McWhorter v. The Procter & Gamble Company

CourtDistrict Court, N.D. California
DecidedMarch 28, 2025
Docket3:24-cv-00806
StatusUnknown

This text of McWhorter v. The Procter & Gamble Company (McWhorter v. The Procter & Gamble Company) 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
McWhorter v. The Procter & Gamble Company, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 LORAINE MCWHORTER, et al., Case No. 24-cv-00806-AMO

8 Plaintiffs, ORDER GRANTING DEFENDANT’S 9 v. MOTION TO DISMISS

10 THE PROCTER & GAMBLE COMPANY, Re: Dkt. No. 17 Defendant. 11

12 13 Defendant The Procter & Gamble Company’s (“P&G”) motion to dismiss was heard 14 before this Court on November 7, 2024. Having read the papers filed by the parties and carefully 15 considered their arguments therein and those made at the hearing, as well as the relevant legal 16 authority, the Court hereby GRANTS P&G’s motion, for the following reasons. 17 I. BACKGROUND 18 This case arises from P&G’s advertising statements that certain of its shampoos and 19 conditioners are comprised of specific proportions of “natural origin ingredients” (e.g., “90% 20 Natural Origin* ingredients”) or “naturally-derived ingredients (e.g., “97% Naturally Derived** 21 Ingredients”). Compl. ¶ 2. 22 A. P&G’s Pantene and Herbal Essences Shampoos and Conditioners 23 The challenged products include, but are not limited to, shampoos and conditioners P&G 24 sells under three brand names: Herbal Essences “Real Botanicals,” Herbal Essences “Certified 25 PurePlants,” and Pantene “Essential Botanicals.” Compl. ¶¶ 2, 28. The front label of each 26 Pantene and Herbal Essences product at issue in this case (the “Products”) state that a certain 27 percentage of the product is made from “naturally derived ingredients” or is of “natural origin.” 1 every shampoo and conditioner bearing Natural Origin Claims includes text that provides P&G’s 2 definition of “naturally derived” or “natural origin.” Id. Plaintiffs’ claims all rely on the Products’ 3 labeling, and the Complaint and Appendix extensively quote and include images of the Products’ 4 front and back labels. 5 There are generally three different ways in which the Natural Origin Claims are presented 6 to consumers. First, the front label of Pantene Apricot & Shea Butter Conditioner and similar 7 products states “96% Naturally Derived** Ingredients.” Compl. App’x B at 59. The back label 8 explains what P&G means by the front-label statement: “**Natural source ingredients with limited 9 processing and purified water create this 96% natural origin shampoo. After processing, natural 10 source ingredients maintain ≥ 50% of their natural origin material.” Compl. ¶¶ 44-45. Asterisks 11 connect the claim and explanatory text. Other Pantene Products have the same type of labeling. 12 See Compl. App’x B at 58-61. 13 Second, the front label of Herbal Essences Argan Oil Shampoo and other products like it 14 includes the phrase “90% Natural Origin.” Compl. ¶ 34. The back label includes the same phrase: 15 “90% Natural Origin*.” Directly below on the back label, P&G explains what it means by 16 “% natural origin”: “*Natural source ingredients with limited processing and purified water. After 17 processing, natural source ingredients maintain ≥ 50% of their natural origin material.” Compl. 18 ¶¶ 36-37. Again, the asterisks connect the claim and its explanatory text. Certain other versions 19 of Herbal Essences products, such as the White Grapefruit & Mint Shampoo and the Coconut Oil 20 Conditioner, have similar labels. See Compl. App’x B at 48, 54. 21 Third and finally, the front label of Herbal Essences White Grapefruit & Mint Conditioner 22 also says “90% Natural Origin.” Compl. App’x B at 48. The back label incorporates the 23 explanation of what “90% natural origin” means into the product description at the top of the 24 label: “Since 1971, we’ve believed in bringing the beauty & experience of nature to your hair. 25 Now we’ve partnered with Royal Botanical Gardens, KEW, to endorse our real botanicals. It is 26 combined with natural source ingredient materials with limited processing & purified water to 27 create this 90% natural origin conditioner.” Compl. ¶ 38 & App’x B at 48. Other Herbal Essences 1 Products, such as the Coconut Milk Shampoo and Conditioner and the Golden Moringa Oil 2 Shampoo and Conditioner, have similar labels. See Compl. App’x B at 46, 47, 49, 50, 52, 53. 