UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

Antionette Smith, individually and on behalf of 

all others similarly situated,

Plaintiff,

- against - Class Action Complaint

The Coca-Cola Company,

Jury Trial Demanded

Defendant

Plaintiff alleges upon information and belief, except for allegations pertaining to Plaintiff, 

which are based on personal knowledge:

1. The Coca-Cola Company (“Defendant”) manufactures, packages, labels, markets, 

and sells dragon fruit flavored soda purporting to have “100% Natural Flavors” under the Fanta 

brand (“Product”).

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2. However, the representations are false, deceptive, and misleading because the 

Product contains DL-Malic Acid, an artificial ingredient which imparts the flavor of dragon fruit.

I. CONSUMER DEMAND FOR NATURAL FLAVORS

3. Consumers are increasingly concerned about the ingredients they eat and drink.

4. Surveys have shown that consumers are less likely to buy beverages, even sodas, 

which have artificial ingredients.

5. Within the spectrum of artificial ingredients, consumers are especially focused on, 

and seek to avoid, artificial flavors, and seek products with only natural flavors.

6. The representation that the Product has “100% Natural Flavors” appeals to the more 

than seven out of ten consumers who avoid artificial flavors, as these synthetic ingredients are 

believed to be associated with detrimental health and environmental effects.1

7. Natural flavor refers to the “essential oil, oleoresin, essence or extractive, protein 

hydrolysate, distillate, or any product of roasting, heating or enzymolysis, which contains the 

flavoring constituents” from fruits or vegetables, “whose significant function in food is flavoring 

rather than nutritional.” 21 C.F.R § 101.22(a)(3).

8. Artificial flavor is “any substance, the function of which is to impart flavor, which is 

not derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark,

bud, root, leaf or similar plant material, meat, fish, poultry, eggs, dairy products, or fermentation 

products thereof.” 21 C.F.R § 101.22(a)(1).

9. According to the Wall Street Journal, “As consumer concern rises over artificial 

1 Alex Smolokoff, Natural color and flavor trends in food and beverage, Natural Products Insider, 

Oct. 11, 2019; Thea Bourianne, Exploring today’s top ingredient trends and how they fit into our 

health-conscious world, March 26-28, 2018; Nancy Gagliardi, Consumers Want Healthy Foods –

And Will Pay More For Them, Forbes, Feb 18, 2015.

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ingredients, more food companies are reconstructing recipes” to remove artificial flavors.2

10. According to Paul Manning, chief executive officer and president of Sensient 

Technologies, “Consumer desire for naturally flavored products is an emerging trend.”3

11. Explanations for why consumers prefer foods containing natural, instead of artificial 

flavors, are varied.

12. A recent survey reported that over 82% of US respondents believe that foods with

artificial flavors are less healthy than those promoted as containing natural flavors and/or not 

containing artificial flavors.

13. Consumers seek to avoid artificial flavors because they are weary of ingredients 

which are highly processed with chemical additives and synthetic solvents in laboratories.

14. According to Nielsen, the absence of artificial flavors is very important for over 40% 

of respondents to their Global Health & Wellness Survey.

15. One scholar theorized “the preference for natural products appeals to a moral 

ideology and offers a moral satisfaction.”4

16. The trade journal, Perfumer & Flavorist, described “The Future of Artificial Flavors 

& Ingredients” as bleak, given consumer opposition to these synthetic ingredients.5

17. Mintel announced that consumer avoidance of artificial flavors is just as strong as 

2 Lauren Manning, How Big Food Is Using Natural Flavors to Win Consumer Favor, Wall Street 

Journal.

3 Keith Nunes, Using natural ingredients to create authentic, fresh flavors, Food Business News, 

Sept. 20, 2018.

4 Rozin, P., Spranca, M., Krieger, Z., Neuhaus, R., Surillo, D., Swerdlin, A., & Wood, K. (2004). 

Preference for natural: Instrumental and ideational/moral motivations, and the contrast between 

foods and medicines. Appetite, 43(2), 147–154. doi:10.1016/j.appet.2004.03.005.

5 Jim Kavanaugh, The Future of Artificial Flavors & Ingredients, Perfumer & Flavorist, June 12, 

2017.

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their desire for natural flavors, in its Report, “Artificial: Public Enemy No. 1.”6

18. About half of Americans say they seek out natural flavors at least some of the time.

19. In contrast, artificial flavors were sought out by only about one in 10 consumers,

with approximately half saying they avoid them at least some of the time.

