71.  While reserving the right to amend, modify, or otherwise revise the Class  definition during class certification, pursuant to Federal Rule of Civil Procedure 23, plaintiff  seeks to represent a Class of all persons in the California who, on or after April 25, 2012,  purchased Healthy Request Gumbo for personal, family, or household use, and not for resale.   72.  The members of the proposed Class are so numerous that individual joinder of  all members is impracticable, and the disposition of the claims of all Class Members in a  single action will provide substantial benefits to the parties and Court.   78.  Plaintiff realleges and incorporates the allegations elsewhere in the Complaint  as if set forth in full herein.   79.  The UCL prohibits any “unlawful, unfair or fraudulent business act or practice.”  Cal. Bus. & Prof. Code § 17200.   80.  The acts, omissions, misrepresentations, practices, and non-disclosures of  Campbell as alleged herein constitute business acts and practices.  Fraudulent   81.  A statement or practice is fraudulent under the UCL if it is likely to deceive the  public, applying a reasonable consumer test.   82.  As set forth herein, Campbell’s health and wellness claims relating to its Healthy  Request Gumbo are likely to deceive reasonable consumers and the public in light of the  product’s artificial trans fat content.   83.  In addition, Campbell’s deceptive omission of material information it was  obligated to disclose, concerning both the presence and detrimental health effects of the  artificial trans fat in Healthy Request Gumbo, and its payment for the AHA certification, are  likely to deceive reasonable consumers, who would have acted differently if Campbell’s had  revealed such information.  Unlawful   91.  Plaintiff realleges and incorporates the allegations elsewhere in the Complaint  as if set forth in full herein.    92.  The FAL provides that “[i]t is unlawful for any person, firm, corporation or  association, or any employee thereof with intent directly or indirectly to dispose of real or  personal property or to perform services” to disseminate any statement “which is untrue or  misleading, and which is known, or which by the exercise of reasonable care should be  known, to be untrue or misleading.” Cal. Bus. & Prof. Code § 17500.   93.  As alleged herein, the advertisements, labeling, policies, acts, practices, and  omissions of Campbell relating to its Healthy Request Gumbo misled consumers acting  reasonably as to the healthfulness of the product.   94.  Plaintiff suffered injury in fact as a result of Campbell’s actions as set forth  herein because plaintiff purchased Healthy Request Gumbo in reliance on Campbell’s false  and misleading health and wellness marketing claims.   95.  Campbell’s business practices as alleged herein constitute unfair, deceptive,  untrue, and misleading advertising pursuant to the FAL because Campbell has advertised the  product in a manner that is untrue and misleading, which Campbell knew or reasonably  should have known, and omitted material information from its advertising.    96.  Campbell profited from its sales of the falsely and deceptively advertised  Healthy Request Gumbo to unwary consumers.    98.  Plaintiff realleges and incorporates the allegations elsewhere in the Complaint  as if set forth in full herein.   Breach of Express Warranties,  Cal. Com. Code § 2313(1)  105. Plaintiff realleges and incorporates the allegations elsewhere in the Complaint  as if set forth in full herein.   106. Through the Healthy Request Gumbo product labels, Campbell made  affirmations of fact or promises, and made descriptions of goods, that formed part of the basis  of the bargain, in that plaintiff and the Class purchased the product in reasonable reliance on  those statements. Cal. Com. Code § 2313(1).   107. These affirmations include “Healthy Request,” “Heart Healthy,” “COOKED  WITH CARE,” “AHA CERTIFIED,” “Meets Criteria for Heart-Healthy Food,” and “Made  with Lean Chicken Meat.”  108. Campbell breached its express warranties by selling a product that is not healthy,  and not heart healthy, but which in fact detrimentally affects cholesterol levels increasing risk  of CHD, stroke, and other morbidity.  109. That breach actually and proximately caused injury in the form of the lost  purchase price that plaintiff and Class members paid for Healthy Request Gumbo product.  110. As a result, plaintiff seeks, on behalf of himself and other Class Members, actual  damages arising as a result of Campbell’s breaches of express warranty.  I.  Artificial Trans Fat Causes Cardiovascular Disease, Type 2 Diabetes, and Other  Chronic Morbidity   Violations of the False Advertising Law (FAL),  Cal. Bus. & Prof. Code §§ 17500 et seq.    Violations of the Consumer Legal Remedies Act,  Cal. Civ. Code §§ 1750 et seq.    Violations of the Unfair Competition Law (UCL),  Cal. Bus. & Prof. Code §§ 17200 et seq.   