Silver v. BA Sports Nutrition, LLC

CourtDistrict Court, N.D. California
DecidedApril 29, 2022
Docket3:20-cv-00633
StatusUnknown

This text of Silver v. BA Sports Nutrition, LLC (Silver v. BA Sports Nutrition, 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
Silver v. BA Sports Nutrition, LLC, (N.D. Cal. 2022).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 6 MARC SILVER, et al., Case No. 20-cv-00633-SI

7 Plaintiffs, ORDER RE: DEFENDANT’S MOTION 8 v. FOR SUMMARY JUDGMENT

9 BA SPORTS NUTRITION, LLC, Re: Dkt. No. 139 10 Defendant.

11 12 On December 17, 2021, the Court held a hearing on defendant’s motion for summary 13 judgment. For the reasons set forth below, the motion is GRANTED IN PART and DENIED IN 14 PART. 15 16 BACKGROUND 17 I. Procedural History 18 Plaintiffs filed this lawsuit in January 2020. Defendant BA Sports Nutrition, LLC (“BA 19 Sports”) is a sports drink company that produces and sells BodyArmor SuperDrink sports drinks 20 (“BodyArmor”) with flavors such as Banana Strawberry, Blackout Berry, Fruit Punch, Orange 21 Mango and Grape. BA Sports advertises that BodyArmor provides “superior hydration,” and the 22 drink labels contain the words “SUPERIOR HYDRATION,” as well as images of fruits, the words 23 “natural flavors and sweeteners,” and advertise that the drinks contain “electrolytes,” “antioxidants,” 24 and various vitamins. 25 A copy of an “exemplar” product label is reproduced below:1 26

27 1 The Court previously took judicial notice of this copy of the front and back of an 1 2 3 □□□ □ : , ; : □ 4 ee West) 0:11) ae | eb toutes Br □□□ a

6 alia NATURAL |\_ ae oy) 2 ce ay, eciaies 7 Bo255 2 aN 10% Coconut Water Pee (@) NO (eo * (Nutrition Facts S255 = rere af ed Serving size 1 Bottle 8 nice a Re ELECTROLYTES: i. i 2 ae Ho tog 22 Oh Ravesiones 120 9 eteel J | earrare □□□ els > be) By sntrecee® i? Ser □□ 10 a) am fone 5 | □ □ 11 Se i Lista □□ □ —_—_ Fa | BODYARMOR rs = a □□ ——= Natural Flavors Natural = □□ eres 3 13 —Ss — 5 ‘Sweeteners & No Colors — (age) □□□□ — eeke | Geto =| Seem | rice). 5 14 210406.012 □ f Antioxidants & Vitamins J { □□□ ‘OR: REFRIGERATE ~*~ peas see Hydration. "al BA □□□□□ □□□□□□□□□ Lie © AFTEROPINING ees ie □□□ □□□□ “HbSe. CRADe ei © 46FL0z @DRINKBODYARMOR 2 | □□□□□ = 15 ol a (200 □ &) Ci □□□□□ 16 Plaintiffs Mare Silver and Alexander Hill are “sports enthusiasts” who purchased and 17 □□□ . . . consumed BodyArmor believing that the drinks were healthy and would benefit their workouts as 4 18 compared to other sports drinks. The focus of the original complaint was “superior hydration” and 19 the theory that BodyArmor was a “dressed-up soda masquerading as a health drink.” Compl. § 12. 20 The complaint did not contain any allegations that plaintiffs were deceived by the labels’ fruit 21 imagery or that they believed “natural flavors” referred to fruit flavors. 22 In an order filed June 4, 2020, the Court dismissed the original complaint with leave to 23 amend. Dkt. No. 40. The Court found that the allegations about “superior hydration” amounted to 24 inactionable puffery because “[p]roduct superiority claims that are vague or highly subjective often 25 amount to nonactionable puffery,” while “[a] specific and measurable claim of product superiority 26 based on product testing is not puffery.” Southland Sod Farms v. Stover Seed Co., 108 F.3d 1134, 27 1145 (9th Cir. 1997). The Court also held that the plaintiffs’ claims that they were misled about 28

