 Defendant manufactures, labels, markets, promotes, advertises, and sells  Barlean’s Greens Products.      Defendant markets and labels the Products with the Representations  described herein.  The following images depict the Products and the uniform, material  Representations made on the Products:    B.  Defendant’s Failure to Include the Proposition 65 Warning Is A   Material Misrepresentation and Omission    Absent from the label of the Products is any disclosure that the Products  contain lead and a “clear and reasonable warning” pursuant to California’s Proposition  65, that the Products exceed the .5 mcg/day allowable limit for lead.    Plaintiff re-alleges and incorporates by reference the allegations contained  in the preceding paragraphs of this complaint, as though fully set forth herein.    Defendant’s conduct constitutes an unfair business act and practice  pursuant to California Business & Professions Code §§ 17200, et seq. (the “UCL”).   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 . . . .”     Plaintiff brings this claim seeking equitable and injunctive relief to stop  Defendant’s misconduct, as complained of herein, and to seek restitution of the  amounts Defendant acquired through the unfair, unlawful, and fraudulent business  practices described herein.     Defendant’s knowing conduct, as alleged herein, constitutes an “unfair”  and/or “fraudulent” business practice, as set forth in California Business & Professions  Code §§ 17200-17208.      Plaintiff re-alleges and incorporates by reference the allegations contained  in the preceding paragraphs of this complaint, as though fully set forth herein.    California Business & Professions Code § 17500 prohibits “unfair,  deceptive, untrue or misleading advertising . . . .”    Defendant violated § 17500 when it represented, through its false and  misleading Representations and omissions, that Defendant’s Products possessed  characteristics and value that they did not actually have.  Among other things,  Defendant made Structure/Function Representations and omissions, which do not  comply with the DSHEA requirements, as described herein.  In addition, Defendant  failed to include the required Proposition 65 warning and to disclose that the Products  exceeded the allowable lead limits.     Defendant’s deceptive practices were specifically designed to induce  reasonable consumers like Plaintiff to purchase the Products.  Defendant’s uniform,  material misrepresentations and omissions regarding the Products were likely to  deceive, and Defendant knew or should have known that its uniform  misrepresentations and omissions were untrue and/or misleading.  Plaintiff purchased  the Products in reliance on the Representations made by Defendant, as alleged herein.     Plaintiff and members of the California Subclass have been directly and  proximately injured by Defendant’s conduct in ways including, but not limited to, the  monies paid to Defendant for the Products, interest lost on those monies, and  consumers’ unwitting support of a business enterprise that promotes deception and  undue greed to the detriment of consumers, such as Plaintiff and Subclass members.     The above acts of Defendant were and are likely to deceive reasonable  consumers in violation of § 17500.     Plaintiff re-alleges and incorporates by reference the allegations contained  in the preceding paragraphs of this complaint, as though fully set forth herein.    Plaintiff brings this action pursuant to California’s Consumer Legal  Remedies Act (“CLRA”), Cal. Civ. Code § 1750, et seq.    The CLRA provides that “unfair methods of competition and unfair or  deceptive acts or practices undertaken by any person in a transaction intended to result  or which results in the sale or lease of goods or services to any consumer are  unlawful.”      The Products are “goods,” as defined by the CLRA in California Civil  Code §1761(a).    Plaintiff re-alleges and incorporate by reference the allegations contained  in the preceding paragraphs of this Complaint, as though fully set forth herein.    By advertising and selling the Products at issue, Defendant made promises  and affirmations of fact on the Products’ packaging, and through its marketing and  advertising, as described herein.  This labeling and advertising constitutes express  warranties and became part of the basis of the bargain between Plaintiff and members  of the Class, and Defendant.   A.  Defendant Manufactures, Labels and Advertises the Products    Breach of Express Warranty  (for the Nationwide Class and California Subclass)   Consumer Legal Remedies Act  (Cal. Civ. Code § 1750, et seq.)  (for the California Subclass)   Deceptive Advertising Practices  (California Business & Professions Code §§ 17500, et seq.)  (for the California Subclass)   QUASI-CONTRACT  (for the Nationwide Class and California Subclass)  104. Plaintiff repeats and re-alleges the allegations of the preceding paragraphs  as if fully set forth herein.  105. By purchasing the Products, Plaintiff and members of the Class conferred  a benefit on Defendant in the form of the purchase price of the Products.  106. Defendant had knowledge of such benefits.  107. Defendant appreciated the benefit because, were consumers not to  purchase the Products, Defendant would not generate revenue from the sales of the  Products.  108. Defendant’s acceptance and retention of the benefit is inequitable and  unjust because the benefit was obtained by Defendant’s fraudulent and misleading  representations and omissions.  109. Equity cannot in good conscience permit Defendant to be economically  enriched for such actions at the expense of Plaintiff and members of the Class, and  therefore restitution and/or disgorgement of such economic enrichment is required  Unfair and Unlawful Business Acts and Practices  (Business and Professions Code § 17200, et seq.)  (for the California Subclass)  