 (Unfair and Deceptive Acts and Practices in   Violation of the California Consumers Legal Remedies Act,   on Behalf of the California Subclass)    (Violations of California’s False Advertising Law,  on Behalf of the California Subclass)   (Violation of California’s Unfair Competition Law,  on Behalf of the California Subclass)   71.  Plaintiff Cooper incorporates by reference and realleges herein all paragraphs  alleged above.   72.  This cause of action is brought pursuant to California’s Consumers Legal  Remedies Act, Cal. Civ. Code §§ 1750-1785 (the “CLRA”).   73.  Plaintiff Cooper and the other members of the California Subclass are  “consumers,” as the term is defined by California Civil Code § 1761(d), because they bought  the Products for personal, family, or household purposes.    74.  Plaintiff Cooper, the other members of the California Subclass, and Defendant  have engaged in “transactions,” as that term is defined by California Civil Code §1761(e).   82.  Plaintiff Cooper incorporates by reference and realleges herein all paragraphs  alleged above.   83.  As alleged more fully above, Defendant has falsely advertised the Products by  falsely claiming that the Products are unqualifiedly naturally derived, green, and  environmentally sound.   84.  At all material times, Defendant engaged in a scheme of offering the Products  for sale to Plaintiff Cooper and the other members of the California Subclass within the State  of California and nationwide through, inter alia, commercial marketing and advertising, the  Internet, the Products’ packaging and labeling, and other promotional materials and offers for  sale of the Products.   85.  The misrepresentations and non-disclosures by Defendant of the material facts  detailed above constitute false and misleading advertising, and therefore constitute a violation  of Cal. Bus. & Prof. Code § 17500, et seq.   86.  Said advertisements and inducements were made within the State of California  and come within the definition of advertising contained in the FAL in that such promotional  materials were intended as inducements to purchase the Products and are statements  disseminated by Defendant to Plaintiff Cooper and the other California Subclass members that  were intended to reach Plaintiff Cooper and the other California Subclass members.  Defendant knew, or in the exercise of reasonable care, should have known, that these  representations were misleading and deceptive.   87.  The above acts of Defendant did and were likely to deceive reasonable  consumers, including Plaintiff Cooper and the other members of the California Subclass, by  obfuscating the nature, quality, and ingredients of the Products, in violation of the  “misleading” prong of the FAL.    90.  Plaintiff Cooper incorporates by reference and realleges herein all paragraphs  alleged above.   91.  By committing the acts and practices alleged herein, Defendant has violated  California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200-17210, as to  the California Subclass as a whole, by engaging in unlawful, fraudulent, and unfair conduct.   92.  Defendant has violated the UCL’s proscription against engaging in unlawful  conduct as a result of:   (a) violations of the CLRA, Cal. Civ. Code § 1770(a)(5), (a)(7), and (a)(9), as  alleged above; and  (b) violations of the FAL, Cal. Bus. & Prof. Code § 17500 et seq., as alleged  above.   93.  Defendant’s acts and practices described above also violate the UCL’s  proscription against engaging in fraudulent conduct.   A. The Products  