Roffman v. Perfect Bar, LLC

CourtDistrict Court, N.D. California
DecidedSeptember 2, 2022
Docket3:22-cv-02479
StatusUnknown

This text of Roffman v. Perfect Bar, LLC (Roffman v. Perfect Bar, LLC) 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
Roffman v. Perfect Bar, LLC, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MEHVA ROFFMAN, et al., Case No. 22-cv-02479-JSC

8 Plaintiffs, ORDER RE: MOTION TO DISMISS v. 9 Re: Dkt. No. 18 10 PERFECT BAR, LLC, Defendant. 11

12 13 Plaintiffs are consumers who challenge Defendant’s claims on its product labels about the 14 amount of protein they contain. (Dkt. No. 1.)1 Before the Court is Defendant’s motion to dismiss. 15 (Dkt. No. 18.) Having carefully considered the parties’ briefing, and with the benefit of oral 16 argument on August 31, 2022, the Court GRANTS the motion. 17 COMPLAINT ALLEGATIONS 18 Defendant makes claims on the front labels of its food products about the amount of 19 protein they contain. The front label of the Perfect Bar in Dark Chocolate Chip Peanut Butter 20 flavor says “15G PROTEIN,” and the front label of the Perfect Peanut Butter Cups Dark 21 Chocolate flavor says “7G PROTEIN.” (Dkt. No. 1 ¶¶ 2, 18.) Plaintiff Ms. Chong bought the 22 Perfect Bar in Dark Chocolate Chip Peanut Butter flavor at stores around the Bay Area between 23 2018 and 2022. (Id. ¶ 15.) Plaintiff Ms. Roffman bought Perfect Peanut Butter Cups in Dark 24 Chocolate and Milk Chocolate flavors at stores around the Bay Area between 2019 and 2022. (Id. 25 ¶ 59.) 26 Each Plaintiff “read[]” and “relied on” the “front labels that promised” “7G PROTEIN,” 27 1 “8G PROTEIN,” and “15G PROTEIN,” “believ[ing] . . . that the product would actually provide 2 her the specific amount of protein on the front label in a form her body could utilize as protein.” 3 (Id. ¶¶ 56, 60; see id. ¶ 2.) But “not all proteins are the same in their ability to meet human 4 nutritional requirements, so a simple statement about the number of grams does not actually 5 inform consumers about how much usable protein they are receiving.” (Id. ¶ 3.)

