Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 1 of 38

1 GOOD GUSTAFSON AUMAIS LLP

J. Ryan Gustafson (Cal. Bar No. 220802)
2 2330 Westwood Blvd., No. 103
Los Angeles, CA 90064
3 Tel: (310) 274-4663
4 jrg@[Link]

5 SHENAQ PC
Amir Shenaq, Esq.*
6 3500 Lenox Road, Ste. 1500
Atlanta, GA 30326
7
Tel: (888) 909-9993
8 amir@[Link]

9 THE KEETON FIRM LLC

Steffan T. Keeton, Esq.*
10 100 S Commons, Ste 102
Pittsburgh PA 15212
11 Tel: (888) 412-5291
12 stkeeton@[Link]

13 *Pro hac vice forthcoming

14 Counsel for Plaintiff and the Proposed Classes

15
UNITED STATES DISTRICT COURT
16
NORTHERN DISTRICT OF CALIFORNIA
17
18
EUREKA DIVISION
19
20
Margaret Murphy, individually, and CASE NO.
21 on behalf of those similarly situated,
CLASS ACTION COMPLAINT
22 Plaintiff,
Demand for Jury Trial
23
v.
24
UNILEVER UNITED STATES, INC.,
25
Defendant.
26
27
28
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 2 of 38

Plaintiff Margaret Murphy (“Plaintiff”) brings this action on behalf of herself,

1
2 and all others similarly situated against Defendant UNILEVER UNITED STATES,

3 INC. (“Unilever” or “Defendant”) for the manufacture, distribution, marketing, and

4
sale of THE LAUNDRESS brand products (the “Product” or “Products”).1 Plaintiff
5
makes the following allegations pursuant to the investigation of their counsel and
6
based upon information and belief, except as to the allegations specifically pertaining
7
8 to themselves, which is based on personal knowledge:

9
NATURE OF ACTION
10
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11 1. This is a class action complaint against Defendant for the manufacture,

12
distribution, marketing, and sale of the Products, that based on Defendant’s own
13
admission suffer from identical deceptive conduct concerning the inclusion of deadly
14
15 bacteria. Despite Defendant’s widespread marketing campaign that the Products are

16 non-toxic and present better-for-you alternatives to other cleaners, the Products

17 contain highly toxic, undisclosed ingredients. Specifically, the Products contain

18
undisclosed bacteria that have fatal consequences. Household cleaning products that
19
pose such a hazard are unreasonably dangerous compared to the utility of the
20
21 Products. This deception rendered the Products unsuitable for their principal and

22 intended purpose. Further, had Plaintiff and Class Members been aware of the

23 presence of fatal bacteria, they would not have purchased the Products.
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2. With the sale of every Product, Defendant delivered a biological weapon
25
into the home of every Class Member.
26
27
1 At the time of this filing, Exhibit A includes the LAUNDRESS products that are
28 included in this definition. This definition is not exhaustive, and shall include all of
Defendant’s products that are similarly misrepresented and defective.
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 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 3 of 38

3. Instead of subtracting bacteria, each Product adds bacteria which can

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2 multiply within a household because it is – as one Oxford researcher describes – a

3 superbug that is antibiotic resistant.2

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4. The Products contain a bacterium, Pseudomonas, that has a mortality
5
rate of 39%3 and has caused multiple fatal outbreaks in infant wards at hospitals
6
throughout the country.4
7
8 5. On November 17, 2022, Defendant first revealed that THE

9 LAUNDRESS brand’s entire product line contains harmful, toxic bacteria.

10
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6. In fact, the toxin has been present in all of the Products for years.
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7. Unfortunately, the toxin permeated – unknowingly to consumers –
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13 throughout all of the Products which led (and currently leads) to unneeded physical

14 injury and economic harm.

15 8. Plaintiff and Class Members are further harmed because once silk,
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cashmere, and wool are contaminated by the bacterium, these garments may be
17
18
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20 2 University of Oxford, Common drug-resistant superbug develops fast resistance to
'last resort' antibiotic (June 7, 2022), [Link]
21 drug-resistant-superbug-develops-fast-resistance-last-resort-antibiotic.
22
3Cheol-In Kang, Sung-Han Kim, Hong-Bin Kim, Sang-Won Park, Young-Ju Choe,
23 Myoung-don Oh, Eui-Chong Kim, Kang-Won Choe, Pseudomonas aeruginosa
Bacteremia: Risk Factors for Mortality and Influence of Delayed Receipt of Effective
24 Antimicrobial Therapy on Clinical Outcome, CLINICAL INFECTIOUS DISEASES, Volume
37, Issue 6, 15 September 2003, Pages 745–751, [Link]
25
4 Justin Moyer, What we know about Pseudomonas, the potentially deadly bacteria
26 found at a Maryland hospital, THE WASHINGTON POST ((Aug. 9, 2016),
[Link]
27 pseudomonas-the-potentially-deadly-bacteria-found-at-a-md-hospital/; Aimee Ortiz,
Deaths of 3 Infants Traced to Contaminated Equipment, Hospital Says, THE NEW
28 YORK TIMES (Nov. 8, 2019), [Link]
[Link].
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destroyed because they cannot be exposed to hot water, intense heat, bleach or
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2 hospital grade disinfectants which are necessary to kill the bacteria.

3 9. In other words, a favorite silk or cashmere garment once owned by a

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parent or grandparent could be forever ruined simply because a Class Member tried
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to clean it with a “premium,” “non-toxic” product.
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10. Because Defendant continues to reap its spoils, and gives the false
7
8 impression that the Products are safe, Defendant exposes this risk to millions of

9 Americans every day while also knowingly selling consumers defective Products that
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expose every Class Members’ household to great harm.

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11. In fact, once the truth is exposed the Products are, at best, worthless.
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13 12. Reasonable consumers, like Plaintiff, purchase the Products to subtract
14 bacteria rather than adding harmful, toxic bacteria that can cause “serious
15 infections,” “severe tissue damage,”5 death, “pneumonia or septicaemia.”6
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17 13. Plaintiff brings claims against Defendant individually and on behalf of a

18 class of all other similarly situated purchasers of the Products for (i) violations of the

19 consumer protection statutes for states included in a Multi-State Consumer Class; (ii)
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violations of California’s Unfair Competition Law; (iii) violation of California’s False
21
Advertising Law; (iv) violation of California’s Consumer Legal Remedies Act; (v)
22
23
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25 5Sabir R, Alvi SF, Fawwad A, Basit A. Antibiogram of Pseudomonas aeruginosa and
Methicillin-resistant Staphylococcus aureus in patients with diabetes. PAK J MED SCI.
26 2014 Jul;30(4):814-8. doi: 10.12669/pjms.304.4755. PMID: 25097523; PMCID:
PMC4121704.
27
6ACTION MEDICAL RESEARCH, Secrets of a 'superbug': what makes Pseudomonas
28 bacteria so deadly? (Oct. 6, 2007), [Link]
what-makes-pseudomonas-bacteria-so-deadly.
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breach of implied warranty; (vi) violation of the Magnuson-Moss Warranty Act; and
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2 (vii) unjust enrichment.

3
PARTIES
4 14. Plaintiff is, and at all times relevant to this action has been, a resident
5
of California and a domiciliary of California.
6
7 a. Within the past two years, Plaintiff made several purchases of

8 Defendant’s Products from e-commerce stores, including but not limited to

9 FabFitFun, that shipped products to her residence in California. The Products

10 purchased by Plaintiff included, but not limited to, the Delicate Wash, the Crease
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11 Relief spray, and the Signature Detergent. Prior to purchasing THE LAUNDRESS

12 Products, Plaintiff saw and relied on the representation and warranty that the

13 product would be a “non-toxic” and “better for you” alternatives to other cleaning

14 methods like dry cleaning. Plaintiff understood these representations to mean that

15 the Products did not contain harsh, harmful, or toxic ingredients. At the time of

16 purchase, Plaintiff did not expect that the cleaning supplies purchased would contain

17 a bacterium with deadly consequences. Plaintiff purchased the Products at a

18 substantial price premium, and would not have purchased the products had she

19 known that the marketing she relied on was false, misleading, deceptive and unfair

20 or that the Products contained potentially deadly bacteria. Plaintiff would purchase

21 the Products again in the future if Defendant conformed the Products to their “non-

22 toxic” marketing.

23 b. Plaintiff purchased the Products because she believed they were

24 fit for use as non-toxic cleaners and safe to be used on delicate clothing in lieu of

25 having to dry clean expensive clothing. However, the Products that Plaintiff

26 purchased were not fit for use due to the presence of toxic bacteria in the Products.

27 Ms. Murphy’s belief that the Products were fit to be used as non-toxic cleaning

28

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 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 6 of 38

1 products formed the basis of the bargain, and Ms. Murphy would not have purchased
2 the Products.
3 c. The Products that Plaintiff purchased and used caused Plaintiff
4 and members of her household to suffer from respiratory infections, skin infections,
5 rashes, and hives.
6 d. Plaintiff suffered economic injury from the Products’ defect
7 because she purchased an item that was worth less than what had been represented
8 to her.
15. Defendant is a Delaware corporation with its principal place of business
9
10 in Englewood Cliffs, New Jersey. Defendant sells the Products throughout the United
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11 States, including in the state of California.

