21.  Defendant markets, sells, and distributes personal-care products, including the  Products.     22.  Knowing that consumers like Plaintiff are increasingly interested in purchasing  products that do not contain potentially harmful artificial, synthetic ingredients and chemicals,  Defendant has sought to take advantage of this growing market by labeling certain products as  “Naturals.”    23.  Seeking to profit from the increasing demand for truly natural products,  Defendant sells a number of hair-care products under the name “Andalou Naturals,” including:  • Andalou Naturals Argan & Sweet Orange Shampoo;  • Andalou Naturals Lavender & Biotin Shampoo;  • Andalou Naturals Sunflower & Citrus Shampoo;  • Andalou Naturals Argan Stem Cells Shampoo;  • Andalou Naturals Argan & Sweet Orange Conditioner;  • Andalou Naturals Lavender & Biotin Conditioner;  • Andalou Naturals Sunflower & Citrus Conditioner; and  • Andalou Naturals Argan Stem Cells Conditioner.   25.    The labels of the Products are deceptive, unfair, false, and misleading in that  Defendant represents that the Products are “Naturals” when they in fact contain the Synthetic  Ingredients.     26.    The Products, however, are not “Naturals” because they contain the Synthetic  Ingredients.     28.  Sodium Benzoate is a synthetically-manufactured preservative that can cause  allergic and asthmatic reactions and may be linked to ADHD.  It can also be cancer-causing  when combined with Citric or Ascorbic Acid.    29.  Potassium Sorbate is a synthetically-manufactured preservative that may cause  allergic reactions, rashes, and irritation to the skin and eyes.    30.  Exthylexylglycerin is a synthetic skin-conditioning agent and preservative that  has been shown to be an allergen that can cause contact dermatitis.     31.  Because the Products contain the Synthetic Ingredients, two of which in  combination are believed to create a carcinogen, Defendant’s representations that the  Products are “Naturals” is deceptive, unfair, and false.    32.  The label of each of the Products is substantially similar.   33.  Like the FTC, Plaintiff and reasonable consumers reasonably believe and assume  that products labeled “Naturals” do not contain any artificial or synthetic substances.  Neither  Plaintiff nor any reasonable consumer would expect to find synthetic ingredients in Products  labeled and named “Naturals.”   34.  No reasonable consumer would know or should know when reviewing the  Products’ labels that Sodium Benzoate, Citric Acid, Potassium Sorbate, and Exthylexylglycerin  are not natural ingredients.    36.  Defendant’s misrepresentation constitutes unfair or deceptive acts or practices,  including but not limited to the use or employment of any deception, fraud, false pretense, false  promise, misrepresentation within the meaning of the ICFA.   37.  For class certification purposes, the term “Andalou Naturals Shampoo and  Conditioner Products” includes the following Products:  a.  Andalou Naturals Argan & Sweet Orange Shampoo;  b.  Andalou Naturals Lavender & Biotin Shampoo;  c.  Andalou Naturals Sunflower & Citrus Shampoo;  d.  Andalou Naturals Argan Stem Cells Shampoo;  e.  Andalou Naturals Argan & Sweet Orange Conditioner;  f.  Andalou Naturals Lavender & Biotin Conditioner;  g.  Andalou Naturals Sunflower & Citrus Conditioner; and  h.  Andalou Naturals Argan Stem Cells Conditioner.   38.  For class certification purposes, the “Class Period” is defined as the five years  preceding the filing of the Complaint in this case, which is August 10, 2011, through the present.   40.  Excluded from the Classes are: (a) federal, state, and/or local governments,  including, but not limited to, their departments, agencies, divisions, bureaus, boards, sections,  groups, counsels, and/or subdivisions; (b) any entity in which Defendant has a controlling  interest, to include, but not limited to, their legal representative, heirs, and successors; (c) all  persons who are presently in bankruptcy proceedings or who obtained a bankruptcy discharge in  the last three years; and (d) any judicial officer in the lawsuit and/or persons within the third  degree of consanguinity to such judge.   41.  Upon information and belief, the Classes consist of thousands of purchasers.  Accordingly, it would be impracticable to join all Class Members before the Court.    43.  The claims of the Plaintiffs are typical of the claims of Class Members, in that  they share the above-referenced facts and legal claims or questions with Class Members, there is  a sufficient relationship between the damage to Plaintiffs and Defendant’s conduct affecting  Class Members, and Plaintiffs have no interests adverse to the interests other Class Members.   44.  Plaintiffs will fairly and adequately protect the interests of Class Members and  have retained counsel experienced and competent in the prosecution of complex class actions  including complex questions that arise in consumer protection litigation.   46.  Because Plaintiffs seek relief for the entire Classes, the prosecution of separate  actions by individual members of the Classes would create a risk of inconsistent or varying  adjudications with respect to individual member of the Classes, which would establish  incompatible standards of conduct for Defendant.   48.  Defendant has acted on grounds that apply generally to the Classes, so that final  injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole. 