33.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   34.  Plaintiff Cesarini brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendants.   35.  This cause of action is brought pursuant to California’s Consumers Legal Remedies  Act, Cal. Civ. Code §§ I750-I785 (the “CLRA”).   36.  Plaintiff Cesarini 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.   43.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   44.  Plaintiff Cesarini brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendants.   45.  Defendants are subject to California’s Unfair Competition Law, Cal. Bus. & Prof.  Code §§ 17200, et seq.  The UCL provides, in pertinent part: “Unfair competition shall mean and  include unlawful, unfair or fraudulent business practices and unfair, deceptive, untrue or  misleading advertising ….”   50.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   51.  Plaintiff Cesarini brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendants.   52.  California’s False Advertising Law, Cal. Bus. & Prof. Code §§ 17500, et seq.,  makes it “unlawful for any person to make or disseminate or cause to be made or disseminated  before the public in this state, ... in any advertising device ... or in any other manner or means  whatever, including over the Internet, any statement, concerning ... personal property or services,  professional or otherwise, or performance or disposition thereof, which is untrue or misleading and  which is known, or which by the exercise of reasonable care should be known, to be untrue or  misleading.”   56.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   57.  Plaintiff brings this claim individually and on behalf of the proposed Class,  California Subclass against Defendants.   58.  Defendants, as the designer, manufacturer, marketer, distributor, and/or seller,  expressly warranted that the Products are “natural.”   59.  Defendants’ express warranties, and its affirmations of fact and promises made to  Plaintiff and the Class regarding the Products, became part of the basis of the bargain between  Defendants and Plaintiff and the Class, thereby creating an express warranty that the Products  would conform to those affirmations of fact, representations, promises, and descriptions.    60.  The Products do not conform to the express warranty because they contain  ingredients that are unnatural and synthetic.    63.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   64.  Plaintiff brings this claim individually and on behalf of the proposed Class,  California Subclass against Defendants.   65.  Plaintiff and class members conferred benefits on Defendants by purchasing the  Products.     66.  Defendants have been unjustly enriched in retaining the revenues derived from  Plaintiff’ and class members’ purchases of the Products.  Retention of those monies under these  circumstances is unjust and inequitable because of Defendants’ misrepresentations about the  Products, which caused injuries to Plaintiff and members of the classes because they would not  have purchased the Products if the true facts had been known.       67.  Because Defendants’ retention of the non-gratuitous benefits conferred on it by  Plaintiff and Class members is unjust and inequitable, Defendants must pay restitution to Plaintiff  and Class members for their unjust enrichment, as ordered by the Court.  68.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   Breach of Express Warranty  Plaintiff against Defendants   Fraud  Plaintiff against Defendants   Unjust Enrichment  Plaintiff against Defendants   Violation Of California’s Consumers Legal Remedies Act (“CLRA”),  California Civil Code §§ 1750, et seq.  (Injunctive Relief Only)  Plaintiff against Defendants   Violation Of California’s False Advertising Law (“FAL”),  California Business & Professions Code §§ 17500, et seq.  Plaintiff against Defendants   Violation Of California’s Unfair Competition Law (“UCL”),  California Business & Professions Code §§ 17200, et seq.  Plaintiff against Defendants  