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16. Defendant is part of the Unilever Group, an international consumer
13
goods company that is comprised of two parent companies, Unilever N.V. in
14
Rotterdam, Netherlands and Unilever PLC in London, United Kingdom. The
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16 Unilever Group operates in the United States under its subsidiary, Unilever United

17 States, Inc., which operates as a single economic entity.

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19
JURISDICTION AND VENUE
20
21 17. This Court has subject matter jurisdiction over this action pursuant to
22 28 U.S.C. § 1332(d) because there are more than 100 class members and the
23 aggregate amount in controversy exceeds $5,000,000, exclusive of interest, fees, and
24 costs, and at least one Class member is a citizen of a state different from Defendant.
25 18. This Court has personal jurisdiction over Defendant. Defendant
26 purposefully avails itself of the California consumer market and distributes the
27 Products to many locations within this District and hundreds of retail locations
28

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1 throughout the State of California, where the Products are purchased by thousands of
2 consumers every day.
3 19. Venue is proper in this District under 28 U.S.C. § 1391(a). Plaintiff’s
4 purchases of Defendant’s Products, substantial acts in furtherance of the alleged
5 improper conduct, including the dissemination of false and misleading information
6 regarding the nature, quality, and/or ingredients of the Products, occurred within this
7 District and the Defendant conducts business in this District.
8
DIVISIONAL ASSIGNMENT
9
10 20. Pursuant to Civil Local Rule 3-2(c-d), a substantial part of the events
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11 giving rise to the claims arose in Lake County, and this action should be assigned to
12
the Eureka Division.
13
COMMON FACTUAL ALLEGATIONS
14
15 A. Defendant Manufactures, Markets, Distributes and Sells the
Products
16
21. Defendant manufactures, markets, distributes, and sells the Products
17
throughout the United States.
18
22. In January 2019, Defendant acquired the “premium eco-friendly line of
19
detergent, fabric care, and home cleaning products”7 for $100,000,000.8
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23. Millions of units containing toxic bacteria were sold throughout the
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United States to consumers in all fifty states and Washington, D.C. at premium
22
prices compared to competing brands. For example, one gallon of its Signature
23
Detergent costs approximately $94 per unit.
24
25 7UNILEVER, Unilever acquires The Laundress (Jan. 27, 2019),
[Link]
26 acquires-the-laundress/.

27 8Elizabeth Segran, The Laundress founders come clean about why they sold to
Unilever, FAST COMPANY (Jan. 29, 2019),
28 [Link]
and-lindsey-boyd-on-why-they-sold-to-unilever.
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17 24. Defendant markets the Products through a widespread campaign
18 focused on premium consumers that demand non-toxic, eco-friendly, and green
19 cleaning products.
20 B. Defendant’s Universal Branding and Marketing Campaigns
Emphasize the Non-Toxic Nature of the Products.
21
25. Defendant positions its Products as premium, non-toxic alternatives to
22
competing products through a widespread marketing campaign.
23
26. THE LAUNDRESS is “known for its luxury, non-toxic and cruelty-free
24
soaps and detergents….”9
25
26
27 9Lauren Silver, Luxury lifestyle brand The Laundress tells customers to stop using its
products, FOX13 (Nov. 21, 2022),
28 [Link]
customers-stop-using-its-products/FLMEKMRPQZG55AO4UHPLKEDO34/
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1 27. For example, Defendant routinely positions its Products as a toxic-free,

2 better-for-you alternative to dry cleaning:
1. “Dry clean only? No way. You've got this, and we can help.
3 Nobody relishes the idea of wearing highly toxic dry cleaning
chemicals against their skin along with their most delicate
4 clothing items. Now there's a solution that is better for both
you and the environment, all without ruining your treasured
5 delicates. Washing delicates is easier than ever with Delicate
Wash from The Laundress. It smells divine and easily removes
6 odors while cleaning and preserving delicate fabrics. Visit our
Clean Talk Blog for instructions on how to wash specific delicate
7 items.”10
8 2. “Of course, your delicates are not usually the items to wear once
and toss in the laundry. If you want to stay fresh between
9 washing delicate items, try our non-toxic, biodegradable, and
delightfully fragrant Delicate Spray. It's perfect for silks, knits,
10 and undergarments. So keep that favorite silk Hermes scarf in the
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rotation a bit longer before your next hand-washing adventure.

11 This fabric spray makes a great gift, too. You can even use it to
freshen bed linens, pillows, and furniture around the house.
12 Herbal and citrus notes combine with amber, bergamot, lavender,
and musk to make everyone's nose a little happier.”11
13
3. “Eliminating the dry cleaner was one of our first missions in
14 creating this line of laundry and fabric care products. And lucky
for you, we've accomplished our goal. Use this kit to safely clean
15 and preserve woolens, delicates, synthetics, and more without
the toxins and extra cost of the dry cleaner!”12
16
4. “Ideal for travel or stashing in your bag or car, this handy kit
17 washes, freshens, and removes stains on silk, delicates, woolens,
synthetics and more without the toxins and extra cost of the dry
18 cleaner. Airplane-friendly and comes housed in a canvas zip
bag.”13
19
20
21 28. These representations are omnipresent in all of Defendant’s marketing
22 efforts.
23
10The Laundress, Gentle, Yet Powerful Cleaning for Your Delicate Items,
24 [Link] (emphasis
added).
25
26
11Id. (emphasis added).
12The Laundress, Dry Cleaning Detox Kit Product Page,
27 [Link] (emphasis added).

28 13The Laundress, Dry Clean on the Go Kit Product Page,

[Link] (emphasis added).
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1 29. For example, in a video entitled “Why You Should Rethink Dry
2 Cleaning” on the brand’s official website, co-founder Lindsey Boyd describes the toxic
3 chemicals that occur in dry cleaning and why THE LAUNDRESS is a “better for you”
4 alternative. She describes the Products as “non-toxic” and containing “the best
5 ingredients.”14
6 30. Defendant markets the Products through social media and uses
7 hashtags like #greencleaning, #plantderived, and #ecoconscious to further the
8 message that its Products are non-toxic, “good for you,” and offer an environmentally-
9 focused cleaning experience.
10 31.
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19 32. Defendant’s marketing campaigns have been successful at cultivating a
20 loyal customer base of consumers that seek non-toxic cleaning products and are
21 willing to pay thousands of dollars to obtain non-toxic cleaning products.
22 33. For example, customers will fill entire shelves at home with the
23 Products.
24
25
26
27
14The Laundress, Why You Should Rethink Your Next Trip to the Dry Cleaner,
28 [Link]
next-trip-to-the-dry-cleaner.
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9 34. Class Members represent this loyal customer base that was deceived
10 into buying “non-toxic” Products that actually contained undisclosed harmful toxins
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11 with fatal consequences.

12
13 C. The Product Contains Harmful, Toxic Ingredients That Were Not
Disclosed at the Time of Sale.
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35. The Products contain toxic ingredients that were not disclosed on the
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Products’ packaging nor in any other medium by Defendant prior to purchase by
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Plaintiff and the Class.
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36. The Products contain harmful bacteria, including Pseudomonas.
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37. Pseudomonas is a “superbug” because, as Dr. Craig MacLean from the
19
University of Oxford describes, it “mutates at an incredibly high rate, allowing [the]
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bacteria to quickly evolve antibiotic resistance.”15
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38. Pseudomonas “frequently cause[] serious infections” and can “cause
22
severe tissue damage.”16
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39. “[I]nfection is severe and life-threatening, leading to pneumonia or
24
septicaemia.”17
25
26 15 University of Oxford, supra note 2.
27
16 Sabir, et. al., supra note 5.
28
17 University of Oxford, supra note 2.
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1 40. Exposure to the bacteria can be fatal, and in 2016 it caused a deadly
2 outbreak that killed multiple infants at a Maryland hospital.18
3 41. In 2019, an outbreak of the bacteria at a Pennsylvania hospital also took
4 the lives of multiple infants.19
5 42. Pseudomonas can kill people “within 24 hours” of exposure.20
6 43. In one study of Pseudomonas, the bacteria displayed a 30-day mortality
7 rate of 39%.21
8 44. Defendant has, or should have, knowledge of the contents of the
9 Products that it sends into homes throughout the country.
10 45. The presence of toxins was not known by Plaintiff or Class Members
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11 prior to purchase.
12 46. The presence of harmful bacteria was a material element in Plaintiff’s
13 and Class Members’ decision to purchase the Products. Prior to purchase, Defendant
14 failed to inform Plaintiff and Class Members that the Products contained a bacterium
15 with fatal consequences. Only recently in November 2022, and after Class Members
16 purchased the Products, Defendant first revealed the presence of the bacteria in the
17 Products.
18 47. Had Plaintiff and Class Members known of the inclusion of the
19 undisclosed bacteria, they would not have purchased the Products.
20 48. Thus, the Products are worthless.
21
22
23
24 18 Moyer, supra note 4.
25
19 Ortiz, supra note 4.
26
27
20 ACTION MEDICAL RESEARCH, supra note 6.

