Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 1 of 64 Page ID #:1
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`KAZEROUNI LAW GROUP, APC
`Abbas Kazerounian, Esq. (SBN: 249203)
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`2 || ak@kazlg.com
`3 245 Fischer Avenue, Unit D1
`Costa Mesa, California 92626
`4 || Telephone: (800) 400-6808
`Facsimile: (800) 520-5523
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`6 [Additional Counsel on Signature Page]
`7 || Attorneys for Plaintiff,
`9 Victoria Palmer
`9 UNITED STATES DISTRICT COURT
`10 CENTRAL DISTRICT OF CALIFORNIA
`Case No.: 2:25-cv-04777
`1T ' VICTORIA PALMER,
`12 || Individually and On Behalf of All CLASS ACTION
`13 Others Similarly Situated, COMPLAINT FOR VIOLATIONS
`= OF:
`%< 14 Plaintiff, 1) CALIFORNIA CONSUMER
`e LEGAL REMEDIES ACT
`98 15 V. (“CLRA”), CAL. CIV. CODE §§
`I 1750, ET SEQ.;
`O 2) CALIFORNIA’S UNFAIR
`fi Z |, | THE COCA-COLA COMPANY, COMPETITION LAW {(“UCL™,
`\Z <5 CAL. BUS. & PROF. CODE §§
`o 18 Defendant. 17200, ET SEQ.;
`o2 3) CALIFORNIA’S FALSE
`19 ADVERTISING LAW (“FAL”),
`20 CAL. BUS. & PROF. CODE §§
`17500, ET SEQ.;
`21 4) BREACH OF EXPRESS
`WARRANTY
`22 5) UNJUST ENRICHMENT;
`73 6) NEGLIGENT
`MISREPRESENTATION; AND,
`24 7) INTENTIONAL
`MISREPRESENTATION.
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`2% JURY TRIAL DEMANDED
`27 ACTION SEEKING STATEWIDE
`OR NATIONWIDE RELIEF
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`CLASS ACTION COMPLAINT
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`Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 2 of 64 Page ID #:2
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`INTRODUCTION
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`1. Plaintiff Victoria Palmer (“Plaintiff” or “Ms. Palmer”), individually and on
`behalf of all others similarly situated, brings this class action complaint
`(“Complaint”) for damages, injunctive relief, and any other available legal or
`equitable remedies resulting from the unlawful actions of Defendant The Coca-Cola
`Company, doing business as Sprite and Fanta (“Coca-Cola ” or “Defendant™).
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`2. This Complaint concerns the illegal, unfair, and deceptive labeling,
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`marketing, and sale of Coca-Cola’s beverage products as being made with “100%
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`Natural Flavors.”
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`3. The unlawfully and deceptively represented products are sold through
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`11 || multiple channels, including, but not limited to, direct-to-consumer sales via
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`Defendant’s Amazon.com (“Amazon”) store, as well as through third-party
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`merchants operating both brick-and-mortar locations and online platforms. These
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`include, but are not limited to, Safeway, Vons, Albertsons, Target, Walmart, Kroger,
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`CVS, Walgreens, and numerous other retailers throughout the United States.
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`4. Ms. Palmer alleges as follows upon personal knowledge as to herself and her
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`own acts and experiences, and as to all other matters, upon information and belief,
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`o 18 including investigation conducted by her attorneys.
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`I 19 || 5. In the highly competitive beverage industry, companies sometimes seek to
`20 || gain an unfair advantage by misleading consumers about the nature and quality of
`21 || their products. Coca-Cola manufactures, markets, and sells two lines of products that
`22 || are prominently labeled as containing “100% Natural Flavors.” In reality, these
`23 || products contain significant amounts of synthetic ingredients that are integral and
`24 || indispensable to their flavor systems, rendering the labeling false, deceptive,
`25 || misleading, and fraudulent.
`26 || 6. Numerous federal and state laws, rules, and regulations govern the proper
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`labeling of consumer products, including beverages.
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`CLASS ACTION COMPLAINT 1
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`Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 3 of 64 Page ID #:3
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`7. For example, the Federal Food, Drug, and Cosmetic Act (“FDCA”), and
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`various state laws!' that generally align with the FDCA govern the aspects of food
`and beverage labeling discussed herein. These laws reflect a fundamental principle:
`consumers have the right to know what they are purchasing and consuming.
