45.  Plaintiffs bring this case as a class action pursuant to Federal Rule of Civil Procedure  23(a), (b)(2) and (b)(3) on behalf of themselves and a proposed class (the “California Class”)  defined as follows:  All California persons who, on or after June 13, 2015, purchased the Products  for personal, family, or household purposes.    46.  There are likely tens of thousands of class members in each class.  Each class is sufficiently  numerous such that joinder is impracticable.   5.  In 2014, the National Institutes of Health cautioned: “experts agree that Americans eat  and drink way too much sugar, and it’s contributing to the obesity epidemic.  Much of the sugar we  eat isn’t found naturally in food but is added during processing or preparation.”   https://newsinhealth.nih.gov/2014/10/sweet-stuff.    The NIH noted further: “[s]everal studies have  found a direct link between excess sugar consumption and obesity and cardiovascular problems  worldwide.”  Id.     52.  Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.   53.  Plaintiff brings this cause of action on behalf of the Class for violation of  California’s Consumers Legal Remedies Act, CAL. CIV. CODE § 1750 et seq. (the “CLRA”).   54.  This claim is for monetary relief and injunctive relief pursuant to California Civil  Code section 1782.   55.  Under the CLRA, “consumer” means “an individual who seeks or acquires, by  purchase or lease, any goods or services for personal, family, or household purposes.” CAL. CIV.  CODE § 1761(d).   56.  Plaintiff and the Class members are “consumers” under the CLRA.   57.  Under the CLRA, “person” means “an individual, partnership, corporation, limited  liability company, association, or other group, however organized.” Id. § 1761(c).   58.  Defendant is a “person” under the CLRA.   59.  Under the CLRA, “transaction” means “an agreement between a consumer and  another person, whether or not the agreement is a contract enforceable by action, and includes the  making of, and the performance pursuant to, that agreement.” Id. § 1761(e).   6.  There has long been a consensus among doctors and nutritionists that “[e]ating too  much sugar contributes to numerous health problems, including weight gain, Type 2 diabetes, dental  caries, metabolic syndrome and heart disease, and even indirectly to cancer because of certain  cancers’ relationship to obesity.”  http://www.chicagotribune.com/lifestyles/health/ct-sugar- addictive-20171218-story.html   60.  Defendant, on the one hand, and Plaintiff and the Class members, on the other hand,  engaged in “transactions” under the CLRA because, among other reasons, Defendant agreed to sell,  and pursuant to that agreement sold, the Products to Plaintiff and the Class members.   61.  Defendant’s actions, representations, omissions, and conduct have violated the  CLRA because they extend to transactions that are intended to result, or that have resulted, in the  sale of goods and services to consumers.    67.  Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.   68.  Plaintiff brings this cause of action on behalf of the Class for violation of  California’s False Advertising Law, CAL. BUS. & PROF. CODE § 17500 et seq. (the “FAL”).   69.  The FAL prohibits “mak[ing] any false or misleading advertising claim.”    7.  In addition, “there is emerging research that suggests high-sugar diets may increase  the risk of developing [dementia].”   http://theconversation.com/yes-too-much-sugar-is-bad-for-our- health-heres-what-the-science-says-92030.  B. As part of a societal trend toward consuming healthier foods and natural foods,  avoidance of added sugar has been and remains a significant consumer preference, with  consumers strongly favoring honey as a sugar substitute.   70.  As alleged herein, Defendant, in its labeling of its Products, makes “false [and]  misleading advertising claim[s],” as it deceives consumers as to the honey content and sugar content  of the Products.   71.  In reliance on these false and misleading advertising claims, Plaintiff and the  members of the Class purchased the Products.   72.  Defendant knew or should have known that its labeling and marketing of the Product  was likely to deceive consumers.   74.  Plaintiff repeats each and every allegation contained in the paragraphs above and  incorporates such allegations by reference herein.   75.  Plaintiff brings this cause of action on behalf of the Class for violation of the  unlawful, unfair, and fraudulent prongs of California’s Unfair Competition Law, CAL. BUS. & PROF.  CODE § 17200 et seq. (the “UCL”).   76.  The acts, omissions, misrepresentations, practices, and non-disclosures of Defendant,  as alleged herein, constitute “unlawful” business acts and practices in that they violate the Federal  Food, Drug, and Cosmetic Act (“FFDCA”) and its implementing regulations, including, at least, the  following sections:  -  21 U.S.C. § 343, which deems food misbranded when the label contains a  statement that is “false or misleading in any particular,” with “misleading”  defined to “take[] into account (among other things) not only representations  made or suggested by statement, word, design, device, or any combination  thereof, but also the extent to which the labeling or advertising fails to reveal  facts material”;  -  21 U.S.C. § 321(n), which states the nature of a false and misleading  advertisement;  -  21 C.F.R. § 101.18(b), which prohibits true statements about ingredients that  are misleading in light of the presence of other ingredients; and  -  21 C.F.R. § 102.5, which prohibits the naming of foods so as to create an  erroneous impression about the presence or absence of ingredient(s) or  component(s) therein.   8.  At least in part due to growing consumer awareness of health problems caused by  excessive sugar consumption, in recent years consumers have shown a distinct preference for products  with little or no added sugar as well as for “natural” products.      9.  In August, 2016, an article in “Prepared Foods” magazine noted that “[o]ngoing  concerns about obesity and sugar intake have driven interest in reduced sugar and diet drinks in recent  years.”   https://www.preparedfoods.com/articles/118643-trends-in-sugar-reduction-and-natural- sweeteners.   A.    The negative health effects of consuming excessive amounts of sugar    Violation of California’s Consumers Legal Remedies Act,  CAL. CIV. CODE § 1750 et seq.  On Behalf of the Class   Violation of California’s False Advertising Law,  CAL. BUS. & PROF. CODE § 17500 et seq.  On Behalf of the Class   Violation of California’s Unfair Competition Law,  CAL. BUS. & PROF. CODE § 17200 et seq.  Unlawful, Unfair, and Fraudulent Prongs  On Behalf of the Class  