28 21 Kang, et. al., supra note 3.

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D. The Products Harm People.

1
2 49. As described above, the Products present a great danger to the public.

3 50. The Products have harmed people and continue to pose a threat to the
4
public.
5
6 51. The Products that Plaintiff purchased and used caused Plaintiff and

7 members of her household to suffer from respiratory infections, skin infections,

8 rashes, and hives.

9 52. With the resiliency of the “superbug,” long-term consequences are

10 unknown but expected given the long timeline that the bacterium colonizes.
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11 53. Other Class Members have had similar experiences:

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54. The Products create undue risk, danger, and harm throughout all
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12 aspects of everyday life. This danger is ever-present. Thus, Defendant’s inclusion of

13 toxins removes all utility from the Products.

14
E. Defendant’s Exclusive Pre-Sale Knowledge of the Toxins
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55. Defendant had exclusive knowledge of the Products’ contents prior to
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sale to consumers.
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56. Plaintiff and Class Members were unable to test or observe the
18
ingredients in the Products prior to purchase.
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57. Defendant knew or should have known that the Products purported to
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be non-toxic contained toxins.
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58. Defendant knew or should have known that the Products contained
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bacteria that can have fatal consequences.
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F. Plaintiff and Class Members Have Suffered Economic Injury
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59. Plaintiff and the Class Members reasonably relied to their detriment on
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Defendant’s deceptive and misleading representations and omissions concerning the
26
Products.
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60. Defendant's false, misleading, and deceptive misrepresentations and
28
omissions are likely to continue to deceive and mislead reasonable consumers and the
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1 general public, as they have already deceived and misled Plaintiff and the Class
2 Members.
3 61. In making the false, misleading, and deceptive representations and
4 omissions described herein, Defendant knew and intended that consumers would pay
5 a premium for Products under the – false – belief that the Products were safe and
6 free of toxins.
7 62. As an immediate, direct, and proximate result of Defendant's false,
8 misleading, and deceptive representations and omissions, Defendant injured the
9 Plaintiff and the Class Members in that they:
10 a. Paid a sum of money for Products that were not what Defendant
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11 represented;
12 b. Paid a premium price for Products that were not what Defendant
13 represented;
14 c. Were deprived of the benefit of the bargain because the Products they
15 purchased were different from what Defendant warranted; and
16 d. Were deprived of the benefit of the bargain because the Products they
17 purchased had less value than what Defendant represented.
18 63. Plaintiff and Class Members were additionally harmed by damage to
19 clothing, washing machines, and other property from exposure to the undisclosed
20 bacteria as well as the countless hours to attempt to clean the contaminated clothing.
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2 64. The scope of the damage to clothing is intensified because of the
3 bacterium’s long colonization period and its durability. Some Class Members have
4 washed thousands of garments with the Products.
5 65. Many garments can only be washed with cold water and can only be
6 hung to dry without the use of heat. For many, these garments are ruined because
7 the bacteria cannot be removed.
8 66. Madeline Miller, Product Specialist at THE LAUNDRESS understands
9 that "[c]ertain delicate natural fibers such as silk, cashmere and wool are particularly
10 sensitive to laundering methods, and cannot be exposed to harsh routines that
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11 include hot water and high spin."22

12 67. In other words, many garments made from silk, cashmere, and wool that
13 are contaminated by the bacterium may never be remedied because hot water cannot
14 be used on these fabrics.
15 68. Had Defendant not made the false, misleading, and deceptive
16 representations and omissions, Plaintiff and the Class Members would not have been
17 willing to pay the same amount for the Products they purchased, and, consequently,
18 Plaintiff and the Class Members would not have been willing to purchase the
19 Products.
20 69. Plaintiff and the Class Members paid for Products that were believed to
21 be safe and free of the Defect but received Products that were unsafe and contained
22 toxins. The products Plaintiff and the Class Members received were worth less than
23 the Products for which they paid.
24 70. Plaintiff and Class Members paid a premium for the Products because
25 they relied on Defendant’s marketing that the Products were non-toxic.
26
27
22Stephanie Osmanski, A Comprehensive Guide to the Laundry Room: What Do
28 Those Common Laundry Symbols Actually Mean?, PARADE (Oct. 19, 2022),
[Link]
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71. Plaintiff and the Class Members all paid money for the Products.
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However, Plaintiff and the Class Members did not obtain the full value of the
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advertised Products due to Defendant's misrepresentations and omissions. Plaintiff
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and the Class Members purchased, purchased more of, and/or paid more for, the
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Products than they would have had they known the truth about the Products.
16
Consequently, Plaintiff and the Class Members have suffered injury in fact and lost
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money as a result of Defendant's wrongful conduct.
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CLASS ACTION ALLEGATIONS
20 72. Plaintiff brings this action as a class action pursuant to Federal Rule of
21
Civil Procedure 23 on behalf of themselves, on behalf of all others similarly situated,
22
and as a member of the Classes defined as follows (collectively, the “Classes” or
23
24 “Class”):

25 a. Multi-State Consumer Class: All persons in the States of California,

26 Florida, Illinois, Massachusetts, Minnesota, Missouri, New Jersey,
27
28

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New York, Pennsylvania, Oregon, and Washington who purchased

1
2 the Products.23

3 b. California Class: All persons who purchased Defendant’s Product

4
within the State of California and within the applicable statute of
5
limitations.
6
c. Nationwide Class: All persons who purchased Defendant’s Product
7
8 within the United States and within the applicable statute of

9 limitations period.
10
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73. Excluded from the Class are Defendant, their parents, subsidiaries,
11
affiliates, officers, and directors, those who purchased the Products for resale, all
12
13 persons who make a timely election to be excluded from the Class, the judge to whom

14 the case is assigned and any immediate family members thereof.

15 74. The members of the Class are so numerous that joinder of all Class
16
Members is impracticable. Defendant has sold, at a minimum, millions of units of the
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Products to Class Members.
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19 75. There is a well-defined community of interest in the questions of law and

20 fact involved in this case. Questions of law and fact common to the members of the

21 putative classes that predominate over questions that may affect individual Class
22
Members include, but are not limited to the following:
23
24
25 23The States in the Multi-State Consumer Class are limited to those States with similar
consumer protection laws under the facts of this case: California (Cal. Bus. & Prof. Code §
26 17200, et seq.); Florida (Fla. Stat. § 501.201, et seq.); Illinois (815 ILCS 505/1, et seq.);
Massachusetts (Mass. Gen. Laws Ch. 93A, et seq.); Michigan (Mich. Comp. Laws §
27 445.901, et seq.); Minnesota (Minn. Stat. § 325F.67, et seq.); Missouri (Mo. Rev. Stat.
407.010, et seq.); New Jersey (N.J. Stat. § 56:8-1, et seq.); New York (N.Y. Gen. Bus. Law
28 § 349, et seq.); Pennsylvania (73 Pa. Stat. Ann. §§ 201-1 et seq.); Oregon (Or. Rev. Stat.
§§ 646.605, et seq.); and Washington (Wash Rev. Code § 19.86.010, et seq).
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a. whether Defendant misrepresented material facts concerning the

1
2 Products on the label of every product;

3 b. whether Defendant’s conduct was unfair, misleading, and/or

4
deceptive;
5
c. whether Defendant has been unjustly enriched as a result of the
6
unlawful, fraudulent, and unfair conduct alleged in this
7
8 Complaint such that it would be inequitable for Defendant to

9 retain the benefits conferred upon it by Plaintiff and the Classes;

10
GOOD GUSTAFSON AUMAIS LLP

d. whether Plaintiff and the Classes are entitled to equitable and/or

11
injunctive relief;
12
13 e. whether Defendant breached warranties to Plaintiff and the

14 Classes;

15 f. whether Plaintiff and the Classes have sustained damages with

16
respect to the common-law claims asserted, and if so, the proper
17
measure of their damages.
18
19 76. Plaintiff’s claims are typical of those of other Class Members because

20 Plaintiff, like all members of the Classes, purchased Defendant’s Products containing

21 the same Defect, and suffering from the same representations and omissions, and
22
Plaintiff sustained damages from Defendant’s wrongful conduct.
23
77. Plaintiff will fairly and adequately protect the interests of the classes
24
25 and have retained counsel that is experienced in litigating complex class actions.