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`8. When companies misrepresent the presence of key ingredients, fail to disclose
`the true nature of components that materially affect product flavor or composition,
`mischaracterize the nature of their formulations, or falsely imply that certain
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`ingredients are natural or derived from natural sources, they violate fundamental
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`consumer protection laws. Such conduct erodes consumer trust, distorts fair
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`competition, and grants deceptive actors an improper advantage in the marketplace.
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`11 I19. Under both the FDCA and the Sherman law, a food is considered misbranded
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`if its labeling is false or misleading in any particular.* This includes representations
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`about the nature, source, or quality of ingredients, including claims regarding
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`whether flavors are “natural.”
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`10. Defendant’s Sprite and Fanta beverage products are labeled, marketed, and
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`sold in the United States as being made with “100% Natural Flavors,” thereby
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`expressly warranting that they contain no artificial flavoring ingredients and that no
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`I o 18 synthetic substances contribute to their flavor systems, including the flavor
`19 || experienced by consumers. In reality, these products contain synthetic ingredients—
`20 || including key flavoring compounds—rendering such representations false and
`21 || misleading under both federal and California law.
`22 || 11. Defendant’s Sprite Lemon-Lime flavor beverages (the “Sprite Product”) and
`23 || Fanta Orange flavor beverages (the “Fanta Product” and, together with the Sprite
`24 || Product, the “Product(s)”) purchased by Plaintiff were falsely labeled as containing
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`27 ||'! See California Sherman Food, Drug, and Cosmetic Law (“Sherman Law”), Cal.
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`Health & Safety Code §§ 109875-111915.
`2 See 21 U.S.C. § 343(a); Cal. Health & Safety Code § 110390, 110395, 110398.
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`CLASS ACTION COMPLAINT 2
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`Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 4 of 64 Page ID #:4
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`“100% Natural Flavors,” despite the presence of synthetic ingredients that materially
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`contributed to the Products’ flavor.
`12. As stated by the California Supreme Court in Kwikset v. Superior Court, 51
`Cal. 4th 310, 328-29 (2011):
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`Simply stated: labels matter. The marketing industry is
`based on the premise that labels matter, that consumers
`will choose one product over another similar product
`based on its label and various tangible and intangible
`qualities that may come to associate with a particular
`source. . .
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`11 || 13. Defendant’s conduct of labeling, marketing and selling deceptively labeled
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`12 || products bearing the aforementioned misrepresentation(s) violates: (1) California’s
`() 13 || Consumer Legal Remedies Act (“CLRA”), Cal. Civ. Code §§ 1750, et seq.; (2)
`%EE 14 || California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200, et
`98 15 || seq.; (3) California’s False Advertising Law (“FAL”), Cal. Bus. & Prof. Code §§
`= % 16 || 17500, et seq.; and constitutes (4) breach of express warranty; (5) unjust enrichment;
`Q (E/ 17 || (6) negligent misrepresentation; and (7) intentional misrepresentation.
`bf\: 18 || 14. Defendant’s conduct of labeling, marketing and selling deceptively labeled
`I 19 || products bearing the aforementioned misrepresentations also violates the FDCA and
`20 || the Sherman Law.
`21 || 15. This conduct caused Plaintiff, and other similarly situated consumers,
`22 || damages, and requires restitution and injunctive relief to remedy and prevent future
`23 || harm.
`24 || 16. In addition to the “100% Natural Flavors™ claims on the Products purchased
`25 || by Plaintiff, upon information and belief, many of Defendant’s other substantially
`26 || similar Sprite and Fanta beverages—including, but not limited to, Sprite Zero Sugar,
`27 || Sprite Chill Strawberry Kiwi, Sprite Tropical Mix, Sprite Lymonade, Sprite Cherry,
`28 || Sprite Winter Spiced Cranberry, Fanta Zero Sugar Orange, Fanta Strawberry, Fanta
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`CLASS ACTION COMPLAINT 3
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`Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 5 of 64 Page ID #:5
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`Grape, Fanta Peach, Fanta Pineapple, Fanta Pina Colada, and Fanta Berry
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`(collectively, with the Products purchased by Plaintiff, the “Class Products”)*—are,
`or have been marketed and sold using the same unlawful, unfair, and deceptive
`“100% Natural Flavors” claims.