3 B. Plaintiffs’ Allegations 4 Plaintiff Loraine McWhorter purchased Herbal Essences Argan Oil Shampoo and Herbal 5 Essences White Charcoal Conditioner from a Walmart “beginning in November 2022.” Compl. 6 ¶ 83. Plaintiff Sameer Sharma purchased Pantene Apricot & Aloe Vera Shampoo and Conditioner 7 from a Walmart around November 11, 2023. Compl. ¶ 88. Plaintiffs assert that, contrary to 8 P&G’s statements, aside from water, natural oils, and natural fragrances, none of the ingredients 9 are “natural source ingredients,” nor made or derived using “limited processing.” Compl. ¶¶ 51- 10 56. By defining “natural source ingredients” as those which “maintain ≥50% of their natural 11 origin material” after processing, P&G obfuscates the fact that these “natural source ingredients” 12 are actually man-made chemicals, synthesized using industrial chemical processes. Compl. ¶¶ 52- 13 82. Neither Plaintiff appears to have read the explanations of the Natural Origin Claims that 14 appear on each product they purchased: McWhorter does not mention the explanations at all, see 15 Compl. ¶¶ 83-87, while Sharma alleges that he “overlooked the asterisks and associated statement 16 due to their small size,” id., ¶ 91. Plaintiffs do not allege that they performed any analysis or 17 testing of the Products before filing their Complaint. 18 Plaintiffs advance that the Products’ labels mislead consumers in several different ways. 19 First, Plaintiffs claim that they understood the Natural Origin Claims to mean “that the product 20 was comprised of ingredients of which [90 or 96]% were natural origin.” Compl. ¶¶ 84, 89. This 21 theory is based solely on the number of ingredients in each product. If a given shampoo is 22 represented to be 96% natural origin and lists 20 ingredients, for example, Plaintiffs contend a 23 reasonable consumer would believe that at least 19 of the ingredients were natural origin, no 24 matter how much of each ingredient is present in the product. Plaintiffs allege they would not 25 26 27 1 have purchased or would have paid less for the Products had P&G “adequately disclosed the 2 number of ingredients that were naturally derived.” Compl. ¶¶ 85, 90.1 3 Second, Plaintiffs assert that if the Natural Origin Claims are instead based on the 4 composition of each product as a whole by weight, the claims are literally false if water is 5 excluded from the analysis, because in that case “over 90% of the ingredients in the Products are 6 not natural and do not originate in nature; rather, they are of industrial-origin.” Compl. ¶ 5. 7 Third, they allege that a consumer may interpret the Product labels to state that a certain 8 percentage of the Products were “extracted directly from plants” or “exclude industrial chemical 9 modifications,” both of which would still render the natural origin percentage statements false. 10 Compl. ¶¶ 9, 55. 11 Finally, Plaintiffs allege “upon information and belief” that even if the Natural Origin 12 Claims are based on composition by weight and water is included, “the claim is not true.” Compl. 13 ¶¶ 5, 57. 14 Based on these allegations, Plaintiffs bring a putative class action in which they seek to 15 represent the following class: “All persons in [sic] who purchased, in the State of California, the 16 Products from February 9, 2024 to the present.” Compl. ¶ 93. Although the Complaint makes 17 passing references to a subclass, it does not define one. See Compl. ¶¶ 93-99. The Complaint 18 seeks relief under the Consumers Legal Remedies Act (“CLRA”); Unfair Competition Law 19 (“UCL”); False Advertising Law (“FAL”); common law fraud, deceit, and/or misrepresentation; 20 and negligent misrepresentation. Compl. ¶¶ 101-150. 21 II. DISCUSSION 22 P&G moves to dismiss on two Rule 12 bases: failure to state a claim and lack of standing.

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