13.  On information and belief, Defendants launched their Flavor God  seasoning business in 2012. Defendants first generated sales by selling their  seasonings at farmer’s markets. On information and belief, Flavor God began  selling products to customers in the United States through its website  (https://flavorgod.com) by at least January 1, 2014, and now exclusively sell their  Flavor God-branded seasonings, rubs, and other products online. Today,  Defendants market, sell, and ship their products worldwide.   14.  Flavor God makes a wide variety of flavored seasonings including  Lemon & Garlic, Chipotle, Italian Zest, Garlic Lover’s, and Everything. In total,  Defendants make 18 different flavors of seasonings. In addition to their seasonings,  Defendants make “toppers,” which are flavored powders meant to be added to a  completed meal to infuse a different flavor into the meal. Defendants make six  topper flavors including Buttery Cinnamon Roll, Chocolate Donut, Gingerbread  Cookie, and Pumpkin Pie. Defendants also make three rubs for seasoning meats  and two flavors of salt.   37.  Plaintiff brings this action on behalf of himself and all persons  similarly situated pursuant to Rule 23(a), (b)(2), and (b)(3) of the Federal Rules of  Civil Procedure and seeks certification of the following class:  All persons in the United States who purchased one or more Flavor  God products from https://flavorgod.com/ between November 30,  2016 through the present (the “Class Period”) at a discount from a  higher reference price and who have not received a refund or credit  for their purchase(s).   38. The above-described class of persons shall hereafter be referred to as  the “Class.” Excluded from the Class are any and all past or present officers,  directors, or employees of Defendants, any judge who presides over this action,  and any partner or employee of Class Counsel. Plaintiff reserves the right to  expand, limit, modify, or amend this class definition, including the addition of one  or more subclasses, in connection with his motion for class certification, or at any  other time, based upon, inter alia, changing circumstances and/or new facts  obtained during discovery.   A. Company Background  