In the latest false advertising decision regarding malic acid (see prior Inside Class Actions coverage here, here, and here), the Southern District of California dismissed with prejudice a plaintiff’s claim that defendant falsely advertised that its licorice was “naturally flavored” because testing allegedly showed that the product may contain synthetic malic acid.

In Trammell v. KLN Enterprises, Inc., 2024 WL 4194794 (S.D. Cal. Sept. 12, 2024), the plaintiff alleged that defendant Wiley Wallaby falsely advertised that its Very Berry Licorice candy is “Natural Strawberry & Raspberry Flavored Licorice,” “Naturally Flavored,” and “Free of … Artificial Colors & Flavors.”  Plaintiff’s amended complaint alleged that third-party testing revealed that the “D isomer was present in the Product purchased by Plaintiff.”  This was sufficient, plaintiff asserted, to state a claim that the candy used synthetic rather than natural malic acid—and that defendant’s licorice was thus deceptively advertised as “all natural.”

The court rejected plaintiff’s claims on several grounds.  First, the court held that plaintiff did not allege fraud with sufficient particularity: plaintiff’s alleged testing only showed the possibility that the malic acid was synthetic, and did not otherwise describe the methodology or other details about the alleged testing.  The court also observed that allegations as to defendant’s “economic incentives” to use artificial malic acid or “common industry practice” did not suffice either.  Without specific allegations showing that the licorice’s malic acid was artificial, plaintiff’s fraud claims failed. 

Second, the court held that even if plaintiff could allege fraud with particularity, his allegations failed the reasonable consumer standard.  According to the court, the public was not likely to be deceived by defendant’s packaging: “nothing about this product—a brightly colored, shelf-stable licorice candy—would lead a reasonable consumer to conclude that Wiley Wallaby Very Berry Licorice is free of artificial ingredients when the product labels make no affirmative representations saying as such.”

Third, the court denied plaintiff’s request for injunctive relief for lack of standing.  Plaintiff did not sufficiently allege that he intended to buy defendant’s licorice again, and now that his testing revealed the possibility that the licorice contained synthetic malic acid, “there is no longer any risk that Plaintiff will be misled the next time he looks at a Wiley Wallaby Very Berry Licorice label.”

The use of allegedly artificial malic and citric acid remains a focus for the plaintiffs’ bar, but this is the latest in a string of helpful decisions holding plaintiffs to their burden to plead their claims with specificity and/or rejecting the premise of these claims outright.    

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Photo of Stephen Rees Stephen Rees

Stephen Rees is a litigation associate in the firm’s Washington, DC office. He has handled matters involving a range of issues, including class actions, antitrust, product liability, ERISA, insurance, breach of contract, and tort claims.

Stephen has experience in all stages of litigation…

Stephen Rees is a litigation associate in the firm’s Washington, DC office. He has handled matters involving a range of issues, including class actions, antitrust, product liability, ERISA, insurance, breach of contract, and tort claims.

Stephen has experience in all stages of litigation, including:

  • dispositive motions;
  • fact and expert discovery;
  • class certification;
  • summary judgment;
  • mediation;
  • arbitration; and
  • trial preparation

Stephen has first-chaired fact witness depositions, drafted dispositive motions in both federal and state court, and argued hearings in federal court. In addition, he maintains an active pro bono practice, with an emphasis on immigration-related impact litigation and criminal law matters.

Photo of Cort Lannin Cort Lannin

Cortlin Lannin is a litigator who defends clients in high-stakes antitrust and consumer matters. Described by Chambers USA as “smart, detail-oriented and thorough,” Cort has a depth of experience helping his clients successfully navigate the entire lifespan of these matters, from leading internal…

Cortlin Lannin is a litigator who defends clients in high-stakes antitrust and consumer matters. Described by Chambers USA as “smart, detail-oriented and thorough,” Cort has a depth of experience helping his clients successfully navigate the entire lifespan of these matters, from leading internal investigations to defending government investigations and the class action litigation that routinely follows.

Cort is co-chair of the firm’s global Cartel Defense and Government Investigations practice group and represents companies and individuals facing criminal and civil antitrust investigations, including before the DOJ Antitrust Division and FTC. Cort is also an experienced class action litigator and has defended his clients in cases implicating the high-tech industry, alleged “no-poach” and wage-fixing agreements, price-fixing, and similar conduct. Cort has been recognized as a Top Antitrust Lawyer by the Daily Journal.

Cort has also defended some of the world’s largest consumer-facing companies in class action litigation across courts nationwide. This includes cases alleging false advertising and unfair trade practices under California’s UCL, FAL, and CLRA, and other states’ laws. He is experienced at heading off cases before any complaint is filed and, if necessary, efficiently defeating complaints.

Cort is a co-chair of Covington’s CovPride Resource Group and is deeply involved in the firm’s efforts to recruit, mentor, and promote diverse attorneys. He also maintains an active pro bono practice and is currently leading a team working to preserve transgender adolescents’ access to gender-affirming care.