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`JURISDICTION AND VENUE
`17. This Court has jurisdiction over this matter pursuant to the Class Action
`Fairness Act (CAFA), 28 U.S.C. § 1332(d), because: (1) there is minimal diversity
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`because Plaintiff 1s a citizen of the State of California and Defendant 1s a Delaware
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`corporation with its headquarters and principal place of business in Georgia;* (2) the
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`amount in controversy in this matter exceeds $5 million, exclusive of interest and
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`11 || costs; and (3) there are more than one hundred (100) people in the putative class.
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`18. Venue is proper in the United States District Court for the Central District of
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`California pursuant to 28 U.S.C. § 1391 for the following reasons: (i) Plaintiff
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`resides in Los Angeles County, California, which is within this judicial district; (i1)
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`a substantial part of the conduct complained of herein occurred within this judicial
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`16 || district; (ii1) Defendant conducted business within this judicial district at all relevant
`17 || times.
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`! o 18 PARTIES
`19 || 19. Ms. Palmer is, and at all times mentioned herein was, a natural person, an
`20 || individual citizen and resident of Los Angeles County, California.
`21 ||20. Defendant is a corporation that is organized and exists under the laws of
`22 || Delaware, with its principal place of business in Georgia located at One Coca-Cola
`23 || Plaza, Atlanta, Georgia 30313.
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`3 Class Products include all seasonal and limited edition variations of Sprite and
`Fanta, including but not limited to those not specifically listed herein.
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`4 According to the California Secretary of State’s website, The Coca-Cola Company
`(Control ID 167890) is a Delaware corporation that has been registered to do
`business in California since July 28, 1936.
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`CLASS ACTION COMPLAINT 4
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`21. Defendant is a manufacturer, distributor and seller of beverage and releated
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`food products that conducts business: (a) direct-to-consumers through its Amazon
`store; (b) through the websites of third-party vendors, including, but not limited to,
`Walmart.com, CVS.com, Walgreens.com, Target.com, and Kroger.com, among
`others; and (c¢) through the distribution of its products to be sold in grocery stores,
`convenience stores, movie theaters, amusement parks, sports and entertainment
`venues, hotels, airports, vending machines, and elsewhere including, but not limited
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`to, Walmart, CVS, Walgreens, Target, and 7-Eleven, among others.
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`22. Ms. Palmer alleges that at all relevant times Defendant conducted business
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`within the State of California, in Los Angeles County, and within this judicial
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`11 || district.
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`23. Unless otherwise indicated, the use of Defendant’s name in this Complaint
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`includes all agents, employees, officers, members, directors, heirs, successors,
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`assigns, principals, trustees, sureties, subrogees, representatives, and insurers of the
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`Defendant, respectively.
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`NATURE OF THE CASE
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`24. Defendant was founded in Atlanta, Georgia in 1886 and has since grown into
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`I o 18 || one of the most recognizable brands in the world—whether in the beverage industry
`19 || or among global consumer brands generally. Today, depending on the year,
`20 || Defendant ranks as either the largest or second-largest beverage company in the
`21 || United States, if not the world.
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`22 ||25. Defendant produces, markets and sells a wide portfolio of beverage products
`23 || through multiple distribution channels including, but not limited to, its Amazon
`24 || store, through third-party retailers online as well as in brick and mortar stores,
`25 || restaurants and elsewhere. In 2024, Defendant reported annual revenue of $47.1
`26 || billion, underscoring its immense scale and market dominance.’
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`)3 > See Coca-Cola Reports Fourth Quarter and Full Year 2024 Results
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`https://investors.coca-colacompany.com/news-events/press-
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`CLASS ACTION COMPLAINT 5
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`26. As a direct result of its sustained success, Defendant commands financial,
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`technical, legal, and regulatory resources that are virtually unparalleled in the global
`marketplace.
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`27. Given Defendant’s long-standing presence in the food and beverage
`industry—and 1its vast resources and operational sophistication—it is difficult to
`comprehend how it could so blatantly disregard the well-established laws, rules,
`and regulations governing the labeling, marketing, and sale of beverage products.
