13.  There are two types of sunscreen products: chemical-based and  mineral-based.  Chemical-based sunscreens contain various synthetic, chemical  active ingredients, such as Octisalate, Octocrylene, and Octinoxate, which protect  the skin by absorbing ultraviolet (“UV”) radiation and dissipating it as heat.2  Conversely, mineral-based sunscreens, also known as “physical” sunscreens, use  mineral active ingredients such as zinc oxide and/or titanium dioxide which cover  the skin and act as a physical barrier, deflecting and scattering UV radiation.   29.  Plaintiff brings this action on behalf of herself and all other similarly  situated consumers pursuant to Federal Rules of Civil Procedure 23(a), 23(b)(2), and  23(b)(3) and seeks certification of the following Class:  California-Only Class Action  All California consumers who, within the applicable statute of  limitations period until the date notice is disseminated, purchased the  Products.   Excluded from the Class are Defendant and its officers, directors, and  employees, and those who purchased the Products for the purpose of  resale.    30.  Numerosity.  The members of the Class are so numerous that joinder  of all members is impracticable.  Plaintiff is informed and believes that the proposed  Class contain thousands of purchasers of the Product who have been damaged by  Defendant’s conduct as alleged herein.  The precise number of Class members is  unknown to Plaintiff.     38.  Plaintiff repeats and re-alleges the allegations contained in the  paragraphs above, as if fully set forth herein.   39.  Plaintiff brings this claim individually and on behalf of the Class.   40.  As alleged herein, Plaintiff has suffered injury in fact and lost money or  property at the time of purchase as a result of Defendant’s conduct because she  purchased the Products in reliance on Defendant’s mineral-based representations,  but purchased Products that actually contained chemical active ingredients.   52.  Plaintiff repeats and incorporates by reference the allegations contained  in the paragraphs 1 through 37 above as if fully set forth herein.   53.  Plaintiff brings this claim individually and on behalf of the Class.   54.  This cause of action is brought pursuant to the Consumers Legal  Remedies Act, California Civil Code §§ 1750, et seq. (the “CLRA”).   55.  Plaintiff is a consumer as defined by California Civil Code § 1761(d).  The Products are “goods” within the meaning of the CLRA.   A. Chemical- vs. Mineral-Based Sunscreen Products   Violation of California Business & Professions Code §§ 17200, et seq.   Violations of the Consumers Legal Remedies Act –   Cal. Civ. Code §§ 1750 et seq.   