Negligent Misrepresentation  163.  Plaintiff repeats and realleges each of the above allegations as if fully set forth  herein.  164.  Defendant had a duty to disclose the presence of artificial ingredients, synthetic  additives, chemical preservatives or added artificial colors in Misbranded Tea Products.  165.  In making misrepresentations of fact and omissions of material fact to Plaintiff  and the other Class members about its  Misbranded Tea Products, Defendant failed to fulfill  its duties to disclose the material facts alleged above.  Among the direct and proximate causes  of said failure to disclose were the negligence and carelessness of Defendant.   166.  Plaintiff and the other Class members, as a direct and proximate cause of  Defendant’s breaches of its duties, reasonably relied upon such representations and omissions  to their detriment.   167.  By reason of the foregoing, Plaintiff and the other Class members have  suffered damages in an amount to be proved at trial, together with punitive damages. 