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`28. At all relevant times, Defendant has made and continues to make material
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`misrepresentations regarding the Class Products either directly or through its
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`agents.®
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`11 |[29. Specifically, Defendant labeled, packaged, marketed, and sold the Class
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`Products as containing “100% Natural Flavors” when, in reality, they contain
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`multiple synthetic ingredients that contribute to the Class Products’ flavor—
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`including one that is a primary driver of the overall flavor profile. These claims are
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`false, unlawful, unfair, and deceptive, and they continue to be made to this day.
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`30. Each consumer, including Plaintiff, was exposed to the same material
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`misrepresentations, as substantially similar labels, packaging and/or marketing
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`I o 18 materials were used in connection with all Class Products sold—and currently being
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`19 || sold—throughout the United States, including within the State of California.
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`20 ||31. Federal and state laws, rules, and regulations regarding the labeling of
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`22 |l releases/detail/1128/coca-cola-reports-fourth-quarter-and-full-year-2024-results
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`23 || (last visited May 16, 2025).
`6 Indeed, Coca-Cola’s B2B platform represents many of the Class Products as
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`24 being made with “100% Natural Flavors.” See
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`25 || https://www.cokesolutions.com/products/brands/sprite/sprite.html (last accessed
`May 16, 2025); https://www.cokesolutions.com/products/brands/sprite-
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`26 zero/sprite-zero_-.html (same);
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`27 || https://www.cokesolutions.com/products/brands/fanta/fanta.html (same);
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`)3 https://www.cokesolutions.com/products/brands/fanta-zero/fanta-zero_.html
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`(same).
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`CLASS ACTION COMPLAINT 6
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`consumer products are well-established and clearly defined. Specifically, under the
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`FDCA and the Sherman Law, a food is considered misbranded if its labeling is false
`or misleading in any particular.
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`32. Asadirect result of Defendant’s unfair and deceptive practices, Plaintiff and
`other similarly situated consumers purchased the Class Products based on false
`impressions and in reasonable reliance on Defendant’s misrepresentation.
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`33. As aresult, Plaintiff and other similarly situated consumers overpaid for the
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`Class Products, purchased the Class Products over the products of competitors,
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`and/or purchased the Class Products under the belief that the Defendant’s
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`representations were accurate, truthful and lawful. This includes both initial and
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`11 || repeat purchases of the Class Products.
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`12 || 34. Despite clearly established and well-defined federal and state laws, rules, and
`() 13 [[ regulations—including consumer protection laws—governing the labeling,
`%E 14 || marketing, and sale of food and beverage products in the United States, Defendant
`98 15 || falsely, unfairly, and deceptively advertised, marketed, and sold its products,
`- % 16 || including the Products purchased by Plaintiff, as further detailed herein.
`Q (E/ 17 ||35. Had Plaintiff been aware that the labeling and marketing of the Class
`:f\: 18 || Products contained false and deceptive misrepresentations, she would not have
`19 || purchased the Class Products or would have paid less for them.
`20 ||36. As aresult of Defendant’s false, unfair, and deceptive representations—and
`21 || its failure to disclose the true nature of the flavoring ingredients used in the Class
`22 || Products—consumers nationwide, inclusive of Plaintiff, purchased millions of units
`23 || of the Class Products across the United States, including in California, and have
`24 || suffered, and continue to suffer, harm, including the loss of money and/or property.
`25 ||37. Defendant’s conduct regarding the labeling, marketing, and sale of the Class
`26 || Products, as alleged herein, violates multiple federal and California laws, rules, and
`27 || regulations, as detailed below.
`28 ||38. This action seeks, among other things, actual damages and prospective
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`CLASS ACTION COMPLAINT 7
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`Case 2:25-cv-04777-GW-AGR Document 1l Filed 05/27/25 Page 9 of 64 Page ID #:9
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`injunctive relief (including public injunctive relief), and in the alternative restitution
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`and disgorgement of all ill-gotten profits resulting from Defendant’s alleged
`wrongdoing.
`39. Unless enjoined, Defendant's unfair, deceptive and unlawful conduct will
`continue into the future, and Plaintiff and Class members will continue to suffer
`harm through the purchase of Defendant’s misbranded Class Products in the
`marketplace.
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`FACTUAL ALLEGATIONS
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`40. Plaintiff re-alleges and incorporates by reference all preceding paragraphs of
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`this Complaint as though fully set forth herein, and further alleges as follows:
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`11 |[41. At all relevant times, including as of the filing of this Complaint, Defendant
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`has made material misrepresentations regarding the Class Products either directly
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`or through its agents.
