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Husch Blackwell LLP

FTC to Sellers: Time to Knock Off the “Made in the USA” Knock-Offs

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If you have shopped online lately, odds are you saw products proudly advertising themselves as “Made in the USA.” Maybe it was a flag, a pair of boots, or a kitchen gadget. But how often is that label actually true? According...more

White & Case LLP

Eight key aspects to know about the EU Ecodesign for Sustainable Products Regulation

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The new Ecodesign for Sustainable Products Regulation1 ("ESPR"), which entered into force on 18 July 2024, is set to significantly reshape the regulatory landscape for companies operating in the European Union ("EU"). As part...more

Mintz

Can a Consumer Plausibly Allege Your Product Labeling is False or Misleading Under California Law?

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California’s consumer protection laws prohibit false advertising, as well as advertising that is “‘either actually misleading or which has a capacity, likelihood, or tendency to deceive or confuse the public.’” These claims...more

Kilpatrick

Ninth Circuit affirms dismissal of false advertising claim against Mars subsidiary based on reasonable consumer test

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The Ninth Circuit recently upheld the dismissal of a putative class action finding that labeling Dove Dark Chocolate products as deriving from a “Rainforest Alliance Certified™ farm” did not mislead reasonable chocolate...more

Maynard Nexsen

FTC Announces Largest Ever Civil Penalty for Made in USA Labelling Violation

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On April 26, 2024, the FTC announced the largest ever civil penalty for the improper labelling of products as “Made in USA.” The FTC announced that Williams Sonoma will pay a record civil penalty of $3.17 million for...more

Kilpatrick

Fine print prevails: Second Circuit affirms dismissal of deceptive business act claims against Stanley Black & Decker

Kilpatrick on

Takeaway:  Is a label clearly false or only ambiguously false?  Where a label is ambiguous – and therefore subject to an interpretation that would render it deceptive – the ambiguity can be clarified by fine print.  The fine...more

Venable LLP

FTC Issues Record-Breaking Civil Penalty in “Made in USA” Case

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Tractor maker Kubota North America Corporation will pay a $2 million civil penalty for falsely labeling its replacement parts as “Made in USA,” the largest civil penalty ever in a Federal Trade Commission (FTC) Made in USA...more

BCLP

PFAS litigation update: The risks of consumer product marketing claims

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As general awareness of per- and polyfluoroalkyl substances (“PFAS”) has continued to rise in recent years, courts have experienced an increase in civil lawsuits alleging false and misleading advertising in corporate...more

BakerHostetler

The FTC’s Latest Made in the USA Case Is a Reminder of the Different Ways the Agency Can Still Get Money Post-AMG

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The latest Federal Trade Commission (FTC) Made in the USA (MUSA) case may be a bit of a head-scratcher that requires us to delve more deeply into FTC authorities and monetary recovery theories....more

Faegre Drinker Biddle & Reath LLP

EU Publishes General Product Safety Regulation – Full Enforcement to Commence in December 2024

On May 23, 2023, the European Commission formally published the new General Product Safety Regulation, which reforms a variety of product safety regulations for manufacturers doing business in the European Union (EU) and its...more

BakerHostetler

There Is Bad Press: FTC Defendant Sues the Agency Over an Over-the-Top Release

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P.T. Barnum famously said, “There’s no such thing as bad publicity.” Oscar Wilde, however, gave that quote his own spin and said, “There’s only one thing in the world worse than being talked about, and that is not being...more

McGuireWoods LLP

FTC Brings Fourth Enforcement Action Under Made in USA Labeling Rule

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On Aug. 9, 2022, the Federal Trade Commission (FTC) announced that it had referred a complaint to the U.S. Department of Justice alleging that Axis LED Group LLC, ALG-Health LLC and the individual who controls the companies...more

Alston & Bird

Class Action & MDL Roundup – Q1 2022

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Welcome back to the Class Action & MDL Roundup! This edition covers notable class actions from the first quarter of 2022. In this edition, COVID cases are still endemic for insurance companies, kids’ contracts are voidable...more