26 Plaintiff has no interests which conflict with those of the Classes.

27 78. A class action is superior to any other available means for the fair and
28
efficient adjudication of this controversy, and no unusual difficulties are likely to be
– 18 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 20 of 38

encountered in the management of this class action. The damages or other financial
1
2 detriment suffered by Plaintiff and the other Class Members are relatively small

3 compared to the burden and expense that would be required to individually litigate
4
their claims against Defendant, making it impracticable for Class Members to
5
individually seek redress for Defendant’s wrongful conduct. Even if Class Members
6
could afford individual litigation, the court system could not. Individualized litigation
7
8 creates a potential for inconsistent or contradictory judgments, and increases the

9 delay and expense to all parties and the court system. By contrast, the class action
10
GOOD GUSTAFSON AUMAIS LLP

device presents far fewer management difficulties, and provides the benefits of single
11
adjudication, economies of scale, and comprehensive supervision by a single court.
12
13 79. The prerequisites to maintaining a class action for equitable relief are

14 met as Defendant has acted or refused to act on grounds generally applicable to the

15 classes, thereby making appropriate equitable relief with respect to the classes as a
16
whole.
17
80. The prosecution of separate actions by members of the classes would
18
19 create a risk of establishing inconsistent rulings and/or incompatible standards of

20 conduct for Defendant. For example, one court might enjoin Defendant from

21 performing the challenged acts, whereas another might not. Additionally, individual
22
actions could be dispositive of the interests of the classes even where certain Class
23
Members are not parties to such actions.
24
25 81. For the purposes of this Complaint, the term “Class Members” refers to

26 all members of the Class, including the Plaintiff.

27 82. This action is maintainable as a class action under Federal Rule of Civil
28
Procedure Rule 23.
– 19 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 21 of 38

83. This Court should certify a class under Rule 23(b)(2) because Defendant
1
2 has acted or refused to act on grounds that apply generally to the Class, by making

3 illegal, unfair, misleading and deceptive representations and omissions regarding

4
Products.
5
84. This Court should certify a class under Rule 23(b)(3) because the
6
common issues identified above predominate over any questions affecting individual
7
8 members and a class is superior to other available methods to fairly and efficiently

9 adjudicate the claims.

10
GOOD GUSTAFSON AUMAIS LLP

85. Notice to the Class. Plaintiff anticipates that this Court can direct
11
notice to the Class, to be effectuated by publication in major media outlets and the
12
13 Internet.

14
COUNT I
15
Violation of State Consumer Protection Statutes
16 (On Behalf of the Multi-State Consumer Class)
17
86. Plaintiff repeats and realleges each and every allegation above as if set
18
forth herein.
19
87. The Consumer Protection Acts of the States in the Multi-State
20
Consumer Class prohibit the use of unfair or deceptive business practices in the
21
conduct of trade or commerce.
22
88. Defendant intended that Plaintiff and the other members of the Multi-
23
State Consumer Class would rely upon their deceptive conduct, and a reasonable
24
person would in fact be misled by its deceptive conduct.
25
89. As a result of the Defendant’s use or employment of unfair or deceptive
26
acts or business practices, Plaintiff, and other members of the Multi-State Consumer
27
Class, have sustained damages in an amount to be proven at trial.
28

– 20 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 22 of 38

COUNT II
1
Violation of California Business & Professions Code §§ 17200 et seq. –
2
Unlawful Conduct Prong of the UCL
3
(On Behalf of the California Class)
4
90. Plaintiff incorporates by reference all allegations contained in the
5
complaint as if fully set forth herein.
6
91. The acts, omissions, misrepresentations and practices of Defendant
7
constitute “unlawful” business acts and practices under the California Business &
8
Professions Code section 17200 (“UCL”).
9
92. Defendant’s acts, omissions, misrepresentations and practices are
10
GOOD GUSTAFSON AUMAIS LLP

“unlawful” because they violate the California False Advertising Law (“FAL”), the
11
Magnuson-Moss Warranty Act (“MMWA”) and the Consumer Legal Remedies Act
12
(“CLRA”).
13
93. Defendant’s representations and omissions that the Products are non-
14
toxic and safe are false, deceptive, and likely to deceive the public.
15
94. Defendant’s representations and omissions concerning the ingredients in
16
the Products is false, deceptive, and likely to deceive the public.
17
95. Defendant’s deceptive advertising caused Plaintiff and members of the
18
Class to suffer injury in fact and to lose money or property, as it denied them the
19
benefit of the bargain when they decided to make their purchases over other products
20
that are less expensive and without the harmful and dangerous effects of the
21
Products.
22
96. In accordance with California Business & Professions Code section
23
17203, Plaintiff seeks an order enjoining Defendant from continuing to conduct
24
business through unfair acts and practices and to commence a corrective advertising
25
campaign.
26
97. Plaintiff also seeks an order for the disgorgement and restitution of all
27
monies from the sale of the Products that were unjustly acquired through acts of
28
unlawful, unfair and/or fraudulent competition.
– 21 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 23 of 38

COUNT III
1
Violation of California Business & Professions Code §§ 17200, et seq. –
2
Unfair and Fraudulent Conduct Prongs of the UCL
3
(On Behalf of the California Class)
4

5 98. Plaintiff incorporates by reference all the allegations of the preceding

6 paragraphs.
7 99. California Business & Professions Code section 17200 prohibits any
8 unfair or fraudulent business act or practice.
9 100. The false and misleading marketing, advertising, and labeling of the
10 Products, as alleged herein, constitute unfair business acts and practices because
GOOD GUSTAFSON AUMAIS LLP

11 such conduct is immoral, unscrupulous, and offends public policy.

12 101. The acts, omissions, misrepresentations, practices, and non-disclosures
13 constitute “fraudulent” business acts and practices, because Defendant’s conduct is
14 false and misleading to Plaintiff and Class Members.
15 102. Further, the gravity of Defendant’s conduct outweighs any conceivable
16 benefit of such conduct.
17 103. Defendant’s advertising, communications, packaging, and marketing of
18 the Products is likely to deceive Class Members about their contents and safety.
19 104. Defendant either knew or reasonably should have known that the claims
20 and statements in the advertising, marketing, and labeling were likely to deceive
21 consumers.
22 105. In accordance with California Business & Professions Code section
23 17203, Plaintiff seeks an order enjoining Defendant from continuing to conduct
24 business through unfair and/or fraudulent acts and practices and to commence a
25 corrective advertising campaign.
26 106. Plaintiff seeks an order for the disgorgement and restitution of all
27 monies from the sale of the Products that were unjustly acquired through acts of
28 unlawful, unfair and/or fraudulent competition.

– 22 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 24 of 38

COUNT IV
1
Violation of California Business & Professions Code §§ 17500, et seq. –
2
False and Misleading Advertising
3
(On Behalf of the California Class)
4
107. Plaintiff incorporates by reference all preceding paragraphs.
5
108. California False Advertising Law (Cal. Business & Professions Code
6
sections 17500 and 17508) prohibits “mak[ing] any false or misleading advertising
7
claim.”
8
109. Defendant, in its advertising, marketing, and labeling of the Products,
9
makes false and misleading advertising claims as it deceives consumers as to their
10
GOOD GUSTAFSON AUMAIS LLP

safety.
11
110. In reliance on these false and misleading advertising claims, Plaintiff
12
and members of the Nationwide Class purchased and used the Products without the
13
knowledge they contained toxins that caused, or greatly increased the risk of, serious
14
injury or death, to users of the Products.
15
111. Defendant knew or should have known that its labeling, advertising,
16
and marketing was likely to deceive consumers.
17
112. As a result, Plaintiff and the Class are entitled to injunctive and
18
equitable relief, restitution, and an order for the disgorgement of the funds by which
19
Defendant was unjustly enriched.
20
21
COUNT V
22 Violation of California’s Consumers Legal Remedies Act
23 CAL. CIV. CODE § 1750 et seq.
24 (Seeking Injunctive Relief Only)
25 (On Behalf of the California Class)

26 113. Plaintiff incorporates by reference and re-alleges herein all paragraphs

27 alleged above.
28

– 23 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 25 of 38

1 114. Plaintiff brings this claim individually and on behalf of the members of
2 the proposed Classes against Defendant.
3 115. This claim seeks injunctive relief only, pursuant to California Civil Code
4 section 1782(d).
5 116. Defendant’s actions, representations, and conduct have violated, and
6 continue to violate, the CLRA because they extend to transactions that are intended
7 to result, or that have resulted, in the sale of goods to consumers.
8 117. Plaintiff and the California Class members are “consumers” as the
9 CLRA defines that term in California Civil Code section 1761(d).
10 118. Defendant sold the Products, which are “goods” within the meaning of
GOOD GUSTAFSON AUMAIS LLP

11 California Civil Code section 1761(a), to Plaintiff and the California Class members.
12 119. Defendant’s policies, acts, and practices were designed to, and did, result
13 in Plaintiff and the California Class members’ purchase and use of the Products
14 primarily for personal, family, or household purposes, and violated and continue to
15 violate the following sections of the California Civil Code section 1770:
16 a. section 1770(a)(5), which prohibits representing that goods or
17 services have sponsorship, approval, characteristics, ingredients,
18 uses, benefits, or quantities which they do not have;
19 b. section 1770(a)(7), which prohibits representing that goods or
20 services are of a particular standard, quality, or grade, or that
21 goods are of a particular style or model, if they are of another;
22 c. section 1770(a)(9), which prohibits advertising goods or services
23 with intent not to sell them as advertised; and
24 d. section 1770(a)(16), which prohibits representing that the subject
25 of a transaction has been supplied in accordance with a previous
26 representation when it has not.
27 120. Defendant’s advertising, labeling, and marketing of the Products are
28 likely to deceive reasonable consumers, including Plaintiff and the California Class