20. Nielsen reported that 62% of consumers try to avoid artificial flavors.

21. New Hope Network concluded that 71% of consumers avoid artificial flavors.

22. Label Insight determined that 76% of consumers avoid artificial flavors.

23. A recent survey shows more than three in four people worldwide are convinced that 

artificial flavors have no place in their ingredient lists.7

24. According to Forbes, 88% of consumers consider foods without artificial flavors to 

be more natural and healthier than foods with artificial flavors and would pay more for such foods.

II. PRODUCT REPRESENTED AS ONLY CONTAINING NATURAL FLAVORS

25. Defendant represents the Product as having “100% Natural Flavors” and being 

“Naturally Flavored,” with pictures of dragon fruit.

6 Alex Smolokoff, Natural color and flavor trends in food and beverage, Natural Products Insider, 

Oct. 11, 2019; Thea Bourianne, Exploring today’s top ingredient trends and how they fit into our 

health-conscious world, March 26-28, 2018; Nancy Gagliardi, Consumers Want Healthy Foods –

And Will Pay More For Them, Forbes, Feb 18, 2015.

7 What ‘Natural’ Really Means to Consumers GNT Group’s Guide to Global Consumer Demands 

attests importance of natural colors for future-proof products, July 13, 2017.

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26. Though the ingredients include “Natural Flavors,” they also include “Malic Acid.”

CARBONATED WATER, LESS THAN 2% OF: MALIC ACID, NATURAL 

FLAVORS, POTASSIUM CITRATE, POTASSIUM SORBATE, VEGETABLE 

EXTRACT (FOR COLOR), ASPARTAME, ACESULFAE POTASSIUM, 

SODIUM BENZOATE (TO PROTECT TASTE), CITRIC ACID.

27. The Product contains more malic acid than natural flavors, as the former isthe second

ingredient listed while the latter isthe third, which reflects their order of predominance.

28. Unbeknownst to consumers, the ingredient list does not disclose that this malic acid 

is an artificial ingredient which imparts dragon fruit flavoring to the Product.

III. MALIC ACID

29. A flavor is a substance with a function to impart taste. See 21 C.F.R. § 101.22(a)(1) 

and (3).

30. Taste is a combination of sensations arising from specialized receptor cells in the 

mouth.8

31. Taste can be defined as sensations of sweet, sour, salty, bitter, and umami.

32. However, limiting taste to five categories suggests taste is simple, which is not true.

33. For example, the taste of sour includes the sourness of vinegar (acetic acid), sour 

milk (lactic acid), lemons (citric acid), apples (malic acid), and wines (tartaric acid). 

34. Each of those acids is responsible for unique sensory characteristics of sourness. 

8 Gary Reineccius, Flavor Chemistry and Technology § 1.2 (2d ed. 2005).

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35. Fruit flavors are the sum of the interaction between sugars, acids, and volatile 

compounds.9

36. Consumer acceptability of the flavor of dragon fruit is based on its perceived 

sweetness, sourness and tartness, determined by its sugar to acid ratio.

37. The sugars in fruits are mainly glucose and fructose, while the acids are mainly malic 

acid and citric acid.

38. The table below shows the acid composition of numerous fruits, and reveals that the 

predominant and primary acid in dragon fruit is malic acid.

Fruit First Predominant Acids Second Predominant Acids

Apple Malic Acid (95%) Tartaric Acid, Fumaric Acid

Apricot Malic Acid (70%) Citric Acid, Tartaric Acid

Blackberry Citric Acid Malic Acid

Blueberry Citric Acid Malic Acid, Quinic Acid

Cherry Malic Acid (94%*) Tartaric Acid

Cherry (Tropical) Malic Acid (32%) Citric Acid

Dragon fruit Malic Acid Citric Acid

Grape Malic Acid (60%*) Tartaric Acid

Grapefruit Citric Acid Malic Acid

Guava Citric Acid Malic Acid

Kiwi Quinic Acid, Citric Acid Malic Acid

Lime, Lemon Citric Acid Malic Acid

Mango Citric Acid Malic Acid, Tartaric Acid

Orange Citric Acid Malic Acid

Peach Malic Acid (73%) Citric Acid

Pear Malic Acid (77%) Citric Acid

Pineapple Citric Acid Malic Acid

Pomegranate Malic Acid (>50%) Citric Acid (>22%)