1 BodyArmor’s healthiness were implausible because they were based on puffery (“superior 2 hydration”) and because BodyArmor’s label truthfully stated its sugar content, including listing 3 sugar as the second ingredient and accurately stating the amount of sugar in each bottle. 4 On July 7, 2020, plaintiffs filed an amended complaint that included new allegations that 5 plaintiffs were misled by the fruit-based labeling of the drinks and that the drinks did not contain 6 any fruit juice. Plaintiffs also expanded on the allegations that plaintiffs were misled by the labeling 7 to believe that the sports drinks provided health benefits, including adding new allegations that 8 plaintiffs understood hydration to be an objective and measurable attribute. The Court denied 9 defendant’s motion to dismiss the amended complaint, finding that “viewed holistically,” plaintiffs 10 had stated a claim. 11 After defendant filed the instant motion for summary judgment, plaintiffs filed an opposition 12 stating, inter alia, that they required certain outstanding discovery in order to fully oppose the 13 motion. The Court continued the summary judgment hearing to allow for the additional discovery, 14 and allowed the parties to file supplemental briefs based upon that discovery. Dkt. No. 145. The 15 parties then filed supplemental briefs; plaintiffs stated that, while they still required certain 16 discovery for the case writ large, they did not actually need any outstanding discovery in order to 17 oppose defendant’s motion. Dkt. No. 148. 18 19 II. The First Amended Complaint 20 The first amended complaint (“FAC”) alleges that Silver and Hill perceived hydration to be 21 “an objective and variable attribute,” FAC ¶ 53, that Silver and Hill understood BodyArmor’s 22 labeling claims “to mean that BodyArmor’s capacity for superior hydration was objective and 23 variable in degree and/or measure, and that BA conveyed as much to them intentionally and 24 honestly, justifying the purchase and price premium.” Id. ¶ 65. Silver and Hill “also understood 25 BA’s labeling claims to imply that BodyArmor was good for their bodies and health overall” 26 because of the “superior hydration claims, and/or from the prominent labeling of BodyArmor’s high 27 vitamin and purported fruit contents.” Id. ¶ 71. Plaintiffs allege that in fact, BodyArmor is a sugar- 1 Plaintiffs did not understand existed given BA’s labeling claims.” Id. ¶¶ 75-76. Silver and Hill 2 “have a favorable view of fruits, believing that natural fruits and fruit juices benefit their health,” 3 and they believed that BodyArmor contained real fruit because of the names of the drinks, the 4 images of fruit on the labels, and/or the natural ingredients claim. Id. ¶¶ 85-86. Plaintiffs would 5 not have purchased BodyArmor had they understood that the drinks contained very little, if any, of 6 the labeled fruits as ingredients. Id. ¶ 92. 7 The FAC also alleges that Hill saw BodyArmor’s non-label advertising in stores, on 8 billboards, television ads, and on social media. Id. ¶¶ 95-100. Hill saw this advertising and 9 “understood that BodyArmor was superior at hydrating as compared to other sports drinks, including 10 but not limited to Gatorade, and/or that such superior hydration would translate into correspondingly 11 better workouts and related physical effects.” Id. ¶ 99. 12 Silver and Hill seek to represent a nationwide class and several state subclasses. Silver 13 asserts causes of action under the following California consumer protection statutes: (1) the Unfair 14 Competition Law (“UCL”), Cal. Bus. & Prof. Code § 17200, et seq., for unlawful business practices; 15 (2) the UCL for unfair and fraudulent business practices; (3) the False Advertising Law (“FAL”), 16 Cal. Bus. & Prof. Code § 17500, et seq., for misleading and deceptive advertising; and (4) the 17 Consumer Legal Remedies Act (“CLRA”), Cal. Civ. Code § 1750, et seq., for deceptive practices 18 in connection with the sale of misbranded products and misrepresentations regarding those products. 19 Hill alleges two causes of action under New York’s Consumer Protection from Deceptive Acts and 20 Practices Law, N.Y. Gen. Bus. Law §§ 349-350, for deceptive labeling and marketing and false 21 advertising. Both plaintiffs allege a claim for unjust enrichment/quasi-contract.2 22 23 III. Plaintiffs’ Depositions 24 A.

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Silver v. BA Sports Nutrition, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/silver-v-ba-sports-nutrition-llc-cand-2022.