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`42. Defendant produces, markets, advertises and sells certain of its products,
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`including the Products purchased by Plaintiff, as being made with “100% Natural
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`Flavors.”
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`43, The term “Natural Flavor” is well-defined under United States law.’ In
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`I o 18 general, it refers exclusively to flavoring substances that are derived from natural
`19 || sources, including plant or animal materials.
`20 ||44. The legal definition of “Natural Flavor” does not encompass substances
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`22 117 See 21 C.F.R. § 101.22(a)(3) (“The term natural flavor or natural flavoring means
`23 || the essential oil, oleoresin, essence or extractive, protein hydrolysate, distillate, or
`any product of roasting, heating or enzymolysis, which contains the flavoring
`24 |[ constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice,
`25 || edible yeast, herb, bark, bud, root, leaf or similar plant material, meat, seafood,
`poultry, eggs, dairy products, or fermentation products thereof, whose significant
`function in food is flavoring rather than nutritional. Natural flavors include the
`27 || natural essence or extractives obtained from plants listed in §§ 182.10, 182.20,
`)3 182.40, and 182.50 and part 184 of this chapter, and the substances listed in §
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`172.510 of this chapter.”) (emphasis in original)
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`CLASS ACTION COMPLAINT 8
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`produced synthetically, including those synthesized by genetically modified or
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`mutated strains of mold. Additionally, consumers’ understanding of “Natural
`Flavor” does not encompass synthetic ingredients that drive or contribute to the
`overall flavor experience.
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`45. In the food and beverage industry, natural flavors are highly valued by
`consumers and frequently used in products targeted at health-conscious individuals.
`Companies often include natural flavors—and prominently advertise their use—to
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`enhance the perceived healthfulness of their products, boost sales, gain a
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`competitive edge, and avoid public scrutiny.
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`46. Consumers, including Plaintiff, increasingly favor products labeled or
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`11 || marketed as "natural," associating them with health benefits and safety. A recent
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`Acosta Group study found that 59% of shoppers prioritize natural and organic
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`groceries and household products, primarily due to perceptions of better health and
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`fewer synthetic additives.® In the same study, younger consumers showed an even
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`stronger preference for natural and organic products, with 89% of Gen Z and 85%
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`of Millennials reporting they purchased such items within the past six months.
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`Additionally, research published in the Journal of Consumer Research indicates that
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`I o 18 | consumers prefer natural products more strongly when used for prevention rather
`19 || than cure, as they are perceived to be safer.” Given the widespread recognition of
`20 || the term “Natural Flavors,” consumers are attracted to products that contain them—
`21 || and even more so to those that are marketed as being made with “100% Natural
`22 || Flavors.”
`23 ||47. Consumers, including Plaintiff, have often sought out products labeled as
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`containing “100% Natural Flavors,” relying on such representations as an express
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`warranty that the product contains no synthetically created flavoring ingredients
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`that contribute to their flavor systems or overall flavor experience. This claim also
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`8 See https://shorturl.at/LLnFZ (last accessed May 16, 2025).
`? See https://shorturl.at/NdFk4 (last accessed May 16, 2025).
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`signals to consumers that the product is generally more natural and healthful overall.
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`48. As aresult, representations such as “100% Natural Flavors” have become a
`significant factor in consumer purchasing decisions, leading consumers to prefer—
`and ultimately purchase—products that prominently make such claims over those
`that do not.
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`49. Recognizing this consumer demand, Coca-Cola deliberately sought to exploit
`it by prominently marketing the Products with bold and conspicuous “100% Natural
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`Flavors” claims—both in advertising and on product packaging—in order to
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`capitalize on consumers’ recognition of, and preference for, such representations.
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`50. Coca-Cola sought to capitalize on consumers' preferences by promoting the
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`11 || Class Products not merely with a vague or general “natural flavors” claim, but with
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`12 || highly specific assertions of “100% Natural Flavors” (emphasis added) and similar
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`%EE 14 || 51. A reasonable consumer understands that when a product explicitly claims to
`9 8 15 || be made with “100% Natural Flavors,” it does not contain flavoring ingredients that
`< % 16 || are synthetically derived or sourced from anything other than natural materials.