Raspberry Citric Acid Malic Acid, Tartaric Acid

Strawberry Citric Acid Malic Acid, Tartaric Acid

9 Y.H. Hui, et al., Handbook of Fruit and Vegetable Flavors, p. 693 (2010).

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Tamarind Tartaric Acid Citric Acid, Malic Acid

Watermelon Malic Acid (99%) Fumaric Acid

39. Malic acid imparts the tart, sweet, fruit, and sour taste of dragon fruit.

IV. CHEMICAL STRUCTURE OF MALIC ACID

40. Malic acid (molecular formula C4H6O5) is the common name for 1-hydroxy-1, 2-

ethanedicarboxylic acid.

41. Malic acid has two isomers, or different arrangements of atoms in the molecule, Lmalic acid, and D-malic acid. 21 C.F.R. § 184.1069.

42. An isomer is a molecule sharing the same atomic make-up as another but differing 

in structural arrangements.10

43. Stereoisomers differ by spatial arrangement, meaning different atomic particles and 

molecules are situated differently in any three-dimensional direction.

44. An enantiomer is a type of stereoisomer and like right and left-hand versions of the 

same molecular formula.

45. D-Malic Acid and L-Malic Acid are enantiomers with almost identical skeletal 

formulas.

10 Dan Chong and Jonathan Mooney, Chirality and Stereoisomers (2019).

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46. L-Malic Acid occurs naturally in dragon fruit and is known for providing the sour, 

sweet and tart taste this fruit is known for.

47. D-Malic Acid does not occur naturally.

48. D-Malic Acid is most commonly found as a racemic mixture of the D and L isomers, 

or DL-Malic Acid, commercially made from petroleum.

49. DL-malic acid is synthetically produced from petroleum in a high-pressure, hightemperature, catalytic process.

V. ADDITION OF DL-MALIC ACID

50. The taste of dragon fruit is the result of the combination of its natural sugars of 

glucose, fructose, and sucrose, combined with its most significant fruit acid, L-Malic Acid.

51. However, the Product adds artificial DL-Malic Acid to resemble dragon fruit’s 

natural combination of sugars and L-Malic Acid.

52. This combination of DL-Malic Acid with sugars is not equivalent to the natural flavor 

of dragon fruit.

53. The addition of DL-Malic Acid imparts, creates, enhances, simulates, resembles 

and/or reinforces the sour, tart, sweet and fruity taste that dragon fruit is known for.

54. Defendant could have added L-Malic Acid from dragon fruit or even other fruits, a 

natural version citric acid, or natural dragon fruit flavor, but used artificial DL-Malic Acid because 

it cost less and/or more accurately resembled the taste of dragon fruit.

55. DL-Malic Acid is not a “natural flavor” as defined by federal and state regulations, 

because it is not from a fruit, vegetable or other natural source.

56. The natural flavor of dragon fruit is heavily dependent on specific ratios of sugar and 

L-Malic Acid, while the Product’s flavors depend upon a ratio of sugar and DL-Malic Acid.

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57. The only way to learn if a beverage adds natural or artificial malic acid is through 

laboratory analysis, which is not available or feasible for potential purchasers like Plaintiff to 

perform at the point-of-sale.

58. The results of analyzing the Product in accordance with accepted methodologies and 

standards revealed the presence of artificial DL-Malic Acid instead of natural L-Malic Acid.

VI. REQUIREMENTS FOR LABELING

59. The Product’s primary or “characterizing” flavor is Dragon Fruit because the label 

makes “direct [] representations” about this fruit through the words, “Dragon Fruit,” pictures of a 

fresh whole and sliced dragon fruit, revealing its white flesh and seeds, and the pink and green 

background, which matches the colors of dragon fruit. 21 C.F.R. § 101.22(i).

60. Federal and identical state regulations require the Product to disclose the source of 

this dragon fruit flavor, i.e., from dragon fruit, natural sources other than dragon fruit, and/or 

artificial, synthetic sources, such as DL-Malic Acid from petroleum. 21 C.F.R. § 101.22(i).

61. By telling consumers the Product contains “100% Natural Flavors” and is “Naturally

Flavored,” Defendant misleads consumers by failing to disclose it contains DL-Malic Acid, which 

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functions to impart dragon fruit flavor.

