(Breach of Express Warranty)   (Fraud)   (Unjust Enrichment)   (Unfair and Deceptive Acts and Practices in Violation of the California  Consumers Legal Remedies Act)   (Violations of California’s False Advertising Law)   (Violation California’s Unfair Competition Law)   (Violation of the Magnuson-Moss Warranty Act,  15 U.S.C. §§ 2301, et seq.)   16.  Ms. Rosillo seeks to represent a class defined as all persons in the  United States who purchased California Baby Natural Bug Blend Bug Repellent (the  “Class”).  Excluded from the Class are persons who made such purchase for purpose  of resale.       17.  Ms. Rosillo also seeks to represent a subclass defined as all Class  members who purchased California Baby Natural Bug Blend Bug Repellent in  California (the “California Subclass”).   23.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   24.  Plaintiff brings this cause of action on behalf of herself and members of  the California Subclass.   25.  This cause of action is brought pursuant to California’s Consumers  Legal Remedies Act, Cal. Civ. Code §§ I750-I785 (the “CLRA”).   26.  Plaintiff and the other members of the California Subclass are  “consumers,” as the term is defined by California Civil Code § 1761(d), because they  bought the Product for personal, family, or household purposes.   27.  Plaintiff, the other members of the California Subclass, and Defendant  have engaged in “transactions,” as that term is defined by California Civil Code  § 1761(e).   28.  The conduct alleged in this Complaint constitutes unfair methods of  competition and unfair and deceptive acts and practices for the purpose of the  CLRA, and the conduct was undertaken by Defendant in transactions intended to  result in, and which did result in, the sale of goods to consumers.   29.  As alleged more fully above, Defendant has violated the CLRA by  falsely representing to Plaintiff and the other members of the California Subclass that  the Product is a “bug repellent” that “repels mosquitoes” when the product in fact  does not.   32.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   33.  Plaintiff brings this cause of action on behalf of herself and members of  the California Subclass.    34.  As alleged more fully above, Defendant has falsely advertised the  Product by falsely claiming that the Product is a “bug repellent” that “repels  mosquitoes” when the Product in fact does not.   35.  Plaintiff and the other members of the California Subclass have suffered  injury in fact and have lost money or property as a result of Defendant’s violations of  California’s False Advertising Law (“FAL”), Cal. Bus. & Prof. Code § 17500 et seq.  36.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   58.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   63.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   64.  Plaintiff brings this claim individually and on behalf of the members of  the proposed Class and California Subclass against Defendant.   65.  Plaintiff and Class members conferred benefits on Defendant by  purchasing the Product.   66.  Defendant has knowledge of such benefits.   67.  Defendant has been unjustly enriched in retaining the revenues derived  from Plaintiff’s and Class members’ purchases of the Product.  Retention of those  moneys under these circumstances is unjust and inequitable because Defendant  misrepresented that the Product is a “bug repellent” that “repels mosquitoes.”   69.  Plaintiff incorporates by reference and re-alleges herein all paragraphs  alleged above.   70.  Plaintiff brings this claim individually and on behalf of the members of  the proposed Class and California Subclass against Defendant.   71.  As discussed above, Defendant misrepresented on the Product’s  labeling that it is a “bug repellent” that “repels mosquitoes.”   72.  The false and misleading representations and omissions were made with  knowledge of their falsehood.  Defendant manufacturers all of its own products5 and  is undoubtedly aware of the Consumer Report study finding that the Product does not  work.  Nonetheless, Defendant continues to sell its ineffective and worthless Product  to unsuspecting consumers.   73.  The false and misleading representations were made by Defendant,  upon which Plaintiff and members of the proposed Class and California Subclass  reasonably and justifiably relied, and were intended to induce and actually induced  Plaintiff and members of the Class and California Subclass to purchase the Product.   74.  The fraudulent actions of Defendant caused damage to Plaintiff and  members of the Class and California Subclass, who are entitled to damages and other  legal and equitable relief as a result. 