs, Dial Complete has no greater

efficacy than soaps that do not contain triclosan, and there is

no clinical support for defendant’s advertising and packaging

claims concerning the product. They say Dial’s “claims about

Dial Complete’s effectiveness and superiority are false,

deceptive, unfair, and unconscionable because there is not

sufficient, competent and/or reliable scientific evidence” to

support such claims. Id. at para. 6 9 . Plaintiffs assert that

Dial’s claims appear to be based upon a single, in-house study,

conducted at the “Dial Center for Innovation.” And, Dial’s

advertising and packaging materials fail to disclose the study’s

substantial limitations which, say plaintiffs, render the study

incomplete, unreliable, and insufficient to support Dial’s false

and deceptive claims about its Dial Complete line of products.1

1 According to plaintiffs, the study’s alleged limitations include: (a) that only two types of bacteria were tested; (b) that the study failed to determine whether repeated use of Dial Complete led to the development of immunity to the product’s antimicrobial properties; (c) that only seven to thirteen subjects participated in the study (which, plaintiffs suggest, renders the study scientifically unreliable); and (d) that the study did not compare Dial Complete with any other antibacterial soap. Id. at para. 7 4 .

4 Plaintiffs also complain that Dial’s advertising and packaging

materials for Dial Complete fail to warn consumers that using

products containing triclosan may lead to the emergence of

bacteria that are resistant to triclosan and/or other

antimicrobial agents. Id. at 7 8 .

In support of their claims, plaintiffs point to several

scientific studies, including one published in 2004 in the

American Journal of Infection Control. The authors of that study

concluded that “after testing the efficacy of fourteen different

hand hygiene agents including a hand wash with 1% triclosan,

washing with plain soap and water was more effective than

triclosan after just one wash.” Consolidated Amended Complaint

at para. 80. 2

Plaintiffs also rely on several published studies that they

say found little evidence to support the claim that “triclosan

soap affords any benefit in the reduction of infectious symptoms,

bacterial counts, or types of bacteria on the hands of

individuals within the household setting in the developed world.”

Id. at para. 8 1 . In another study, published in Clinical

2 The packaging and labeling materials submitted by the parties disclose that triclosan is present in Dial Complete at a concentration of less than one-half of one percent. See Consolidated Amended Complaint at 1 2 . See also Exhibit B to Defendant’s Motion to Dismiss (document n o . 3 6 - 4 ) .

5 Infectious Diseases, plaintiffs say researchers reviewed 27

separate studies conducted over the past 30 years and determined

that “soaps containing added ingredients such as triclosan in

liquid soap and Triclocarbon in bar soap do not show a benefit

above and beyond soap that does not contain those ingredients in

the real world environment.” Consolidated Amended Complaint at

para. 8 3 .

Additionally, plaintiffs allege that, in 2005, the U.S. Food

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