 I.  Glyphosate and the Enzyme It Targets   28.  Glyphosate, the active ingredient in Roundup, is a non-selective biocide, meaning  that it will kill most plants and many simple organisms. Unlike selective biocides, glyphosate  cannot be used on most conventional lawns, as it would kill grass that has not been genetically  modified.    57.  Plaintiffs re-allege and incorporate by reference the allegations set forth in the  preceding paragraphs of this Complaint.   58.  This action is maintainable as a class action pursuant to Rule 23(a) and 23(b)(3)  of the Federal Rules of Civil Procedure.   59.  Plaintiffs bring this action on behalf of a National Class defined as follows:  National Class: All consumers who purchased Roundup Products, containing the  statement “Glyphosate targets an enzyme found in plants but not in people or  pets” on the labeling, in the United States within the applicable statute of  limitations.   71.  All of the foregoing paragraphs are re-alleged as if fully set forth herein.   72.  Plaintiff Blitz brings this cause of action as a member of the Wisconsin Class.   80.  All of the foregoing paragraphs are re-alleged as if fully set forth herein.   81.  Plaintiff Blair brings this cause of action on behalf of members of the Illinois  Class.   82.  The Illinois Consumer Fraud and Deceptive Business Practices Act (“Illinois  CFA”) prohibits “unfair or deceptive acts or practices, including but not limited to the use or  employment of any deception, fraud, false pretense, false promise, misrepresentation . . . or the  use or employment of any practice described in Section 2 of the ‘Uniform Deceptive Trade  Practices Act’ [815 ILCS 510/2] . . . in the conduct of trade or commerce . . . whether any person  has in fact been misled, deceived or damaged thereby.” 815 ILCS 505/2.   83.  In using a false statement to market their Roundup Products, Defendants  employed deception, fraud, false pretense, false promise, and misrepresentation.   84.  Defendants violated 815 ILCS 505/2, by:   a.  Representing that Roundup Products have “characteristics, … benefits,  [and] quantities that they do not have,” 815 ILCS 510/2 (a)(5);  b.  Representing that Roundup Products “are of a particular standard, quality,  [and] grade” when “they are of another,” 815 ILCS 510/2 (a)(7);  c.  Labeling Roundup Products “with intent not to sell them as advertised,” 815  ILCS 510/2 (a)(9); and  d.  Engaging in “conduct which similarly creates a likelihood of confusion or  misunderstanding,” 815 ILCS 510/2 (a)(12).   91.  All of the foregoing paragraphs are re-alleged as if fully set forth herein.   92.  Plaintiff Chick brings this cause of action against Defendant Monsanto on behalf  of members of the California Class.   93.  This cause of action is brought pursuant to California’s Consumers Legal  Remedies Act, Cal. Civ. Code §§ 1750-1785 (the “CLRA”).   Breach of Express Warranty  169.  All of the foregoing paragraphs are re-alleged as if fully set forth herein.  170.  Plaintiffs bring this claim on behalf of the National Class and the various state  Classes set forth herein.  171.  Defendants provided Plaintiffs and members of the National Class with written  express warranties including, but not limited to, warranties that the glyphosate present in  Roundup “targets an enzyme found in plants but not in people or pets.”   172.  Plaintiffs and members of the National Class purchased Roundup Products  believing them to conform to the express warranties.   173.  Defendants breached these warranties.  174.  As a proximate result of the breach of warranties by Defendants, Plaintiffs and the  members of the National Class did not receive goods as warranted and did not receive the benefit  of the bargain. They have, therefore, been injured and have suffered damages in an amount to be  proven at trial.   Violations of California’s Consumers Legal Remedies Act   Violations of Wisconsin’s Deceptive Trade Practices Act  