– 24 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 26 of 38

1 members. Defendant’s representations and omissions that the Products are adequate
2 and safe are false and likely to deceive the public, as is Defendant’s failure to mention
3 the numerous adverse events related to their usage.
4 121. Plaintiff and the California Class members would not have purchased
5 the Products absent Defendant’s misleading and deceptive marketing campaign and
6 labeling regarding the safety of the Products.
7 122. Defendant knew or should have known that its Products’ advertising,
8 labeling, and marketing were likely to deceive reasonable consumers regarding the
9 safety of the Products.
10 123. Defendant’s deceptive representations and omissions about the Products
GOOD GUSTAFSON AUMAIS LLP

11 caused Plaintiff and the members of the California Class to suffer injury in fact and
12 to lose money or property, as it denied them the benefit of the bargain when they
13 decided to make their Product purchases over other products that are less expensive
14 and without the harmful and dangerous contents of the Products.
15 124. Plaintiff and the California Class members request that this Court
16 enjoin Defendant from continuing to employ the unlawful methods, acts, and
17 practices alleged herein pursuant to California Civil Code section 1780(a)(2). If
18 Defendant is not restrained from engaging in these types of practices in the future,
19 Plaintiff and the California Class members will be harmed in that they will continue
20 to be unable to rely on Defendant’s deceptive representations and omissions
21 regarding the contents and safety of the Products.
22 COUNT VI
23 Breach of Implied Warranty
24 (On Behalf of the Nationwide Class)
25 125. Plaintiff incorporates by reference and re-allege herein all paragraphs
26 alleged above.
27 126. Plaintiff brings this claim individually and on behalf of the members of
28 the proposed Classes against Defendant.

– 25 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 27 of 38

1 127. Defendant, as the manufacturer, marketer, distributor, and/or seller of

2 the Products, impliedly warranted that the Products (i) would not contain toxins and
3 (ii) was generally safe for consumer use.
4 128. Defendant breached the warranty implied in the contract for the sale of
5 the defective Products because it could not pass without objection in the trade under
6 the contract description, the Products were not of fair or average quality within the
7 description, and the Products were unfit for its intended and ordinary purpose
8 because the Products were defective in that it contained ingredients that made the
9 Products unreasonably dangerous, and as such is not generally recognized as safe for
10 consumer use. As a result, Plaintiff and Class Members did not receive the goods as
GOOD GUSTAFSON AUMAIS LLP

11 impliedly warranted by Defendant to be merchantable.

12 129. Defendant was on notice of the presence of toxins because it has
13 exclusive knowledge of the Products’ contents.
14 130. Additionally, Plaintiff sent notice of these breaches to the retailer.
15 131. Plaintiff and Class Members purchased the Products in reliance upon
16 Defendant’s skill and judgment and the implied warranties of fitness for the purpose.
17 132. The Products were not altered by Plaintiff or Class Members.
18 133. The Products were nonconforming and defective when they left the
19 exclusive control of Defendant.
20 134. Defendant knew that the Products would be purchased and used without
21 additional testing by Plaintiff and Class Members.
22 135. The Products contained dangerous, undisclosed ingredients and were
23 unfit for their intended purpose, and Plaintiff and Class Members did not receive the
24 goods as warranted.
25 136. Privity is not required as to Defendant because the Products contained a
26 dangerous toxin. As the known end purchaser, Plaintiff is also a third-party
27 beneficiary of the implied warranty of merchantability.
28

– 26 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 28 of 38

1 137. Defendant’s attempts to disclaim or limit the implied warranty of

2 merchantability vis-à-vis consumers are unconscionable and unenforceable.
3 Specifically, Defendant’s warranty limitations are unenforceable because Defendant
4 knowingly sold a defective product without informing consumers about the toxins.
5 138. A gross disparity in bargaining power existed between Defendant and
6 Class Members, as only Defendant knew or should have known that the Products
7 contained toxins at the time of sale and that the devices were not of merchantable
8 quality.
9 139. As a direct and proximate cause of Defendant’s breach of the implied
10 warranty, Plaintiff and Class Members have been injured and harmed because: (a)
GOOD GUSTAFSON AUMAIS LLP

11 they would not have purchased the Products on the same terms if they knew that the
12 Products contained the toxins, making it unsafe for consumer use; and (b) the
13 Products do not have the characteristics, uses, or benefits as promised by Defendant.
14 COUNT VII
15 Violation Of The Magnuson-Moss Warranty Act,
16 15 U.S.C. §§ 2301, et seq.
17 (On Behalf of the Nationwide Class)
18 140. Plaintiff incorporates by reference and re-allege herein all paragraphs
19 alleged above.
20 141. Plaintiff brings this claim individually and on behalf of the members of
21 the proposed Classes against Defendant.
22 142. The Products are consumer products as defined in 15 U.S.C. § 2301.
23 143. Plaintiff and the Class Members are consumers as defined in 15 U.S.C. §
24 2301.
25 144. Defendant is a supplier and warrantor as defined in 15 U.S.C. § 2301.
26 145. In connection with the marketing and sale of the Products, Defendant
27 impliedly warranted that the Products was fit for use. The Products were not fit for
28 use due to the presence of toxic substances described in the allegations above.

– 27 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 29 of 38

1 146. By reason of Defendant’s breach of warranties, Defendant violated the

2 statutory rights due to Plaintiff and the Class Members pursuant to the Magnuson-
3 Moss Warranty Act, 15 U.S.C. §§ 2301, et seq., thereby damaging Plaintiff and the
4 Class Members.
5 147. Plaintiff and the Class Members were injured as a direct and proximate
6 result of Defendant’s breach because they would not have purchased the Products if
7 they knew the truth about the toxic nature of the Products.
8 148. Despite notice by Plaintiff and the Class Members to Defendant of the
9 toxic nature of the Products, Defendant did not replace or repair the defective
10 Products. Instead, the costs of the defects were borne by consumers.
GOOD GUSTAFSON AUMAIS LLP

11 149. As a direct and proximate result of Defendant’s breach of implied

12 warranties pursuant to 15 U.S.C. § 2310(d)(1), Plaintiff and Class Members have
13 suffered damages in an amount to be proven at trial.
14 150. The amount in controversy for the Plaintiff’s and Class Members’
15 individual claims meets or exceeds the sum of $25. The total amount in controversy of
16 this action in sum exceeds $50,000, exclusive of interest and costs, computed on the
17 basis of all claims to be determined in this lawsuit.
18 151. Plaintiff and Class Members are entitled to recover damages as a result
19 of Defendant’s breach of warranties.
20 152. Plaintiff and Class Members are also entitled to seek costs and expenses,
21 including attorneys’ fees, under the MMWA. 15 U.S.C. § 2310(d)(2).
22
COUNT VIII
23
Unjust Enrichment
24
(On Behalf of the Nationwide Class)
25
153. Plaintiff incorporates by reference and re-alleges herein all paragraphs
26
alleged above.
27
28

– 28 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 30 of 38

1 154. Plaintiff brings this claim individually and on behalf of the members of
2 the proposed Classes against Defendant.
3 155. “Although there are numerous permutations of the elements of the
4 unjust enrichment cause of action in the various states, there are few real differences.
5 In all states, the focus of an unjust enrichment claim is whether the defendant was
6 unjustly enriched. At the core of each state’s law are two fundamental elements—the
7 defendant received a benefit from the plaintiff and it would be inequitable for the
8 defendant to retain that benefit without compensating the plaintiff. The focus of the
9 inquiry is the same in each state.” In re Mercedes-Benz Tele Aid Contract Litig., 257
10 F.R.D. 46, 58 (D.N.J. Apr. 24, 2009) (quoting Powers v. Lycoming Engines, 245 F.R.D.
GOOD GUSTAFSON AUMAIS LLP

11 226, 231 (E.D. Pa. 2007)).

12 156. At all times relevant hereto, Defendant deceptively marketed,
13 advertised, and sold merchandise to Plaintiff and the Classes.
14 157. The Products purchased by Plaintiff and the Class Members did not
15 provide the promised performance and instead contained toxic substances.
16 158. Plaintiff and Class Members conferred a benefit on Defendant by
17 purchasing the Products and by paying a price premium for them.
18 159. Defendant has knowledge of such benefits.
19 160. Defendant has been unjustly enriched in retaining the revenues derived
20 from Plaintiff’s and Class Members’ purchases of the Product, which retention under
21 these circumstances is unjust and inequitable because Defendant misrepresented
22 that the Product (i) would not contain toxic substances and (ii) is generally recognized
23 as safe. This misrepresentation caused injuries to Plaintiff and Class Members
24 because they would not have purchased the Products if the true facts regarding the
25 Products were known.
26 161. Because Defendant’s retention of the non-gratuitous benefit conferred on
27 it by Plaintiff and Class Members is unjust and inequitable, Defendant must pay
28

– 29 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 31 of 38

1 restitution to Plaintiff and the Class Members for their unjust enrichment, as ordered
2 by the Court.
3 PRAYER FOR RELIEF
4 WHEREFORE, Plaintiff, on behalf of themselves and other members of the
5 proposed Class herein, prays for judgment and relief on all of the legal claims as
6 follows:
7
A. Certification of the Class, certifying Plaintiff as representatives of the
8
Class, and designating Plaintiff’s counsel for the Class;
9
B. A declaration that Defendant has committed the violations alleged
10 herein;
GOOD GUSTAFSON AUMAIS LLP

11
C. A declaration that Defendant has committed that Defendant’s actions
12 are fraudulent, deceptive, and misleading as alleged herein;

13 D. For restitution and disgorgement pursuant to, without limitation, the

California Business & Professions Code §§ 17200, et seq. and Cal Civ.
14
Code § 1780;
15
E. For declaratory and injunctive relief pursuant to, without limitation, the
16 California Business & Professions Code §§ 17200, et seq. and 17500, et
seq.;
17
18 F. An award of compensatory damages, the amount of which is to be
determined at trial;
19
20 G. For punitive damages;

21 H. For interest at the legal rate on the foregoing sums;

22 I. For statutory damages;

23
J. For attorneys’ fees;
24
K. For costs of suit incurred; and
25
26 L. For such further relief as this Court may deem just and proper.