Perkins Coie

PFAS Litigation Expands Into “Mislabeling” Class Action Arena

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Per- and polyfluoroalkyl substances (PFAS) are a group of over 4,000 synthetic chemicals that have been used in industry and consumer products since the 1940s. These substances are identified by their chains of...more

Faegre Drinker Biddle & Reath LLP

State AGs Fail in Objections to Proposed Settlement in Class Action Challenging Godiva’s Labeling Practices

The last thing the parties to a class action settlement want to see is an objection from state Attorneys General (AGs).  AG objections to class action settlements are relatively rare and courts tend to give AG objections more...more

BakerHostetler

What’s in a Label - Three Takeaways from the FTC’s First Enforcement Action Brought Under the New Made in the USA Rule

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Last year, the Federal Trade Commission (FTC) finalized a new rule (Rule) that would allow the agency to seek civil penalties in matters where a company made a false and unqualified Made in the USA (MUSA) claim on product...more

BakerHostetler

Made in USA, Part Two – How Far Back Do You Have to Look?

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Prior to the new year, we blogged about how the Federal Trade Commission’s (Commission) decision to codify its Made in USA (MUSA) guidance into a rule – and the accompanying threat of civil penalties – makes it all the more...more

Alston & Bird

Class Action & MDL Roundup – Fall 2021

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In the fall edition of the Class Action & MDL Roundup, covering notable class actions from the third quarter of 2021, a marriage nearly tears apart a certified class, insurers are vaccinated against more COVID-19 suits, and...more

Perkins Coie

The Reasonable Consumer Defense: Vanilla Cases Show It’s Here to Stay in Food Litigation

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Food litigation filings have risen significantly in the recent past. According to data collected by Perkins Coie, even with the pandemic, filings targeting the food and beverage industry have seen record levels in 2020 and...more

Alston & Bird

Ninth Circuit Tells Honey Buyers to Buzz Off in “100% New Zealand Manuka Honey” Appeal

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Who said it better: “The pedigree of Honey / Does not concern the bee” (Dickinson, E.); or “[G]iven the foraging nature of bees, … it is impossible to produce honey that is derived exclusively from a single floral source”...more

Wiley Rein LLP

Under New FTC Rule, “Made in USA” Violators Will Face Monetary Penalties

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On Thursday, July 1, 2021, the U.S. Federal Trade Commission (FTC) finalized a rule that both formally adopts the agency’s longstanding guidelines for “unqualified” claims that a product has U.S. origin, and authorizes...more

Husch Blackwell LLP

FDA Reiterates Importance Of Allergen Labeling By Issuing Warning Letter Following Repeated Recalls

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On December 16, 2020, the U.S. Food and Drug Administration (“FDA”) issued a corporate Warning Letter to Whole Foods Market (“Whole Foods”) following 32 recalls Whole Foods conducted over an approximate one year period for...more

Proskauer - Advertising Law

Judges Toss Plain “Vanilla” Deceptive Labeling Claims

The beverage industry came out on top in a pair of recently dismissed lawsuits alleging the use of the term “vanilla” on drink labels was misleading, where the vanilla flavor allegedly did not come exclusively from the...more

Proskauer - Advertising Law

Added Allegations of Consumer Survey Results Fail to Sweeten the Deal: Court Dismisses “White Chips” False Advertising Suit With...

We previously blogged about the dismissal without prejudice of a putative consumer class action alleging that the well-known confectioner Ghirardelli misled consumers into believing its “Premium Baking Chips Classic White...more

Morrison & Foerster LLP - Class Dismissed

Fool Me Once, No Injunctive Relief On Behalf Of A Class Of Purchasers

Does a plaintiff who files a class action alleging false advertising have Article III standing to seek injunctive relief—even when that plaintiff is a past purchaser of the product, and therefore is aware of the defendant’s...more

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