`5% 17 || 52. Inthe case of the Class Products, Coca-Cola prominently displays the “100%
`I ; 18 || Natural Flavors” representation on the packaging and heavily features it throughout
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`19 || its marketing materials and marketing materials of retailers.
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`20 || 53. Below are non-exhaustive examples of the aforementioned representations
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`21 || appearing on the packaging and in the marketing of the Class Products.!”
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`27 [ Images include representations found on Coca-Cola’s websites at
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`)3 https://www.coca-cola.com/us/en/brands/sprite/products and https://www.coca-
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`cola.com/us/en/brands/fanta/products (last accessed May 16, 2025).
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`Case 2:25-cv-04777-GW-AGR Document1 Filed 05/27/25 Page 12 of 64 Page ID
`#:12
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`CLASS ACTION COMPLAINT 11
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`KAZEROUNI
`LAW GROUP. APC
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`7
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`21
`22
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`24
`25
`26
`27
`28
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`Case 2:25-cv-04777-GW-AGR Document 1 Filed 05/27/25 Page 13 of 64
`
`#:13
`
`Sprl 1 ® LEMON-LIME SODA
`
`100% NATURAL
`
`LEMON-LIME NOCAFFEINE
`
`L, [ [ S—
`
`10-7.5 FL OZ CANS (75 FL 02) @@& 2,
`10-222 mL CANS (2.21) Lo |
`
`LEMON-LIME
`
`Page ID
`
`Sprite Mini-Can 7.50z
`Visit the Sprite Store
`47 s kkdr v 22,749 ratings | Search this page
`
`10K+ bought in past month
`
`$598 5080/ #102)
`
`Get Fast, Free Shipping with Amazon Prime
`
`Apply now and get a $10 Amazon Gift Card upon approval of the Amazon Store Card, or see if you pre-
`qualify with no impact to your credit bureau score.
`
`SNAP EST eligible
`
`4
`
`Flavor Name: Sprite
`
`|
`[ |
`
`= Sprite Lemon-lime Sprite Zero
`" zero Sugar
`- $5.98 See available See available
`e ($0.80 / 1 02) options options.
`
`Size: 7.5 Fl Oz (Pack of 10)
`
`7.5 Fl Oz (Pack of 10) | | 7.5 FlL Oz (Pack of 6) 7.5 Ounce Mini Cans
`(Pack of 20)
`
`12 Fl Oz (Pack of 12) | | 16.9 fl oz (Pack of 6) 16.9 Oz Bottles (Pack of
`12)
`
`0 Ing '
`1 |
`
`EMON-LIME
`
`— —
`
`7.5 fl oz (Pack of 10) | | 144 FL Oz (Pack of 12)
`
`Package Information Can
`
`« A pack of 10, 7.5 fl oz Mini cans
`« Introduced in 1961, Spnte is the world's leading lemon-lime flavored soft drink; it has a crisp,
`
`« Perfect size for drinking with meals, on the go, or any time.
`
`Ingredients v
`
`About this item A
`Roll over image to zoom in )
`
`Brand Sprite
`
`Item Form Liquid
`
`Flavor Sprite
`
`Number of items 10
`
`CLASS ACTION COMPLAINT 12
`
`
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`
`
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`KAZEROUNI
`LAW GROUP. APC
`
`7
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`Case 2:25-cv-04777-GW-AGR Document 1
`
`Filed 05/27/25 Page 14 of 64 Page ID
`
`#:14
`
`Colorless, lemon-lime soft drink witl affeine-free. Sprite Zero Sugar
`- zero-calorie, sugar-free soda - is @ 2 e for drinking with meals, on
`the go, or any time. Sprite soda is Available in 7.5 FL OZ mini cans, 8 FL. OZ botties, 8.5 FL
`OZ botties, 10 FL OZ cans, 12 FL OZ cans, 12 FL OZ bottles, 16 FL OZ cans, 16 FL OZ
`bottles, 16.9 FL OZ bottles, 20 FL OZ bottles, 24 FL OZ bottles, 1 liter bottles, 1.25 liter
`bottles, 2 liter bottles, 3 liter bottles, and a variety of multi-packs.
