19.  Whey is a complete protein source, which means it contains all the  essential amino acids the human body needs to build protein-based compounds such as  muscle tissue, skin, fingernails, hair and enzymes. Daily protein needs depend on one’s  size, gender and activity levels, although they likely amount to somewhere between 46  grams and 56 grams. For elite athletes, daily protein requirements are well over 100  grams, a need that is difficult to fulfill with simply ingesting food.  Others may also  need to supplement their protein intake for reasons of ill health.    20.  Whey protein powder is especially rich in branched-chain amino acids --  leucine, isoleucine and valine -- which are metabolized directly within the muscles as  opposed to being processed in the liver first.     56.  Plaintiff incorporates all preceding factual allegations as if fully set forth  herein.    57.  Plaintiff and each member of the Class is a “Consumer” as that term is  defined by Cal. Civ. Code § 1761(d).    58.  The Products are a “Good” as that term is defined by Cal. Civ. Code §  1761(a).   59.  Defendant is a “Person” as defined by Cal. Civ. Code § 1761(c).   60.  The transaction(s) involved here are “Transaction(s)” as defined by Cal.  Civ. Code § 1761(e).   61.  Plaintiff and members of the Class are Consumers who purchased the  Products for personal use within the applicable statute of limitations period.   62.  Plaintiff has standing to pursue this cause of action because Plaintiff has  suffered injury-in-fact and has lost money or property as a result of Defendant’s actions  as set forth here.   63.  Plaintiff and Class members purchased the Products in reliance on  Defendant’s labeling and marketing claims.   71.  Plaintiff incorporates all preceding factual allegations as if fully set forth  herein.    72.  Plaintiff and the Class have standing to pursue a cause of action for false  advertising under Cal. Bus. & Prof. Code §17500, et seq., because Plaintiff and  members of the Class have suffered an injury-in-fact and lost money as a result of  Defendant’s actions as set forth herein.   73.  Defendant labeled, advertised, marketed, and otherwise disseminated  misleading information to the public through the product labels.   74.  Defendant continues to disseminate such statements.   75.  Defendant’s statements are misleading.   76.  Defendant knows that these statements are misleading, or could have  discovered their misleading nature with the exercise of reasonable care.   77.  Plaintiff and Class members relied on Defendant’s marketing and labeling.   78.  Defendant’s actions violate Cal. Bus. & Prof. Code § 17500, et seq.   79.  As a direct and proximate result of Defendant’s actions, as set forth herein,  Defendant has received ill-gotten gains and/or profits, including but not limited to  money from Plaintiff and Class members who paid for the Products. Therefore,  Defendant has been unjustly enriched.   82.  Plaintiff incorporates all preceding factual allegations as if fully set forth  herein.   83.  Plaintiff and the Class have standing to pursue a cause of action for false  advertising under Cal. Bus. & Prof. Code § 17200, et seq., because Plaintiff and  members of the Class have suffered an injury-in-fact and lost money as a result of  Defendant’s actions as set forth herein.   84.  Defendant’s actions as described herein constitute unfair competition  within the meaning of Cal. Bus. & Prof. Code § 17200, in that Defendant has engaged  in deceptive business practices by falsely advertising the content of whey protein in the  Products.    85.  Defendant’s actions as described herein constitute unfair competition  within the meaning of Cal. Bus. & Prof. Code § 17200, in that Defendant has engaged  in unlawful, unfair and deceptive business practices by deceiving consumers and  violating California’s Sherman Food Drug & Cosmetic Act and California’s Consumer  Legal Remedies Act.   86.  Defendant’s actions as described herein constitute unfair competition  within the meaning of Cal. Bus. & Prof. Code § 17200, on the additional grounds that  Defendant has failed to properly label the Products in accordance with 21 C.F.R. § 101,  et seq.   The Differences Between Whey Protein & Free Form Amino Acids   Violation of the False Advertising Law, Cal. Bus. & Prof. Code § 17500, et seq.   (On Behalf of the California Subclass)   Violation of the Consumers Legal Remedies Act, Cal. Civ. Code §1750, et. seq.   (On Behalf of the California Subclass)   Violation of the Unfair Competition Law, Cal. Bus. & Prof. Code § 17200, et seq.  (On Behalf of the California Subclass Members)  