27
JURY TRIAL DEMAND
28
Plaintiff demands a jury trial on all causes of action so triable.
– 30 –
CLASS ACTION COMPLAINT
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 32 of 38

1 Dated: November 22, 2022

Good Gustafson Aumais LLP
2
3 /s/ J. Ryan Gustafson
J. Ryan Gustafson (Cal. Bar No. 220802)
4 2330 Westwood Blvd., No. 103
Los Angeles, CA 90064
5
Tel: (310) 274-4663
6 jrg@[Link]

7
SHENAQ PC
8
Amir Shenaq, Esq.*
9 3500 Lenox Road, Ste. 1500
Atlanta, GA 30326
10 Tel: (888) 909-9993
GOOD GUSTAFSON AUMAIS LLP

amir@[Link]
11
12
THE KEETON FIRM LLC
13 Steffan T. Keeton, Esq.*
14 100 S Commons Ste 102
Pittsburgh PA 15212
15 Tel: (888) 412-5291
stkeeton@[Link]
16
17 *Pro hac vice forthcoming

18 Counsel for Plaintiff and the Proposed

Classes
19
20
21
22
23
24
25
26
27
28

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CLASS ACTION COMPLAINT
Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 33 of 38

EXHIBIT A
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 34 of 38

The safety notice from The Laundress covers products listed in the table below with the following lot
codes: 
• 9-digit code starting with a letter: Last four digits are in the range of 1001-2259 
• 9-digit code starting with a number: First five digits are in the range of 21001-22259 

Item Description  UPC  Size / Contents 

Number 10 Detergent Packet  None  0.5 fl oz 

Fabric Conditioner Baby Packet  857060005229  0.5 fl oz 
Baby Detergent Packet  857060005205  0.5 fl oz 
All Purpose Bleach Alternative Packet  None  0.5 fl oz 
Fabric Conditioner Classic Paquette  857060005236  0.5 fl oz 
Delicate Lady Wash Packet  None  0.5 fl oz 
Denim Wash Packet  857060005212  0.5 fl oz 
Le Labo Rose 31 Packet  857060005304  0.5 fl oz 
Le Labo Santal 33 Packet  857060005298  0.5 fl oz 
Signature Detergent Classic Packet  857060005168  0.5 fl oz 
Sport Detergent Packet  857060005274  0.5 fl oz 
Stain Solution Packet  857060005175  0.5 fl oz 
Wool & Cashmere Packet   857060005199  0.5 fl oz 
#723 Detergent 2 oz  858114008869  2 fl oz 
Artisan Detergent 2 oz  858114008883  2 fl oz 
John Mayer Way Out West 2 fl oz  858114008760  2 fl oz 
Kith Signature Detergent 2oz  None  2 fl oz 
Baby Detergent 2 oz  859675001238  2 fl oz 
Fabric Conditioner Baby 2 fl oz  None  2 fl oz 
Wool & Cashmere Shampoo 2 fl oz  859675001252  2 fl oz 
All Purpose Cleaning Concentrate  2oz  858114008777  2 fl oz 
Isle Detergent 2 fl oz   858114008814  2 fl oz 
Delicate Lady Wash 2 fl oz  859675001245  2 fl oz 
Signature Detergent Classic 2 fl oz  858114008357  2 fl oz 
Number 10 Detergent 2 oz  858114008876  2 fl oz 
Stain Solution 2 fl oz  859675001320  2 fl oz 
Denim Wash 2 fl oz  859675001955  2 fl oz 
Sport Detergent 2oz  857060005052  2 fl oz 
John Mayer Out West Detergent 2 fl oz  None  2 fl oz 
Le Labo Rose Signature Detergent 2 fl oz  850041104096  2 fl oz 
#723 Detergent 8 fl oz  858114008418  8 fl oz 
Artisan Detergent 8 oz  858114008654  8 fl oz 
Wool & Cashmere Shampoo 8 fl oz  858114008708  8 fl oz 
Surface Cleaner 8 fl oz  858114008951  8 fl oz 
Dish Detergent 8 fl oz  858114008982  8 fl oz 
Glass & Mirror Cleaner 8 fl oz  858114008968  8 fl oz 
Delicate Lady Wash 8 fl oz  858114008692  8 fl oz 
Signature Detergent Classic 8 fl oz  858114008678  8 fl oz 
Stain Solution 8 fl oz  858114008685  8 fl oz 
#723 Fabric Conditioner 16 fl oz  858114008531  16 fl oz 
Wool & Cashmere Shampoo 16 fl oz  859675001054  16 fl oz 
Glass & Mirror Cleaner 16 fl oz  859675001207  16 fl oz 
Summer Fridays Detergent 16oz  850041104065  16 fl oz 
Fresh Wash Signature Detergent 32 fl oz  857060005922  32 fl oz 
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 35 of 38

Baby Detergent 32 fl oz  859675001030  32 fl oz 

Unscented Baby Detergent 32 oz  859675001665  32 fl oz 
Baby Detergent Unscented 32 fl oz  857060005076  32 fl oz 
Isle Detergent 32 fl oz   857060005922  32 fl oz 
Unscented/Fragrance-Free Detergent 32 fl 858114008838  32 fl oz 
oz 
Signature Detergent Classic 32oz  859675001009  32 fl oz 
Whites Detergent 32 fl oz  859675001016  32 fl oz 
Darks Detergent 32 fl oz  859675001023  32 fl oz 
Surface Cleaner - Flexpack 64 oz.  858114008517  64 fl oz 
Dish Detergent - Flexpack 64 oz.  858114008500  64 fl oz 
Signature Detergent Classic- Flexpack 64 858114008487  64 fl oz 
oz. 
Sport Detergent Flexpack 64 oz.  858114008494  64 fl oz 
Baby Detergent Gallon  857060005953  128 fl oz 
Signature Detergent Classic Gallon  857060005960  128 fl oz 
#723 Detergent 16 fl oz  858114008401  16 fl oz  
Fresh Wash Fabric Conditioner 16 fl oz  857060005939  16 fl oz  
Artisan Detergent 16 oz  858114008623  16 fl oz  
Fabric Conditioner Baby 16 fl oz  859675001597  16 fl oz  
Aromatherapy Associates Deep Relax 642498015014  16 fl oz  
Signature Detergent 16 fl oz 
Aromatherapy Associates Forest Therapy 642498015007  16 fl oz  
Signature Detergent 16 fl oz 
Surface Cleaner 16 fl oz  859675001719  16 fl oz  
All Purpose Cleaning Concentrate 16 fl oz  859675001689  16 fl oz  
Dish Detergent 16 fl oz  859675001887  16 fl oz  
John Mayer Out West Detergent 16 fl oz  857060005632  16 fl oz  
John Mayer Way Out West  Detergent 16 fl 858114008746  16 fl oz  
oz 
Kith Signature Detergent 16 fl oz  858114008920  16 fl oz  
Delicate Lady Wash 16 fl oz  859675001047  16 fl oz  
Le Labo Rose Signature Detergent 16 fl oz  859675001696  16 fl oz  
Le Labo Santal Signature Detergent 16 fl oz  859675001986  16 fl oz  
Unscented/Fragrance-Free Detergent 16 fl 859675001504  16 fl oz  
oz 
Jenni Kayne Signature Detergent 16 fl oz  None  16 fl oz  
Number 10 Detergent 16 fl oz  857060005045  16 fl oz  
Number 10 Fabric Conditioner 16 fl oz  857060005038  16 fl oz  
Fabric Conditioner Classic 16 fl oz  859675001061  16 fl oz  
Denim Wash 16 fl oz  859675001580  16 fl oz  
Stain Solution 16 fl oz  859675001603  16 fl oz  
Sport Detergent 16 fl oz  859675001917  16 fl oz  
Aromatherapy Associates Support Breathe 642498015021  16 fl oz  
Surface Cleaner 16 fl oz 
Aromatherapy Associates Support Breathe 642498015038  16 fl oz  
Dish Detergent 16 fl oz 
Summer Fridays Detergent 16oz  850041104065  16 fl oz  
The Laundress & Peruvian Connection None  16 fl oz 
Luxury Fibre Wash 16 oz 
The Laundress & Peruvian Connection None  2 fl oz 
Luxury Fibre Wash 2 oz 
Kits and Bundles that contain the impacted products above: 
All Purpose Bleach Alternative & Cleaning None  All Purpose Bleach Alternative 32 fl oz, All Purpose Cleaning
Concentrate Duo  Concentrate 16 fl oz 
Ultimate Stain Solving Kit  None  All Purpose Bleach Alternative 32 fl oz, Stain Solution 16 fl oz 
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 36 of 38