62. Since the Product contains DL-Malic Acid that functions to impart the flavor of 

dragon fruit, “Dragon Fruit Soda” is required to “be accompanied by the word(s) ‘artificial’ or 

‘artificially flavored,’” such as “Artificial Dragon Fruit Flavored Soda” or “Artificially Flavored

Dragon Fruit Soda.” 21 C.F.R. § 101.22(i)(2).

VII. DL-MALIC ACID IS USED TO IMPART FLAVOR

63. In certain uses, DL-Malic Acid could be a flavor enhancer or PH balancer.

64. A flavor enhancer is “added to supplement, enhance, or modify the original taste and 

or aroma of a food without imparting a characteristic taste or aroma of its own.” 21 C.F.R. § 

170.3(o)(11).

65. The addition of malic acid to vinegar (ascetic acid) dishes like barbecue pork, 

coleslaw, or pickled eggs would not fundamentally alter those underlying vinegar flavors.

66. However, because the flavor imparted by malic acid is the core component of dragon 

fruit, DL-Malic Acid imparts a flavor of its own and is not a flavor enhancer.

67. PH balancers are “substances added to change or maintain active acidity or basicity, 

including buffers, acids, alkalis, and neutralizing agents.” 21 C.F.R. § 170.3(o)(23).

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68. The added DL-Malic Acid is not a PH balancer because it is not necessary to change 

or maintain the Product’s acidity or basicity, as carbonated beverages are highly acidic.

69. Irrespective of the purpose DL-Malic Acid was added, its effect is to provide the 

flavor of dragon fruit.

VIII. CONCLUSION

70. The Product contains other representations and omissions which are false and

misleading.

71. The value of the Product that Plaintiff purchased was materially less than its value 

as represented by Defendant. 

72. Defendant sold more of the Product and at higher prices than it would have in the

absence of this misconduct, resulting in additional profits at the expense of consumers.

73. Had Plaintiff and proposed class members known the truth, they would not have 

bought the Product or would have paid less for it.

74. As a result of the false and misleading representations, the Product is sold at a 

premium price, approximately no less than $2.29 for 20 oz, excluding tax and sales, higher than 

similar products, represented in a non-misleading way, and higher than it would be sold for absent 

the misleading representations and omissions.

Jurisdiction and Venue

75. Jurisdiction is based on the Class Action Fairness Act of 2005 (“CAFA”). 28 U.S.C. 

§ 1332(d)(2).

76. The aggregate amount in controversy exceeds $5 million, including any statutory 

damages, exclusive of interest and costs.

77. Plaintiff Antionette Smith is a citizen of Florida.

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78. Defendant The Coca-Cola Company is a Delaware corporation with a principal place 

of business in Atlanta, Fulton County, Georgia.

79. The class of persons Plaintiff seeks to represent includes persons who are citizens of 

different states from which Defendant is a citizen.

80. The members of the classes Plaintiff seeks to represent are more than 100, because 

the Product is sold at thousands of grocery stores, dollar stores, drug stores, convenience stores, 

big box stores, and/or online, in these States.

81. Venue is in this District because a substantial part of the events or omissions giving 

rise to the claims occurred here, including Plaintiff’s purchase and consumption of the Product, 

exposure to and reliance on the representations, and her awareness that they were misleading.

82. This action should be assigned to the Fort Lauderdale Division because Plaintiff 

resides in Broward County and a substantial part of the events or omissions giving rise to the 

claims occurred in Broward County, including Plaintiff’s purchase, consumption, and/or use of the 

Product, and her awareness and/or experiences of and with the issues described here.

Parties

83. Plaintiff Antionette Smith is a citizen of Lauderdale Lakes, Florida, Broward County.

84. Defendant The Coca-Cola Company is a Delaware corporation with a principal place 

of business in Atlanta, Georgia, Fulton County.

85. Fanta was first made in Europe during the Second World War by The Coca-Cola 

Company’s European divisions.

86. The version of Fanta sold today is based on the Fanta that was re-introduced to Italy 

in the mid-1950s.

87. This soda was unique because it was made with local produce instead of only sugary 

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syrups.

88. Fanta has always been known as a more “natural” and fruit-centric brand of soda 

than American soda brands, due to its European origins.

89. In the United States, Fanta sodas are based on real fruit flavors, with bright colors

from real fruit and natural ingredients.

90. Consumers trust the Fanta brand to be honest with them, because they have built up 

a reservoir of good will when it comes to fruit-flavored sodas.