6 Some proteins are deficient in one or more of the nine amino acids essential to human protein synthesis and/or are not fully digestible 7 within the human gut. When a human body uses up the least prevalent essential amino acid from a food product, protein synthesis shuts 8 down and all of the remaining amino acids from that protein source degrade mostly into waste. Likewise, whatever portion of a protein 9 source is not digestible is similarly unavailable for protein synthesis. A protein’s ability to support human nutritional requirements is 10 known as its “quality.” 11 (Id.; see id. ¶¶ 25–28.) The “Protein Digestibility Corrected Amino Acid Score” (“PDCAAS”), 12 also known as the “corrected amount of protein per serving,” is a method for measuring protein 13 quality. (Id. ¶ 4.) PDCAAS “combines a protein source’s amino acid profile and its percent 14 digestibility into a discount factor ranging from 0.0 to 1.0 that, when multiplied by the total 15 protein quantity, shows how much protein in a product is actually available to support human 16 nutritional requirements.” (Id.) For example, nuts, the primary protein source in Defendant’s 17 products, have a PDCAAS score of 0.4–0.5, meaning that only 40–50% of the protein is “actually 18 available to support human protein needs.” (Id. ¶ 5.) PDCAAS can also be expressed as a percent 19 daily value, meaning “the corrected amount of protein per serving divided by the daily reference 20 value for protein of 50 grams.” (Id. ¶ 4.) For example, a product with 10 grams of protein and a 21 PDCAAS score of 0.5 would have a percent daily value of 10%: 10 grams multiplied by 0.5, 22 divided by 50 grams. (See id.) 23 Plaintiffs allege Defendant’s front-label claims, like “15G PROTEIN,” are misleading 24 because they provide only a quantitative amount without any information about protein quality. 25 They also challenge Defendant’s failure to include, in the nutrition facts panel on the back of its 26 products, information about protein quality in the form of a percent daily value. (See id. ¶ 19.) 27 Defendant’s protein claims caused Plaintiffs “to pay a price premium for the products.” (Id. ¶ 7.) 1 a very minimum, [they] would have paid less.” (Id. ¶¶ 57–58, 61–63.) 2 Plaintiffs filed suit on behalf of a nationwide class and California subclass. (Id. ¶ 64.) 3 They bring claims under California law for violations of the Consumers Legal Remedies Act 4 (“CLRA”), False Advertising Law (“FAL”), and Unfair Competition Law (“UCL”); fraud; and 5 unjust enrichment. Plaintiffs disclaim any causes of action under the Federal Food, Drug, and 6 Cosmetic Act (“FDCA”) and its regulations, relying on them only to the extent they are also 7 enacted under state law or provide a predicate for liability under state law. (See id. at 21.) 8 DISCUSSION 9 Plaintiffs have three theories of liability. Defendant argues that each theory is expressly or 10 impliedly preempted by the FDCA, and that Plaintiffs do not sufficiently allege reliance on the 11 product labels. 12 I. Are the Front-Label Protein Claims Unlawful Without Corresponding Figures on the 13 Nutrition Facts Panel? 14 Plaintiffs’ first theory is that Defendant’s front-label protein claims do not comply with 21 15 C.F.R. §§ 101.9(c)(7)(i) and 101.13(n), Food and Drug Administration (“FDA”) regulations 16 implementing the FDCA. These allegations serve as a predicate for violating California laws, 17 including the Sherman Law, which in turn serve as a predicate for violating the “unlawful” prong 18 of the UCL. (Dkt. No. 20 at 12–13; Dkt. No. 1 ¶¶ 100–01); see Morgan v. Wallaby Yogurt Co., 19 Inc., No. 13-cv-00296-WHO, 2013 WL 5514563, at *5 (N.D. Cal. Oct. 4, 2013) (noting that 20 California’s Sherman Law incorporates the FDCA and can form the basis for a UCL unlawful 21 prong claim). 22 A. Express Preemption 23 The FDCA, as amended, expressly preempts state claims that are “not identical to” its own 24 requirements. 21 U.S.C. § 343-1(a); see Hawkins v. Kroger Co., 906 F.3d 763, 769–70 (9th Cir. 25 2018); Reid v. Johnson & Johnson, 780 F.3d 952, 959–60 (9th Cir. 2015). Thus, if the FDCA or 26 FDA regulations do not prohibit Defendant’s conduct as alleged in the complaint, then Plaintiffs’ 27 state law claims are expressly preempted. See Hawkins, 906 F.3d at 769–70; see also Durnford v. 1 same preemptive effect as a statute”); Gitson v. Trader Joe’s Co., No. 13-1333, 2015 WL 2 9121232, at *1 (N.D. Cal. Dec. 1, 2015) (“[W]hen it comes to food labels, state law may only 3 impose liability for what the federal statute proscribes.”). 4 Section 101.9 regulates the information that appears in the nutrition facts panel on the back 5 or side of a food product’s packaging. With respect to protein:

6 (c) The declaration of nutrition information on the label and in labeling of a food shall contain information about the level of the 7 following nutrients . . .

8 (7) “Protein”: A statement of the number of grams of protein in a serving, expressed to the nearest gram . . . . Protein content may be 9 calculated on the basis of the factor 6.25 times the nitrogen content of the food . . . . 10 (i) A statement of the corrected amount of protein per serving, as 11 determined in paragraph (c)(7)(ii) of this section, . . . expressed as Percent of Daily Value, may be placed on the label, except that such 12 a statement shall be given if a protein claim is made for the product . . . . When such a declaration is provided, it should be placed on the 13 label adjacent to the statement of grams of protein and aligned under the column headed “Percent Daily Value,” and expressed to the 14 nearest whole percent. 15 21 C.F.R.

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Roffman v. Perfect Bar, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roffman-v-perfect-bar-llc-cand-2022.