`
`@ Categories Deals New & featured Pickup & delivery sprite & x Q @® signin
`) Shop all Sprite
`® See ! deal for this Sem
`| 9567
`Details A
`Highlights
`
`satisfied fans for over 50 years with its intense, but crisp and refreshing lemon-lime flavor
`combination. And there are a whole bunch of other Sprite products to enjoy. Each is perfectly
`designed to complement the crisp classic lemon-lime flavor. Crack open the iconic green can
`or bottie and enjoy refreshing and crisp citrus taste today. Sprite is caffeine-free and comes in
`7.5 FL. OZ mini cans, 8 FL OZ bottles, 8.5 FL OZ bottles, 10 FL OZ cans, 12 FL OZ cans, 12 FL
`OZ bottles, 16 FL OZ cans, 16 FL. OZ bottles, 16.9 FL OZ bottles, 20 FL OZ botties, 24 FL OZ
`botties, 1 liter bottles, 1.25 liter bottles, 2 liter bottles, 3 liter bottles, and a variety of multi-
`packs. Check out the iconic refreshment on a shelf near you or buy Sprite online and have it
`delivered straight to your dooe. Sprite ingredients include carbonated water, high fructose com
`syrup, citric acid and other natural flavors. Each 12 oz serving, or Sprite can, has 100 calories
`and 279 of sugar. Sprite is not a significant source of fat, trans fat, cholesterol, dietary fiber,
`vitamin D, calcium, iron and potassium. View nutrition label for complete Sprite nutrition facts &
`ingredient list. Introduced in 1961, Sprite is the world's leading lemon-lime flavored soft drink.
`Sprite is produced by the Coca-Cola Company and is sold in more than 190 countries. All
`Sprite flavor options are caffeine-free and deliver delicious, thirst-quenching refreshment with
`every sip. Sprite Flavors: Sprite, Sprite Zero Sugar, Sprite Cherry, Sprite Cherry Zero Sugar,
`Sprite Tropical Mix, Sprite Lymonade, Sprite Ginger, and Sprite Ginger Zero Sugar.
`
`=]
`
`~ t » Q How do you want your items?
`
`"‘ Santa Ana, 92704 - Santa Ana Superce
`
`86 Departments 33 Services v | PharmacyDelivery New
`
`Search everything at Walmart online and in store
`
`Easter Mother's Day LocalFinds Fashion Home Patio & Garden
`
`Visit the Sprite Store
`
`Lemon-lime flavored soda with a cooling sensation and strawberry
`kiwi flavor
`
`Limited Edition soda with refreshing, crisp, lemon-lime taste
`Caffeine-free with 100% natural flavors
`
`Satisfying, cut-through refreshment you love from Sprite with an
`unexpectedly cold taste that intensifies after every sip
`
`Alemon-lime burst of crispness paired with a unique blend of citrusy
`
`Sprite Chill Strawberry Kiwi Fridge Pack Cans, 12 fl 0z, 12
`
`Pack
`
`(34) | 29ratings
`Ingredients v
`About this item
`
`Eleq
`
`and strawberry flavors
`* Obey Your Thirst
`Only at Walmart .
`Viewsll Y View full item details
`CLASS ACTION COMPLAINT 13
`
`
`
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`
`
`
`
`
`I
`
`LAW GROUP, APC
`
`KAZEROU
`
`7
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`N NN N N N N N N M= e e e ek e e
`(o< I BN e) NV, B SN VS B S =N R <N BN e ) WU, B SN US T O B e BN ENe <N e LY, B~ US B \O)
`
`Case 2:25-cv-04777-GW-AGR Document 1
`#:15
`
`Filed 05/27/25
`
`Page 15 of 64 Page ID
`
`\'I 9 How do you want your items? -
`Search everything at Walmart online and in store
`’.\ Santa Ana, 92704 - Santa Ana Superce. b
`28 Departments Vv 22 Services v | Pharmacy Delivery New Easter Mother's Day LocalFinds Fashion Home Patio & Garden Electr,
`-
`- Visit the Sprite Store
`P [1] Sprite Tropical Mix Lemon Lime Soda Pop, 20 fl oz Bottle
`& /,fl o 45) | ISratings
`A\
`/ - @ Pack Size: Single
`[
`. Single
`Sp r See more seller options
`TROPICAL MIX Ingredients v
`W About this item
`sy * Take it back to the 2000s and sip refreshing Sprite Tropical Mix soda
`TROPICAL * (Clear, crisp lemon-lime soda with the perfect remix of tropical
`2 o oz strawberry and pineapple flavors that will keep you invigorated and
`| M 'x inspired
`4 5 P * Adelicious citrus taste that knows how to keep things cool
`View all . * Caffeine-free, full of 100% natural flavors
`* 20 floz bottle to help you cut through the noise
`w Search Q @ 19001 Brookhurst St, Huntingto... 8 Account
`Prescriptions Health Services Shopv Savingsv Photov Morev Weekly Ad Easter Shop Vaccinations Es)
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`Home > Shop > Grocery & Beverages > Beverages > Soda
`
`“Restrictions spply
`- A
`= oz
`=R Eil
`Bax
`‘ o '
`
`Description
`
`100% natural flavors.