91. Plaintiff viewed the label which said “100% Natural Flavors” and “Naturally 

Flavored,” and expected only natural flavors were responsible for the dragon fruit taste.

92. Plaintiff is part of the over 70% of consumers who avoid artificial flavors.

93. Plaintiff is part of the over 82% of Americans who believe foods with artificial 

flavors are less healthy than those containing natural flavors without artificial flavors.

94. Plaintiff is part of the over 40% of consumers identified by Nielsen for whom the 

absence of artificial flavors is very important.

95. Plaintiff was unable to learn the malic acid listed in the ingredients was the artificial 

version or that it was used to provide the Product’s dragon fruit taste.

96. Plaintiff relied on the words, terms coloring, descriptions, layout, packaging, and/or 

images on the Product, on the labeling, statements, omissions, claims, statements, and instructions, 

made by Defendant or at its directions, in digital, print and/or social media, which accompanied 

the Product and separately, through in-store, digital, audio, and print marketing.

97. Plaintiff purchased the Product on one or more occasions within the statutes of 

limitations for each cause of action alleged, at stores including Dollar Tree, 5920 W Oakland Park 

Blvd, Lauderhill, FL 33313, between January 13, 2022, and August 27, 2022, and/or among other 

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times.

98. Plaintiff bought the Product at or exceeding the above-referenced price.

99. Plaintiff chose between Defendant’s Product and products represented similarly, but 

which did not misrepresent their attributes, requirements, instructions, features, and/or 

components.

100. Plaintiff paid more for the Product than she would have paid had she known that 

“100% Natural Flavors” and “Naturally Flavored” was false and misleading, as she would not have 

bought it or would have paid less.

101. Plaintiff intends to, seeks to, and will purchase the Product again when she can do so 

with the assurance its representations are consistent with its composition.

102. Plaintiff is unable to rely on the labeling and representations not only of this Product, 

but other similar sodas represented as made with only natural flavors, because she is unsure 

whether those representations are truthful.

Class Allegations

103. Plaintiff seeks certification under Fed. R. Civ. P. 23 of the following classes:

Florida Class: All persons in the State of Florida

who purchased the Product during the statutes of 

limitations for each cause of action alleged; and

Consumer Fraud Multi-State Class: All persons in 

the States of Alabama, New Mexico, Mississippi, 

Utah, Nebraska, South Carolina, Tennessee, and 

Virginia who purchased the Product during the 

statutes of limitations for each cause of action 

alleged.

104. Common questions of issues, law, and fact predominate and include whether 

Defendant’s representations were and are misleading and if Plaintiff and class members are entitled 

to damages.

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105. Plaintiff’s claims and basis for relief are typical to other members because all were 

subjected to the same unfair, misleading, and deceptive representations, omissions, and actions.

106. Plaintiff is an adequate representative because her interests do not conflict with other 

members. 

107. No individual inquiry is necessary since the focus is only on Defendant’s practices 

and the class is definable and ascertainable.

108. Individual actions would risk inconsistent results, be repetitive and are impractical 

to justify, as the claims are modest relative to the scope of the harm.

109. Plaintiff’s counsel is competent and experienced in complex class action litigation 

and intends to protect class members’ interests adequately and fairly.

110. Plaintiff seeks class-wide injunctive relief because the practices continue.

Florida Deceptive and Unfair Trade Practices Act, 

Fla. Stat. § 501.201, et seq.

111. Plaintiff incorporates by reference all preceding paragraphs.

112. Plaintiff relied on the representations and omissions to believe the Product contained 

only natural flavoring, which was false and misleading.

113. Plaintiff and class members would not have purchased the Product or paid as much 

if the true facts had been known, suffering damages.

 Violation of State Consumer Fraud Acts

(Consumer Fraud Multi-State Class)

114. The Consumer Fraud Acts of the States in the Consumer Fraud Multi-State Class are 

similar to the consumer protection statute invoked by Plaintiff and prohibit the use of unfair or 

deceptive business practices in the conduct of commerce.

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115. The members of the Consumer Fraud Multi-State Class reserve their rights to assert 

their consumer protection claims under the Consumer Fraud Acts of the States they represent 

and/or the consumer protection statute invoked by Plaintiff.

116. Defendant intended that members of the Consumer Fraud Multi-State Class would 

rely upon its deceptive conduct.

