Mccausland v. PepsiCo, Inc.

CourtDistrict Court, N.D. California
DecidedAugust 14, 2024
Docket5:23-cv-04526
StatusUnknown

This text of Mccausland v. PepsiCo, Inc. (Mccausland v. PepsiCo, Inc.) 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
Mccausland v. PepsiCo, Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 IAN MCCAUSLAND, et al., Case No. 23-cv-04526-PCP

8 Plaintiffs, ORDER GRANTING MOTION TO 9 v. DISMISS IN PART

10 PEPSICO, INC., Re: Dkt. No. 18 Defendant. 11

12 13 In this lawsuit, plaintiffs Ian McCausland, Carlo Garcia, and Michael Zurl allege that 14 PepsiCo, Inc. deceptively advertises that its Gatorade Protein Bars promote consumers’ fitness, 15 health, athleticism, and well-being when they in fact contain high levels of total and added sugars 16 that render such claims misleading. Plaintiffs further contend that Gatorade’s labeling of the bars 17 as “Protein Bars” is deceptive or misleading because, in truth, the bars’ primary ingredient is 18 sugar. 19 PepsiCo now moves to dismiss plaintiffs’ complaint under Rules 12(b)(1) and 12(b)(6). 20 For the following reasons, PepsiCo’s motion is granted in part and denied in part. 21 Background 22 Plaintiff Ian Mccausland is a self-proclaimed fitness enthusiast and resident of San Jose, 23 California who purchased Gatorade Protein Bars in California and on Amazon.com in 2022 and 24 2023. Compl. ¶¶ 20–22.1 Plaintiff Michael Zurl is a self-proclaimed fitness enthusiast and resident 25 of Remsenburg, New York who purchased Gatorade Protein Bars in New York and on 26 Amazon.com in 2020, 2021, and 2022. Id. ¶¶ 31–33. Plaintiff Carlo Garcia is a self-proclaimed 27 f1i tness enthusiast and resident of Sanger, California who purchased Gatorade Protein Bars in C2 alifornia and on Amazon.com in 2020. Id. ¶¶ 42–44. 3 Each plaintiff alleges that the label on the Gatorade Protein Bars he bought “touted claims o4f and/or equivalent to ‘PROTEIN BAR’ in large, bolded letters, ‘20 g of Protein,’ and contained l5o gos for the NFL, NBA, WNBA, and MLB sports leagues, and the side labels in oversized bolded a6n d capitalized letters, stated ‘PROTEIN TO HELP MUSCLES REBUILD.’” Compl. ¶¶ 23, 34, 475 . Relying on those statements, similar claims on the Amazon.com landing page for the product, a8n d trust in the Gatorade brand, each plaintiff “believed that consuming Gatorade Protein Bars w9 ould be a clear benefit to his muscles and athleticism” and not “a Product with excessive total a1nd/or added sugars.” Id. ¶¶ 24–26, 35–37, 46–48. No plaintiff was familiar with “how many 0 grams of sugar are in a teaspoon,” “what limits on added sugar daily intake the health authorities r1ecommend,” or the negative health consequences of regularly consuming high-sugar protein bars. 1 Id. ¶¶ 27, 39, 49. 1 Plaintiffs allege that “PepsiCo’s Gatorade Protein Bar marketing is deceptive, misleading, 2 and unlawful, because both individually and collectively the health halo marketing claims, i1ncluding the Product name, imply that the Product is a fitness enhancer and/or healthful Product 3 that promotes athleticism and well-being when, in fact, it contains high levels of total and added s1ugars.” Compl. ¶ 54. According to plaintiffs, “marketing the inclusion of protein as a nutrient in 4 products appeals to consumers and exponentially increases sales,” leading consumers to “1mistakenly perceive that adding more protein to their diet is important to health and well-being.” 5 Id. ¶¶ 56–57. They contend that PepsiCo “capitalizes on this fraudulent advertising trend—with i1ntensive and misleading marketing about the purported benefits of protein and/or the advantages 6 of consuming its protein-fortified Product to enhance general fitness, athleticism and impliedly, o1verall well-being and/or health—all notwithstanding its high sugar content.” Id. ¶ 58. 