`
`No caffeine.
`
`Made with 1% real juice.
`
`220 calories per bottle.
`
`A product of The Coca-Cola Company.
`
`FREE 1-Hour Delivery on $35° _ @ g
`
`Shop all Sprite
`
`@ [fi[] Store Pickup
`
`Not sold at 19001 BROOKHURST
`ST, HUNTINGTON BEACH, CA
`92646
`
`Sprite Soda Lymonade 20 oz.
`Bottle, 20.0 fl oz
`
`44 Jedkekokyfy 632
`2/$5.00 or 1/$2.99
`
`Extra 15% off $35 Sitewide code
`
`Check other stores
`
`EGG15 or Extra 20% off $50 code
`
`EGG20 () [6 same Day Delivery
`As soon as 1hour or schedule
`delivery.
`
`Sign in to unlock savings and earn
`myWalgreens cash rewards on every
`purchase
`
`@ Shipping
`
`= Save to shopping list
`
`Lemon-lime & lemonade flavored soda with real juice & other natural flavors.
`
`CLASS ACTION COMPLAINT
`
`14
`
`
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`W
`3
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`K
`
`EROUNI
`GROUP, APC
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`Case 2:25-cv-04777-GW-AGR Document 1
`#:16
`
`Filed 05/27/25
`
`Page 16 of 64
`
`Page ID
`
`Sprite
`The OG, the flavor that started it all—classic, cool, crisp
`
`lemon-lime taste that's caffeine free with 100% natural
`E
`
`flavors.
`
`e
`
`Available Sizes: 7.5 fl 0z, 8 floz, 12 fl oz, 13.2fl 0z, 16.9 fl 0z,
`20 fl oz, 1 Liter, 1.25 Liters, 2 Liters, 3 Liters
`
`View Nutrition Facts A
`
`Nutrition Facts
`
`1 serving per container
`
`Serving Size 1Can(12FLO2)
`
`Amount per serving
`Calories 140
`
`9% Daily Value*
`
`Nutritional Composition
`
`Total FatOg 0%
`Sodium 65mg 3%
`Total Carbohydrate 38g 14%
`
`Total Sugars 38g -
`Includes Added Sugars 389 76%
`Protein Og -
`
`Ingredients
`
`CARBONATED WATER, HIGH FRUCTOSE CORN SYRUP,
`CITRIC ACID, NATURAL FLAVORS, SODIUM CITRATE,
`SODIUM BENZOATE (TO PROTECT TASTE).
`
`J 100% NATURAL FLAVORS NO CAFFEINE
`
`* Not a significant source of saturated fat, trans fat, cholesterol, dietary
`fiber, vitamin D, calcium, iron and potassium.
`
`CLASS ACTION COMPLAINT 15
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`Case 2:25-cv-04777-GW-AGR Document1l Filed 05/27/25 Page 17 of 64 Page ID
`#:17
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`O 0 9 N N B WD =
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`(RANGE SODA
`
`WTRALLY FAVORED
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`49000-04121
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`REFRESCO DE NARANJA
`SABORIZADO
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`NS I \C T \O B N
`0 3 N W
`
`CLASS ACTION COMPLAINT 16
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`I
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`LAW GROUP, APC
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`KAZEROU
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`3
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`
`Case 2:25-cv-04777-GW-AGR
`
`Document1l Filed
`
`#:18
`
`05/27/25 Page 18 of 64 Page ID
`
`Home Products
`
`FANTA PINA COLADA
`
`Fanta Pifla Colada i