Lopez v. Abbott Laboratories

District Court, S.D. California·Decided March 27, 2023·No. 3:22-cv-00421·Unknown

Opinion

Case No. 3:22-cv-00421-L-RBB ROCIO LOPEZ, Plaintiff, ORDER DENYING DEFENDANT’S v. MOTION TO DISMISS ABBOTT LABORATORIES, [ECF No. 15] Defendant.

Pending before the Court is Defendant’s motion to dismiss this false advertising action for failure to state a claim. Plaintiff filed an opposition and Defendant replied. For the reasons which follow, Defendant’s motion is denied. I. Background Defendant sells baby and toddler food under brand names Similac and PediaSure. The products prominently display a label stating that they are “Non-GMO” with an asterisk to the statement “Ingredients not genetically engineered.” Plaintiff alleges that this representation is false with or without the language in the asterisk because the products in fact contain GMO ingredients. She further alleges that she and other consumers purchased Defendant’s products at a premium in reliance on the representations made on the label. The operative first amended complaint (ECF no. 11, “Compl.”), includes detailed allegations describing Defendant’s products and ingredients, product labeling, and explains why the labels are deceptive. Plaintiff alleges violation of California Unfair Competition Law, Cal. Bus. & Prof. Code §§ 17200 et seq. (“UCL”); violation of California False Advertising Law, id. §§ 17500 et seq. (“FAL”); violation of California Consumers Legal Remedies Act, Cal. Civ. Code §§ 1750 et seq. (“CLRA”); breach of express warranty; breach of the implied warranty of merchantability; unjust enrichment/restitution; negligent misrepresentation; fraud; and fraudulent misrepresentation. She alleges California statutory violations on behalf of a putative subclass of California consumers. The remaining claims are alleged on behalf of a putative nationwide class of consumers, including California subclass. Plaintiff seeks damages, restitution or other monetary equitable relief, as well as declaratory and injunctive relief. The Court has federal jurisdiction under the Class Action Fairness Act, 28 U.S.C. § 1332(d). II. Discussion In its Rule 12(b)(6)1 motion to dismiss Defendant contends that Plaintiff failed to sufficiently allege any of her claims. A motion under Rule 12(b)(6) tests the sufficiency of the complaint. Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). Dismissal is warranted where the complaint lacks a cognizable legal theory. Shroyer v. New Cingular Wireless Serv., Inc., 622 F.3d 1035, 1041 (9th Cir. 2010). Alternatively, a complaint may be dismissed if it presents a cognizable legal theory yet fails to plead essential facts under that theory. Robertson v. Dean Witter Reynolds, Inc., 749 F.2d 530, 534 (9th Cir. 1984). Generally, to plead essential facts a plaintiff must allege only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. Proc. 8(a)(2); see also Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). The plaintiff must "plead[] factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Plaintiff’s allegations must provide “fair notice” of the

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