13.  Defendant manufactures, markets, and sells Crisco EVOO as Extra Virgin  Olive Oil.     14.  Plaintiff purchased and consumed the Crisco EVOO product multiple  times during 2017 and 2018 in reliance on Defendant’s advertising and labeling of the  “Crisco EVOO” product as Extra Virgin Olive Oil.  Specifically, Plaintiff and the Class  purchased the “Crisco “EVOO” product for the dual purpose of consuming it and  determining its authenticity as Extra Virgin Olive Oil.     15.  As noted above, extensive clinical testing conducted by a leading  laboratory – measuring the key variables of (1) Insoluble Impurities; (2) Free Fatty  Acid, (3) Peroxide Value (Acetic Acid-Isooctane Method), (4) Specific Extinction,  Ultraviolet Absorption, (5) Sensory analysis, (6) Copper (ICP-AES), and (7) Moisture  & Volatile Content – conclusively establishes that Crisco EVOO is not Extra Virgin  Olive Oil.  Accordingly, Defendant’s statements that the “Crisco EVOO” product is  Extra Virgin Olive Oil are false and misleading.     19.  Plaintiff brings this action as a class action pursuant to Rule 23 of the  Federal Rules of Civil Procedure on behalf of herself and the following class  (collectively, the “Class” or “Classes”), defined as:   All California residents who made retail purchases of Defendant’s Crisco  EVOO product during the applicable limitations period up to and including  final judgment in this action.   20.  The proposed Class excludes current and former officers and directors of  Defendant, Members of the immediate families of the officers and directors of  Defendant, Defendant’s legal representatives, heirs, successors, assigns, and any entity  in which it has or has had a controlling interest, and the judicial officer to whom this  lawsuit is assigned.    21.  Plaintiff reserves the right to revise the Class definition based on facts  learned in the course of litigating this matter.   22.  The Crisco EVOO products sold by Defendant suffer from illegal product  labeling and advertising.   33.  Plaintiff realleges and incorporates herein by reference the allegations  contained in all preceding paragraphs, and further alleges as follows:   34.  Plaintiff brings this claim individually and on behalf of the Class for  Defendant’s violations of California’s Consumer Legal Remedies Act (“CLRA”), Cal.  Civ. Code 1761(d).   35.  Plaintiff and the Class Members are consumers who purchased the Crisco  EVOO product for personal, family or household purposes. Plaintiff and the Class  Members are “consumers” as that term is defined by the CLRA in Cal. Civ. Code §  1761(d).    45.  Plaintiff realleges and incorporates herein by reference the allegations  contained in all preceding paragraphs, and further alleges as follows:   46.  Plaintiff has standing to pursue this cause of action because Plaintiff has  suffered injury in fact and has lost money as a result of Defendant’s actions as set forth  herein.  Specifically, Plaintiff purchased the Crisco EVOO product in reliance on  Defendant’s marketing claims.  Plaintiff later learned, on the basis of the testing  described herein, that the Crisco EVOO product was not in fact Extra Virgin Olive Oil.   47.  Defendant has engaged in false advertising as it has disseminated false  and/or misleading representations about the Crisco EVOO product.   48.  Defendant knew or should have known by exercising reasonable care that  its representations were false and/or misleading.  During the Class Period, Defendant  engaged in false advertising in violation of Cal. Bus. & Prof. Code §§ 17500, et seq., by  misrepresenting in its advertising and marketing of the Crisco EVOO product to  Plaintiff, Class members, and the consuming public that the Crisco EVOO product is  Extra Virgin Olive Oil.   49.  Each of the aforementioned representations alleged in this Complaint was  false and misleading because the Crisco EVOO product is not of the standard, quality  or grade advertised, and is in reality, not Extra Virgin Olive Oil.   54.  Plaintiff realleges and incorporates herein by reference the allegations  contained in all preceding paragraphs, and further alleges as follows:   55.  Plaintiff has standing to pursue this cause of action because Plaintiff has  suffered injury in fact and has lost money as a result of Defendant’s actions as set forth  herein.  Specifically, Plaintiff purchased the Crisco EVOO product in reliance on  Defendant’s marketing claims.  The product was not of the standard, quality and grade  advertised; specifically, it was not Extra Virgin Olive Oil.     65.  Plaintiff realleges and incorporates herein by reference the allegations  contained in all preceding paragraphs, and further alleges as follows:   66.  During the Class Period, Defendant misrepresented to consumers through  the advertising, marketing, and sale of the Crisco EVOO product that the Crisco EVOO  product was Extra Virgin Olive Oil.   67.  Defendant’s misrepresentations were false because the Crisco EVOO  product is not Extra Virgin Olive Oil.   68.  Defendant’s misrepresentations were material because a reasonable  consumer would attach importance to them in determining whether to purchase and  consume the Crisco EVOO product.     69.  Defendant’s material misrepresentations regarding the characteristics of  the Crisco EVOO product are false and made without reasonable grounds for believing  them to be true.   NEGLIGENT MISREPRESENTATION  (By Plaintiff and on Behalf of the Class Against Defendant)   UNLAWFUL, FRAUDULENT & UNFAIR BUSINESS PRACTICES  (CAL. BUS. & PROF. CODE §§ 17200, ET SEQ.)  (By Plaintiff and on Behalf of the Class Against Defendant)   VIOLATION OF CALIFORNIA’S CONSUMER LEGAL REMEDIES ACT,  (CAL. CIV. CODE § 1750, ET SEQ.)  (By Plaintiff and on Behalf of the Class Against Defendant)   VIOLATION OF CALIFORNIA’S FALSE ADVERTISING LAW  (CAL. BUS. & PROF. CODE §§ 17500, ET SEQ.)   (By Plaintiff and on Behalf of the Class Against Defendant)  