26.  Consumers have become increasingly concerned about the effects of synthetics and  chemical ingredients in cosmetic products.  As a result, consumers are willing to pay, and have  paid, a premium for products labeled “natural” over ordinary products that contain synthetic  ingredients.        38.  Plaintiff Meyers seeks to represent a class defined as all persons in the United States  who purchased the Products during the class period (the “Class”).  Excluded from the Class are  Defendant, its affiliates, employees, officers and directors, persons or entities that purchased the  Products for resale, and the Judge(s) assigned to this case.   39.  Plaintiff Meyers also seek to represent a Subclass of all persons in California who  purchased the Products during the class period (the “California Subclass”).  Excluded from the  California Subclass are Defendant, its affiliates, employees, officers and directors, persons or  entities that purchased the Products for resale, and the Judge(s) assigned to this case.   46.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   47.  Plaintiff Meyers brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendant.   48.  This cause of action is brought pursuant to California’s Consumers Legal Remedies  Act, Cal. Civ. Code §§ I750-I785 (the “CLRA”).   49.  Plaintiff Meyers 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 Products for  personal, family, or household purposes.   50.  Plaintiff Meyers, the other members of the California Subclass, and Defendant have  engaged in “transactions,” as that term is defined by California Civil Code § 1761(e).   51.  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.   52.  As alleged more fully above, Defendant has violated the CLRA by falsely  representing to Plaintiff Meyers and the other members of the California Subclass that the Products  are “natural” when in fact they are made with synthetic ingredients.   53.  As a result of engaging in such conduct, Defendant has violated California Civil  Code § 1770(a)(5), (a)(7) and (a)(9).     56.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   57.  Plaintiff Meyers brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendant.   58.  Defendant is subject to California’s Unfair Competition Law, Cal. Bus. & Prof.  Code §§ 17200, et seq.  The UCL provides, in pertinent part: “Unfair competition shall mean and  include unlawful, unfair or fraudulent business practices and unfair, deceptive, untrue or  misleading advertising ….”   59.  Defendant violated the “unlawful” prong of the UCL by violating the CLRA and the  FAL, as alleged herein.   60.  Defendant’s misrepresentations and other conduct, described herein, violated the  “unfair” prong of the UCL in that their conduct is substantially injurious to consumers, offends  public policy, and is immoral, unethical, oppressive, and unscrupulous, as the gravity of the  conduct outweighs any alleged benefits.      61.  Defendant violated the “fraudulent” prong of the UCL by misrepresenting that the  Products are “natural” when, in fact, they are made with synthetic ingredients.   63.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   64.  Plaintiff Meyers brings this claim individually and on behalf of the members of the  proposed California Subclass against Defendant.   65.  California’s False Advertising Law, Cal. Bus. & Prof. Code §§ 17500, et seq.,  makes it “unlawful for any person to make or disseminate or cause to be made or disseminated  before the public in this state, ... in any advertising device ... or in any other manner or means  whatever, including over the Internet, any statement, concerning ... personal property or services,  professional or otherwise, or performance or disposition thereof, 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.”   66.  Defendant committed acts of false advertising, as defined by §§17500, et seq., by  misrepresenting that the Products are “natural” when they are not.   67.  Defendant knew or should have known through the exercise of reasonable care that  their representations about the Products were untrue and misleading.   69.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   70.  Plaintiff brings this claim individually and on behalf of the proposed Class,  California Subclass against Defendant.   71.  Defendant, as the designer, manufacturer, marketer, distributor, and/or seller,  expressly warranted that the Products are “natural.”   72.  Defendant’s express warranties, and its affirmations of fact and promises made to  Plaintiff and the Class regarding the Products, became part of the basis of the bargain between  Defendant and Plaintiff and the Class, thereby creating an express warranty that the Products  would conform to those affirmations of fact, representations, promises, and descriptions.    73.  The Products do not conform to the express warranty because they contain  ingredients that are unnatural and synthetic.    74.  As a direct and proximate cause of Defendant’s breach of express warranty, Plaintiff  and Class members have been injured and harmed because: (a) they would not have purchased the  Products on the same terms if they knew the truth about the Products’ unnatural ingredients; (b)  they paid a substantial price premium based on Defendant’s express warranties; and (c) the  Products do not have the characteristics, uses, or benefits as promised.    75.  On May 30, 2017, Plaintiff Meyers mailed a notice letter to Defendant consistent  with Cal. Com. Code § 2607(3)(a) and U.C.C. 2-607(3)(A), and Defendant received the letter on June  16, 2017.   The letter was sent on behalf of Meyers and all other persons similarly situated.    76.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   81.  Plaintiff hereby incorporates by reference the allegations contained in all preceding  paragraphs of this complaint.   82.  Plaintiff brings this claim individually and on behalf of the proposed Class,  California Subclass against Defendant.   83.  As discussed above, Defendant provided Plaintiff and Class members with false or  misleading material information about the Products by representing that they are “natural.”   Defendant made that misrepresentation knowing it was false.   84.  Defendant’s misrepresentations, upon which Plaintiff and class members reasonably  and justifiably relied, were intended to induce and actually induced Plaintiff and class members to  purchase the Products.   85.  Defendant’s fraudulent actions harmed Plaintiff and class members, who are entitled  to damages and other legal and equitable relief as a result.  Breach of Express Warranty   Fraud   Unjust Enrichment   Violation Of California’s Consumers Legal Remedies Act (“CLRA”),  California Civil Code §§ 1750, et seq.   Violation Of California’s Unfair Competition Law (“UCL”),  California Business & Professions Code §§ 17200, et seq.   Violation Of California’s False Advertising Law (“FAL”),  California Business & Professions Code §§ 17500, et seq.  