12. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   13. Defendant manufactures, markets and/or sells Lands’ End apparel products  that have been represented on Defendant’s website as “Made in USA.”   14. Contrary to the representation, Defendant’s apparel products are wholly  and/or substantially manufactured or produced with component parts that are  manufactured outside of the United States.     15. Based upon information and belief, the offending Necktie purchased by  Plaintiff, and presumably all other offending Lands’ End products, are  wholly made and/or manufactured in China and/or include component parts  such as fabric and thread which are not in fact made or manufactured in the  U.S.A., as represented by Defendant.   16. Defendant markets, and continues to market, and represent to the general  public via its website that certain Lands’ End apparel products are “Made in  USA.”  In addition, Defendant fraudulently concealed the material facts at  issue in this matter by misrepresenting to the general public the true country  of origin of the offending apparel products. Defendant possesses superior  knowledge of the true facts that were not disclosed, thereby tolling the  running of any applicable statute of limitations.    27. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   28. Plaintiff brings this action individually and on behalf of all others similarly  situated (“the Class”), against Defendant, pursuant to Federal Rules of Civil  Procedure, Rules 23(a), 23(b)(1), 23(b)(2) and 23(b)(3).   29. Plaintiff represents, and is a member of the Class, consisting of:  All persons within the United States who purchased one  or more of Defendant’s apparel products, that were  advertised with a “Made in USA” country of origin  designation, that were foreign-made and/or composed of  foreign-made component parts, within the four years  prior to the filing of the Complaint.   30. Plaintiff represents, and is a member of the Subclass of the Class (“the  Subclass”), consisting of:   All persons within California who purchased one or more  of Defendant’s apparel products, that were advertised  with a “Made in USA” country of origin designation, that  were foreign-made and/or composed of foreign-made  component parts, within the four years prior to the filing  of the Complaint.   31. Defendant and its employees and/or agents are excluded from the Class and  the Subclass.  Plaintiff does not know the number of members in the Class,  but Plaintiff currently believes that there are hundreds of thousands, if not  more, members of the Class within the United States; and there are hundreds  of thousands of members of the Subclass located within the State of  California. This matter should therefore be certified as a Class action to  assist in the expeditious litigation of this matter.     42. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   43.  Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), establishes a federal  cause of action for, among other things, false advertising by:  (a)(1) Any person who, on or in connection with any  goods or services, or any container for goods, uses in  commerce any word, term, name, symbol, or device, or  any combination thereof, or any false designation of  origin, false or misleading description of fact, or false or  misleading representation of fact, which…(B) in  commercial advertising or promotion misrepresents the  nature, characteristics, qualities, or geographic origin of  his or her or another person’s goods, services, or  commercial activities, shall be liable in a civil action by  any person who believes that he or she is likely to be  damaged by such act.” [Emphasis added].   44.  Defendant violated Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a),  by making false and misleading statements and/or omissions of fact in  commercial advertisements by marketing and representing that its apparel  products are “Made in USA” when they actually foreign-made and/or  contain component parts that are manufactured outside of the United States.   45. Defendant’s false and/or misleading representations actually deceived and/or  had the capacity to deceive Plaintiff and the Class members whose decision  to purchase Defendant’s apparel products in reliance upon Defendant’s  representation that its apparel products are “Made in USA.”   56. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   67. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   68. Business & Professions Code § 17200 et seq. provides that unfair  competition means and includes “any unlawful, unfair or fraudulent business  act or practice and unfair, deceptive, untrue or misleading marketing.”   69. By and through Defendant’s conduct alleged in further detail above and  herein, Defendant engaged in conduct which constitutes unlawful, unfair,  and/or fraudulent business practices prohibited by Bus. & Prof. Code §  17200 et seq.     82. Plaintiff realleges and incorporates by reference all of the above paragraphs  of this Complaint as though fully stated herein.   83. Business & Professions Code § 17533.7 provides:  It is unlawful for any person, firm, corporation or  association to sell or offer for sale in this State any  merchandise on which merchandise or on its container  there appears the words “Made in U.S.A.,” “Made in  America, “ U.S.A.,” or similar words when the  merchandise or any article, unit, or part thereof, has been  entirely or substantially made, manufactured, or  produced outside of the United States.    VIOLATION OF BUSINESS & PROFESSIONS CODE  BUS. & PROF. CODE, SECTION 17533.7   VIOLATION OF CALIFORNIA CONSUMERS LEGAL REMEDIES ACT  CAL. CIV. CODE SECTION 1750, ET SEQ.   VIOLATION OF BUSINESS & PROFESSIONS CODE  BUS. & PROF. CODE, SECTION 17200, ET SEQ.   VIOLATION OF  SECTION 43(A) OF THE LANHAM ACT  15 U.S.C. § 1125, ET SEQ.  