7 Plaintiffs allege that sugar, not protein, is the Gatorade Protein Bar’s primary c1haracterizing ingredient. Consequently, they contend that PepsiCo’s use of the word “protein” in 8 the product’s name and its claims highlighting the protein content and promoting its effect on o1f the product, including on Amazon.com, similarly “trumpets the Product’s protein content and t2h e purported scientific substantiation for the Product’s health benefits (including enhanced a3t hleticism and overall well-being),” in claims including “‘Backed by Science,’ ‘Gatorade Sports S4 cience Institute,’ and ‘Used by the Pros,’ along with logos for and claims of use by the NFL, M5 BL, NBA, and MNBA.” Id. ¶ 61. Similarly, they allege that PepsiCo’s reference to science and s6p ecifically the Gatorade Sports Science Institute (e.g., “Formulated and tested at the Gatorade S7 ports Science Institute”) works to deceive consumers into thinking that the institute’s work is a8i med at promoting health and athletic performance. See id. ¶¶ 62–64. 9 Plaintiffs allege that a “single serving of the Product—one Gatorade Protein Bar—exceeds t1he daily, health-based limits for added sugars recommended by the AHA for women and youth, 0 and approaches it for men.” Compl. ¶ 87. Plaintiffs contend that consumers are unaware of this f1act because PepsiCo fails to clearly state the percentage of recommended daily limit 1 (Recommended Daily Value or %DV) of sugar for the Product the way it does for fat and sodium. I1d. ¶ 64. PepsiCo also does not state “by way of teaspoons the added sugars content” on the 2 principal display pane (PDP). According to plaintiffs, “[a]verage consumers, as is the case with t1he Plaintiffs, who trust Gatorade and its marketing, are not sufficiently nutritionally literate, or 3 sophisticated scientifically, to comprehend that the amount of added sugars in the Product is high a1nd/or excessive, and/or to understand that the leading health authorities advise against the 4 consumption of added sugars at such levels given links to disease—particularly when presented w1ith Gatorade/PepsiCo’s health halo marketing about protein levels and the Product overall.” Id. 5 ¶ 68. Plaintiffs allege that PepsiCo’s deceptive marketing occurs in the wake of widespread and h1igh rates of obesity, diabetes, and cardiovascular disease correlated with the consumption of 6 processed foods and excessive amounts of added sugars, often hidden or unrecognized, across the c1ountry. By contrast, according to plaintiffs, there is little evidence of protein deficiency among 7 Americans. See id. ¶¶ 70–84. 1 Plaintiffs allege that they would not have purchased the bars, would have purchased fewer 8 bars, or would have paid a lower price for the bars had they understand the nutritional character of m1 arketing.” Id. ¶¶ 28–29, 39–40, 50–51. Each plaintiff alleges that he would “consider purchasing t2h e Product again were it marketed in a non-misleading and lawful manner such that he could trust t3h e marketing claims.” Id. ¶¶ 30, 41, 52. 4 In their complaint, plaintiffs allege that PepsiCo’s conduct violates multiple federal and s5t ate statutory provisions, official policies, and regulations targeting deceptive marketing. New Y6 ork and California both prohibit deceptive business practices and false advertising and i7n corporate parallel federal principles or provisions into their consumer protection statutes. Compl. ¶8¶ 88–89. In New York, this includes its General Business Law Sections 349 and 350. In C9 alifornia, this includes its Unfair Competition Law, California Business and Professions Code §1 17200 et seq. (“UCL”); its Consumer Legal Remedies Act, California Civil Code § 1750 et seq. 0 (“CLRA”); and its False Advertising Law, California Business and Professions Code § 17500 (1“FAL”). Id. ¶ 89. 1 In support of their claims, plaintiffs also point to several provisions of federal law. Section 3143 of the federal Food, Drug, and Cosmetic Act (“FDCA”) provides that food is “misbranded … 2 (a) if (1) its labeling is false or misleading in any particular.” 21 U.S.C. § 343(a).

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Mccausland v. PepsiCo, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccausland-v-pepsico-inc-cand-2024.