Stain Removal Essentials  None  All Purpose Bleach Alternative 32 fl oz, Stain Solution 16 fl oz, Stain
Brush, Wash & Stain Bar 
John Mayer Out West Detergent and Fabric None  All Purpose Bleach Alternative 32 fl oz, Stain Solution 16 fl oz, Wash
Fresh Boxed Gift Set  & Stain Bar, Stain Brush 
Home Cleaning Best Seller Kit  None  All Purpose Bleach Alternative 32 fl oz, Surface Cleaner 16 fl oz,
Glass & Mirror Cleaner 16 fl oz, Scented Vinegar 16 fl oz 
All Purpose Cleaning Concentrate Duo  859675001689  All Purpose Cleaning Concentrate 16 fl oz x2 
All Purpose Cleaning Concentrate Bulk (6 859675001689  All Purpose Cleaning Concentrate 16 fl oz x6 
units) 
All Purpose Cleaning Concentrate 16 fl oz None  All Purpose Cleaning Concentrate 16 fl oz, Glass Spray Bottle 
with Glass Bottle 
Spring Cleaning Bundle  None  All Purpose Cleaning Concentrate 16 fl oz, Scented Vinegar 16 fl oz,
All Purpose Bleach Alternative 32 fl oz, Signature Detergent 32 fl oz,
Stain Solution 16 fl oz, Stain Brush 
Aromatherapy Associates Deep Relax & None  Aromatherapy Associates Deep Relax Detergent 16 fl oz,
Forest Therapy Boxed Gift Set  Aromatherapy Associates Forest Therapy Detergent 16 fl oz 
Aromatherapy Associates Full Collection  None  Aromatherapy Associates Forest Therapy Detergent 16 fl oz, Deep
Relax Detergent 16 fl oz, Support Breathe Dish Detergent 16 fl oz,
Support Breathe Surface Cleaner 16 fl oz 
Aromatherapy Associates Support Breathe None  Aromatherapy Associates Support Breathe Surface Cleaner 16 fl oz,
Surface Cleaner & Dish Detergent Duo  Aromatherapy Associates Support Breathe Dish Detergent 16 fl oz 
Artisan Detergent and Candle Boxed Gift None  Artisan Detergent 16 fl oz, Artisan Candle 
Set 
Baby Detergent Duo  859675001030  Baby Detergent 32 fl oz x2 
Baby Detergent 32 fl oz Bulk (6 Units)  859675001030  Baby Detergent 32 fl oz x6 
Baby Detergent & Fabric Conditioner Duo  None  Baby Detergent 32 fl oz, Baby Fabric Conditioner 16 fl oz 
New Parent Kit  None  Baby Detergent 32 fl oz, Baby Fabric Conditioner 16 fl oz, Baby
Fabric Fresh 4 fl oz, All Purpose Bleach Alternative 32 fl oz, Stain
Solution 16 fl oz 
Baby Detergent & Fabric Fresh Duo  None  Baby Detergent 32 fl oz, Baby Fabric Fresh 4 fl oz 
Fabric Conditioner Baby Duo  859675001597  Baby Fabric Conditioner 16 fl oz x2 
Fabric Conditioner- Baby Bulk (6 Units)  859675001597  Baby Fabric Conditioner 16 fl oz x6 
On the Spot Holiday Edition  None  Classic Fabric Fresh 2 fl oz, Crease Release 2 fl oz, Static Solution 2 fl
oz, Holiday Wash & Stain Bar, Stain Solution 2 fl oz, Gift Bag 
On The Spot Kit  859675001542  Classic Fabric Fresh 2 fl oz, Crease Release 2 fl oz, Static Solution 2 fl
oz, Wash & Stain Bar, Stain Solution Packet 2 fl oz, Stain Solution
Packet 2 fl oz 
Denim Wash & Fabric Fresh Classic Duo  None  Classic Fabric Fresh 8 fl oz, Denim Wash 16 fl oz 
Darks Detergent Duo  859675001023  Darks Detergent 32 fl oz x2 
Darks Detergent Bulk (6 Units)  859675001023  Darks Detergent 32 fl oz x6 
Darks Detergent & Fabric Fresh Duo  None  Darks Detergent 32 fl oz, Classic Fabric Fresh 8 fl oz 
Darks Detergent & Fabric Conditioner Duo  None  Darks Detergent 32 fl oz, Fabric Conditioner Classic 16 fl oz 
Delicate Kit Holiday Edition  None  Delicate Spray 4 fl oz, Delicate Wash 16 fl oz, Mesh Bag Bundle,
Holiday Wash & Stain Bar 
Delicate Wash Duo  859675001047  Delicate Wash 16 fl oz x2 
Delicate Wash Bulk (6 Units)  859675001047  Delicate Wash 16 fl oz x6 
Delicate Wash & Spray Duo  None  Delicate Wash 16 fl oz, Delicate Spray 4 fl oz 
Delicate Kit  None  Delicate Wash 16 fl oz, Delicate Spray 4 fl oz, Wash & Stain Bar,
Mesh Bag Bundle 
Delicate Wash & Mesh Washing Bag Duo  None  Delicate Wash 16 fl oz, Mesh Bag Bundle 
Clean Clutch  None  Delicate Wash 2 fl oz, Stain Solution 2 fl oz, Classic Fabric Fresh 2 fl
oz, Crease Release 2 fl oz 
Denim Wash Bulk (6 Units)  859675001580  Denim Wash 16 fl oz x6 
Denim Kit  None  Denim Wash 16 fl oz, Classic Fabric Fresh 8 fl oz, Stain Solution 16 fl
oz, Mesh Bag Bundle 
Denim Gift Bag   None  Denim Wash 16 fl oz, Stain Solution 16 fl oz, Classic Fabric Fresh 8 fl
oz, Gift Bag 
Dish Detergent Bulk (6 Units)  859675001887  Dish Detergent 16 fl oz x6 
Dish Detergent Duo  859675001887  Dish Detergent 16 fl oz, Dish Detergent 16 fl oz 
Kitchen Clean Duo  None  Dish Detergent 16 fl oz, Kitchen Soap Bar 
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 37 of 38