Breaches of Express Warranty,

Implied Warranty of Merchantability/Fitness for a Particular Purpose and

Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.

117. The Product was manufactured, identified, marketed, and sold by Defendant and 

expressly and impliedly warranted to Plaintiff and class members that it contained only natural 

flavoring.

118. Defendant directly marketed the Product to Plaintiff and consumers through its 

advertisements and marketing, through various forms of media, on the packaging, in print 

circulars, direct mail, and targeted digital advertising.

119. Defendant knew the product attributes that potential customers like Plaintiff were 

seeking, such as beverages with only natural flavorings, and developed its marketing and labeling 

to directly meet those needs and desires.

120. The representations were conveyed in writing and promised the Product would be

defect-free, and Plaintiff understood this meant that it contained only natural flavoring.

121. Defendant affirmed and promised that the Product contained only natural flavoring.

122. Defendant described the Product so Plaintiff and consumers believed it contained 

only natural flavoring, which became part of the basis of the bargain that it would conform to its 

affirmations and promises.

123. Defendant had a duty to disclose and/or provide non-deceptive descriptions and 

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marketing of the Product.

124. This duty is based on Defendant’s outsized role in the market for this type of product, 

custodian of the Fanta brand, the preeminent seller of natural fruit-flavored sodas.

125. Plaintiff recently became aware of Defendant’s breach of the Product’s warranties.

126. Plaintiff provides or will provide notice to Defendant, its agents, representatives, 

retailers, and their employees that it breached the Product’s express and implied warranties 

associated with the Product.

127. Defendant received notice and should have been aware of these issues due to 

complaints by third-parties, including regulators, competitors, and consumers, to its main offices, 

and by consumers through online forums.

128. The Product did not conform to its affirmations of fact and promises due to 

Defendant’s actions.

129. The Product was not merchantable because it was not fit to pass in the trade as 

advertised, not fit for the ordinary purpose for which it was intended and did not conform to the 

promises or affirmations of fact made on the packaging, container, or label, because it was marketed 

as if it contained only natural flavoring.

130. The Product was not merchantable because Defendant had reason to know the 

particular purpose for which the Product was bought by Plaintiff, because she expected it contained 

only natural flavoring, and she relied on Defendant’s skill and judgment to select or furnish such 

a suitable product.

Negligent Misrepresentation

131. Defendant had a duty to truthfully represent the Product, which it breached.

132. This duty is based on its position, holding itself out as having special knowledge and 

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experience this area, custodian of the Fanta brand, the preeminent seller of fruit-flavored sodas.

133. The representations took advantage of consumers’ cognitive shortcuts made at the 

point-of-sale and their trust in Defendant, a globally recognized and iconic brand.

134. Plaintiff reasonably and justifiably relied on these negligent misrepresentations and 

omissions, which served to induce and did induce, their purchase of the Product. 

Fraud

135. Defendant misrepresented that the Product contained only natural flavoring.

136. The records Defendant is required to maintain, and/or the information 

inconspicuously disclosed to consumers, provided it with actual and constructive knowledge of 

the falsity and deception, through statements and omissions.

Unjust Enrichment

137. Defendant obtained benefits and monies because the Product was not as represented 

and expected, to the detriment and impoverishment of Plaintiff and class members, who seek 

restitution and disgorgement of inequitably obtained profits.

Jury Demand and Prayer for Relief

Plaintiff demands a jury trial on all issues.

WHEREFORE, Plaintiff prays for judgment:

1. Declaring this a proper class action, certifying Plaintiff as representative and the

undersigned as counsel for the class;

2. Entering preliminary and permanent injunctive relief by directing Defendant to correct the

challenged practices to comply with the law;

3. Awarding monetary, statutory, and/or punitive damages pursuant to applicable laws;

4. Awarding costs and expenses, including reasonable fees for Plaintiff's attorneys and 

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experts; and

5. Other and further relief as the Court deems just and proper.

Dated: September 1, 2022

Respectfully submitted, 

/s/Will Wright 

The Wright Law Office, P.A.

515 N Flagler Dr Ste P-300 

West Palm Beach FL 33401

(561) 514-0904

willwright@wrightlawoffice.com

Sheehan & Associates, P.C.

Spencer Sheehan*

60 Cuttermill Rd Ste 412

Great Neck NY 11021

(516) 268-7080

spencer@spencersheehan.com

Pro Hac Vice Application Forthcoming

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