16.  On September 18, 2017, Plaintiff opened a bag of Manna Pro  Products, LLC Select Series rabbit food in order to feed her rabbits. This bag was  clearly marked with a label stating “Contains No Corn: Helps Reduce The Risk of  Digestive Disorders.” The ingredients label similarly omitted any reference to corn  as an ingredient in the bag that Plaintiff had purchased.   17.    In fact, it is well known by rabbit breeders that corn is very   dangerous to feed to rabbit. Research has shown that including corn in the feed   can increase the risk of a toxic mold, which mimics rabies and can cause death to  the animals. It also is an unhealthy grain for these animals to ingest, causing them  to put on “bad” fat, and have increased health issues. For this reason, many  breeders and rabbit owners, such as Plaintiff, avoid any food with corn as an  ingredient.   18.   Plaintiff relief on the information presented to her prior to purchase  and at the point of sale when purchasing this brand of rabbit food for her  animals.   19.   On September 18, 2017, Plaintiff noticed in her recently purchased  bag of rabbit food, that there was, in fact, a lot of corn mixed in with the rabbit  pellets, despite the clear labeling.  Plaintiff picked out at least a half a cup of corn,  by hand, from this bag purporting to contain “No corn.”   23.   33.  Plaintiff brings this action, on behalf of herself and all others similarly  situated, and thus, seeks class certification under Federal Rule of Civil Procedure   60.  Plaintiff incorporates the above allegations by reference.   61.  Defendant’s conduct resulted from policies that Defendant  contrived, ratified, and implemented systematically throughout its retail  locations.    62.  Defendant’s conduct violates the UCL’s prohibition of fraudulent  business practices.   63.  To induce purchases of Defendant’s rabbit feed products, Defendant  made misleading statements in its advertisements that deceived Plaintiff and  Class members and reinforced its reasonable expectation and belief about the  quality of its ingredients.    64.  A reasonable consumer would expect that they would be able to rely  on the price information provided by Defendant.    80.  Plaintiff incorporates the above allegations by reference.   81.  Defendant violated the FAL by using false and misleading statements,  and material omissions, to promote the sale of Class Products.    82.  Class Products do not possess the level of quality or value that  Defendant promised.    83.  Defendant made uniform representations and material omissions that  communicated to Plaintiff and Class members that Class Products were of a  different quality and contained different ingredients.   84.  Defendant knew, or in the exercise of reasonable diligence should  have known, that its representations and omissions were false and misleading at  the time it made them. Defendant deliberately provided false representations and  omissions to deceive reasonable consumers.   85.  Defendant’s false and misleading advertising of Class Products  deceived the general public.   86.  As a direct and proximate result of Defendant’s misleading and false  advertising, Plaintiff and Class members have suffered injury-in-fact and have  lost money and property. Plaintiff and Class members reasonably relied to their  detriment on Defendant’s material misrepresentations and omissions that Class  Products would be of a certain quality, and contain certain ingredients.    Fraudulent Business Practices in Violation of the Unfair Competition Law,  Cal. Bus. & Prof. Code § 17200, et seq.  (On Behalf of the Class)   Violations of the False Advertising Law,  Cal. Bus. & Prof. Code § 17500, et seq.  (On Behalf of the Class)  