Dish Detergent Flex Pack with 16 oz Glass None  Dish Detergent Flex Pack 64 fl oz, Glass Pump Bottle 
Pump 
Fabric Conditioner Classic Duo  859675001061  Fabric Conditioner Classic 16 fl oz x2 
Fabric Conditioner Bulk (6 units)  859675001061  Fabric Conditioner Classic 16 fl oz x6 
Scent Discovery Kit  None  Gift Bag, Artisan Detergent 2 fl oz, Isle Detergent 2 fl oz, Signature
Detergent 2 fl oz, No. 723 Detergent 2 fl oz, No. 10 Detergent 2 fl
oz, Baby Detergent 2 fl oz 
Glass and Mirror Cleaner Duo  859675001207  Glass & Mirror Cleaner 16 fl oz x2 
Glass & Mirror Cleaner 16 fl oz Bulk (6 859675001207  Glass & Mirror Cleaner 16 fl oz x6 
units) 
Holiday Make Messes  None  Holiday Wash & Stain Bar, All Purpose Bleach Alternative 32 fl oz,
Stain Brush, Stain Solution 16 fl oz 
Mini Dry Clean Kit with Holiday Bar  None  Holiday Wash & Stain Bar, Classic Fabric Fresh 2 fl oz, Stain Solution
2 fl oz, Wool & Cashmere Shampoo 2 fl oz, Delicate Wash 2 fl oz,
Gift Bag 
Dry Cleaning Detox Kit Holiday Edition  None  Holiday Wash & Stain Bar, Mesh Bag Bundle, Wool & Cashmere
Shampoo 16 fl oz, Delicate Wash 16 fl oz 
Travel Pack  859675001337  Hotel Laundry Bag, Crease Release 2 fl oz, Classic Fabric Fresh 2 fl
oz, Delicate Wash 2 fl oz, Stain Solution 2 fl oz, Gift Bag 
Isle Signature Detergent 32 oz  857060005922  Isle Detergent 32 fl oz x6 
Isle Signature Detergent and Fabric Fresh  None  Isle Detergent 32 fl oz, Isle Fabric Fresh 8 fl oz 
John Mayer Out West Detergent and Fabric None  John Mayer Out West Fabric Fresh 8 fl oz, John Mayer Out West
Fresh Duo  Deteregent 16 fl oz 
John Mayer Way Out West Detergent and None  John Mayer Way Out West Deteregent 16 fl oz, John Mayer Way
Fabric Fresh Duo  Out West Fabric Fresh 8 fl oz 
Le Labo Rose and Le Labo Santal Duo  None  Le Labo Rose Detergent 16 fl oz, Le Labo Santal Detergent 16 fl oz 
Gift Set Le Labo Rose and Le Labo Santal  None  Le Labo Santal Detergent 16 fl oz, Le Labo Rose Detergent 16 fl oz 
Spotless Kit  None  Lint-Free Cleaning Cloths, Surface Cleaner 16 fl oz, Scented Vinegar
16 fl oz 
Dry Cleaning Detox Kit  None  Mesh Bag Bundle, Wool & Cashmere Shampoo 16 fl oz, Delicate
Wash 16 fl oz, Wash & Stain Bar 
Number 10 Gift Set Detergent and None  No. 10 Detergent 16 fl oz, No. 10 Fabric Conditioner 16 fl oz 
Conditioner Duo 
Number 10 Detergent and Conditioner None  No. 10 Detergent 16 fl oz, No. 10 Fabric Conditioner 16 fl oz 
Boxed Gift Set  
Number 10 Kit  None  No. 10 Fabric Fresh 8 fl oz, No. 10 Fabric Conditioner 16 fl oz, No. 10
Detergent 16 fl oz 
723 Detergent Bulk (6 units)  858114008401  No. 723 Detergent 16 fl oz x6 
723 Detergent and Conditioner Duo  None  No. 723 Detergent 16 fl oz, No. 723 Fabric Conditioner 16 fl oz 
723 Gift Set Detergent and Conditioner None  No. 723 Detergent 16 fl oz, No. 723 Fabric Conditioner 16 fl oz 
Boxed Gift Set 
723 Collection  None  No. 723 Detergent 16 fl oz, No. 723 Fabric Conditioner 16 fl oz, No.
723 Fabric Fresh 8 fl oz 
723 Gift Set Detergent and Fabric Fresh None  No. 723 Detergent 16 fl oz, No. 723 Fabric Fresh 8 fl oz 
Boxed Gift Set 
Scented Vinegar & Dish Detergent Duo  None  Scented Vinegar 16 fl oz, Dish Detergent 16 fl oz 
Pet Mess Kit  None  Scented Vinegar 16 fl oz, Stain Brush, Stain Solution 16 fl oz 
Home Cleaning Starter Kit  None  Scented Vinegar 8 fl oz, Surface Cleaner 8 fl oz, Dish Detergent 8 fl
oz, Glass & Mirror Cleaner 8 fl oz 
Home Cleaning Starter Kit - Holiday 2022  850041104188  Scented Vinegar 8 fl oz, Surface Cleaner 8 fl oz, Dish Detergent 8 fl
oz, Glass & Mirror Cleaner 8 fl oz 
Signature Detergent Duo  859675001009  Signature Detergent 32 fl oz x2 
Signature Detergent 32 fl oz Bulk (6 Units)  859675001009  Signature Detergent 32 fl oz x6 
Clean Break Kit  None  Signature Detergent 32 fl oz, All Purpose Bleach Alternative 32 fl oz,
Surface Cleaner 16 fl oz, Scented Vinegar 16 fl oz 
Best Sellers Kit  None  Signature Detergent 32 fl oz, Delicate Wash 16 fl oz, Sport
Detergent 16 fl oz, Wool & Cashmere Shampoo 16 fl oz 
Signature Detergent & Fabric Conditioner None  Signature Detergent 32 fl oz, Fabric Conditioner Classic 16 fl oz 
Duo 
Everyday Laundry Kit  None  Signature Detergent 32 fl oz, Stain Solution 16 fl oz, All Purpose
Bleach Alternative 32 fl oz, Classic Fabric Fresh 8 fl oz, Stain Brush 
 Case 1:22-cv-07468 Document 1 Filed 11/24/22 Page 38 of 38

The Pit Kit  None  Signature Detergent 32 fl oz, Stain Solution 16 fl oz, All Purpose
Bleach Alternative 32 fl oz, Stain Brush 
Holiday Gift Kit 2022  850041104157  Signature Detergent 8 fl oz, Stain Solution 2 fl oz, Delicate Wash 2 fl
oz, Wool & Cashmere Shampoo 2 fl oz 
Signature Detergent Flex Pack with 32 oz None  Signature Detergent Flex Pack 64 fl oz, Signature Detergent 32 fl oz 
Signature 
Sport Detergent Duo  859675001917  Sport Detergent 16 fl oz x2 
Sport Detergent 16 oz Bulk (6 units)  859675001917  Sport Detergent 16 fl oz x6 
Sport Detergent & Spray Duo  None  Sport Detergent 16 fl oz, Sport Spray 4 fl oz 
Sport Kit  None  Sport Detergent 16 fl oz, Sport Spray 4 fl oz, Mesh Bag Bundle, Wash
& Stain Bar 
Sport Detergent Refill Duo  None  Sport Detergent Flex Pack 64 fl oz, Sport Detergent 16 fl oz 
The Skimm Laundry Bundle  None  Stain Brush, Signature Detergent 32 fl oz, Fabric Conditioner Classic
16 fl oz, Stain Solution 16 fl oz 
Stain Solution Duo  859675001603  Stain Solution 16 fl oz x2 
Stain Solution Bulk (6 units)  859675001603  Stain Solution 16 fl oz x6 
Today Show Bundle 2020  None  Stain Solution 16 fl oz, Sport Detergent 16 fl oz, Wool & Cashmere
Shampoo 16 fl oz, Delicate Wash 16 fl oz 
Clean Collar Duo  None  Stain Solution 16 fl oz, Wash & Stain Bar 
Make Messes Kit  None  Stain Solution 16 fl oz, Wash & Stain Bar, All Purpose Bleach
Alternative 32 fl oz 
Winter Travel Trio  None  Stain Solution 2 fl oz, Wool & Cashmere Shampoo 2 fl oz, Signature
Detergent 2 fl oz 
Surface Cleaner Duo  859675001719  Surface Cleaner 16 fl oz x2 
Surface Cleaner Bulk (6 units)  859675001719  Surface Cleaner 16 fl oz x6 
Little Laundress Kit  None  Surface Cleaner 16 fl oz, Glass & Mirror Cleaner 16 fl oz, Dish
Detergent 16 fl oz, Scented Vinegar 16 fl oz 
Surface Cleaner Flex Pack with 16 oz Glass None  Surface Cleaner Flex Pack 64 fl oz, Glass Spray Bottle 
Bottle 
Unscented/Fragrance-Free Detergent 16 fl 859675001504  Unscented/Fragrance-Free Detergent 16 fl oz x6 
oz Bulk (6 units) 
Unscented/Fragrance-Free Detergent 32 oz 858114008838  Unscented/Fragrance-Free Detergent 32 fl oz x6 
Bulk (6 units) 
Dry Clean On-The-Go Kit  None  Wash & Stain Bar, Classic Fabric Fresh 2 fl oz, Stain Solution 2 fl oz,
Wool & Cashmere Shampoo 2 fl oz, Delicate Wash 2 fl oz, Gift Bag 
Laundry Essentials Pack  None  Wash & Stain Bar, Delicate Wash 2 fl oz, Classic Fabric Fresh 2 fl oz,
Wool & Cashmere Shampoo 2 fl oz, Stain Solution 2 fl oz, Gift Bag 
The Laundress Welcome Kit  None  Wash & Stain Bar, Signature Detergent 2 fl oz, Classic Fabric Fresh 2
fl oz, Crease Release 2 fl oz 
Whites Detergent Duo  859675001016  Whites Detergent 32 fl oz x2 
Whites Detergent 32 fl oz Bulk (6 units)  859675001016  Whites Detergent 32 fl oz x6 
Brighten Up Duo  None  Whites Detergent 32 fl oz, All Purpose Bleach Alternative 32 fl oz 
Whites and Darks Duo  None  Whites Detergent 32 fl oz, Darks Detergent 32 fl oz 
Seasonal Whites Detergent and Fabric None  Whites Detergent 32 fl oz, Fabric Conditioner Classic 16 fl oz 
Conditioner Duo 
Wool & Cashmere Shampoo 16 fl oz Bulk (6 859675001054  Wool & Cashmere Shampoo 16 fl oz x6 
units) 
Wool and Cashmere Kit  None  Wool & Cashmere Shampoo 16 fl oz, Stain Solution 16 fl oz, Wool &
Cashmere Spray 4 fl oz, Sweater Comb 
Wool & Cashmere Shampoo & Wool & None  Wool & Cashmere Shampoo 16 fl oz, Wool & Cashmere Spray 4 fl
Cashmere Spray Duo  oz 
Wool and Cashmere Kit   None  Wool & Cashmere Shampoo 16 fl oz, Wool & Cashmere Spray 4 fl
oz, Mesh Bag Bundle 
The Laundress Starter Kit  None  Wool & Cashmere Shampoo 8 fl oz, Delicate Wash 8 fl oz, Signature
Detergent 8 fl oz, Stain Solution 8 fl oz 
Laundry Starter Kit - Holiday 2022  850041104195  Wool & Cashmere Shampoo 8 fl oz, Delicate Wash 8 fl oz, Signature
Detergent 8 fl oz, Stain Solution 8 fl oz