Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 1 of 22
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`UNITED STATES DISTRICT COURT
`DISTRICT OF CONNECTICUT
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`Tonya Akes, individually and on behalf of all
`others similarly situated,
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` Plaintiff,
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`v.
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`Beiersdorf, Inc.
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` Defendant.
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`Case No. 3:22-cv-869
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`JURY TRIAL DEMANDED
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`JULY 11, 2022
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`Class Action Complaint
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`i
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 2 of 22
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`Table of Contents
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`I.
`II.
`III.
`IV.
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`Introduction. ........................................................................................................................ 1
`Parties. ................................................................................................................................. 2
`Jurisdiction and venue......................................................................................................... 2
`Facts. ................................................................................................................................... 3
`Defendant makes, markets, distributes and sells Coppertone Sport Mineral
`A.
`and Coppertone Sport Mineral FACE sunscreen lotions. ....................................... 3
`The Coppertone Sport Mineral FACE label is misleading to reasonable
`consumers. .............................................................................................................. 9
`Plaintiff was misled by Defendant’s misrepresentations. ..................................... 10
`C.
`Class action allegations. .................................................................................................... 12
`V.
`Claims. .............................................................................................................................. 14
`VI.
`Jury demand. ..................................................................................................................... 19
`VII.
`VIII. Relief. ................................................................................................................................ 19
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`B.
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`ii
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 3 of 22
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`I.
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`Introduction.
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`1.
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`Defendant makes, distributes, sells, and markets “Coppertone Sport Mineral”
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`sunscreen. Defendant sells several products in the “Coppertone Sport Mineral” line. One of
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`those products, the “Coppertone Sport Mineral FACE” lotion, is prominently labelled “FACE.”
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`The front of the product also prominently touts that the sunscreen “Won’t Run Into Eyes” and is
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`“Oil Free.”
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`2.
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`These prominent representations lead reasonable consumers to believe that the
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`Sport Mineral FACE lotion is specifically designed for the face. And based on this reasonable
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`belief, they are willing to pay more for the product. In fact, per ounce, the Sport Mineral FACE
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`1
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 4 of 22
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`lotion costs twice as much as Coppertone’s regular (i.e., non-face) Sport Mineral lotion. But
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`reasonable consumers buy it anyway, because they want a product that is specifically formulated
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`for use on their face.
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`3.
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`The truth, however, is that the Coppertone Sport Mineral FACE lotion is exactly
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`the same as the regular Coppertone Sport Mineral lotion. Defendant is putting the same
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`sunscreen into two different bottles with different labels. Consumers are being deceived and
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`overcharged.
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`II.
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`Parties.
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`4.
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`5.
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`6.
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`Plaintiff Tonya Akes is a citizen of California (domiciled in Fresno).
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`The proposed class(es) include citizens of numerous states.
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`Defendant Beiersdorf, Inc. is a Delaware corporation with its principal place of
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`business in Wilton, Connecticut. Defendant makes, labels, distributes, sells, and markets the
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`Coppertone Sport Mineral FACE products. Defendant is responsible for the making, labelling,
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`distribution, selling, and marketing of the Coppertone Sport Mineral FACE products throughout
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`the applicable statute of limitations period.
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`III.
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`Jurisdiction and venue.
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`7.
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`This Court has subject matter jurisdiction under 28 U.S.C. § 1332(d)(2). The
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`amount in controversy exceeds the sum or value of $5,000,000, exclusive of interest and costs,
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`and the matter is a class action in which one or more members of the proposed class(es) are
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`citizens of a state different from the Defendant.
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`8.
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`The Court has personal jurisdiction over Defendant. Defendant has its principal
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`place of business here.
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`9.
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`Venue is proper under 28 U.S.C. § 1391(b)(1) and 28 U.S.C. § 1391(d).
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`Defendant would be subject to personal jurisdiction in this District if this District were a separate
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`2
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 5 of 22
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`state. Defendant has its principal place of business here. And Defendant sells the Coppertone
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`Sport Mineral FACE products here.
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`IV.
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`Facts.
`A.
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`Defendant makes, markets, distributes and sells Coppertone Sport Mineral
`and Coppertone Sport Mineral FACE sunscreen lotions.
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`10.
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`Defendant makes, markets, distributes and sells the Coppertone Sport Mineral line
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`of sunscreens.
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`11.
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`The Coppertone Sport Mineral line of sunscreens includes various products such
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`as lotions and spray bottles, each with various SPF ratings.
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`12.
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`One of the products in the Coppertone Sport Mineral line is the regular
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`Coppertone Sport Mineral lotion. It comes in 5-ounce bottles. An example is shown below: 1
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`1 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Sunscreen-SPF-50-Lotion-
`Zinc-Oxide-UVA-UVB-Protection-5-fl-oz/286215538
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`3
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 6 of 22
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`13.
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`Another product in the Coppertone Sport Mineral line is the Coppertone Sport
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`Mineral FACE lotion. It comes in smaller, 2.5-ounce bottles. An example is shown below: 2
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`2 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Face-Sunscreen-Lotion-SPF-
`50-2-5oz/789123873?athbdg=L1600
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`4
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 7 of 22
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`14.
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`The label of the Coppertone Sport Mineral FACE lotion is almost identical to that
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`of the regular Coppertone Sport Mineral lotion, with one important exception: the FACE lotion
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`is prominently labelled “FACE.” And it includes face-specific representations, such as “Won’t
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`Run Into Eyes” and “Oil Free”. 3
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`3 “Oil-free” is important for face use because, as consumers know, oil can clog pores and
`lead to break outs on the face.
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`5
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 8 of 22
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`15.
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`These representations are materially the same across all Coppertone Sport Mineral
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`FACE lotions. That is, all the labels of all Coppertone Sport Mineral FACE lotions are
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`substantially similar.
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`16.
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`Both the regular Coppertone Sport Mineral and the Coppertone Sport Mineral
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`FACE lotions recently got a “new look.” This is shown below:
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`Regular 4:
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`4 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Sunscreen-SPF-50-Lotion-
`Zinc-Oxide-UVA-UVB-Protection-5-fl-oz/286215538
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`6
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 9 of 22
`Case 3:22-cv-00869-AVC Document1 Filed 07/11/22 Page 9 of 22
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`NEW LOOK!
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`Coppertone.
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`100%Naturally
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`Seureed Zinc Oxide
`7 amit THONG
`
`50
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`Coppertone.
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`
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`¥
`SOURCED ZINC OXIDE
`RESETS,
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`100% NATURALL
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`SAME TRUSTED SUN PROTECTION
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`
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`7
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 10 of 22
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`FACE 5:
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`17.
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`As the pictures show, the “old” labels are substantially similar to the “new” ones.
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`In particular, both the old and new labels for the Coppertone Sport Mineral FACE lotion are
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`5 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Face-Sunscreen-Lotion-SPF-
`50-2-5oz/789123873?athbdg=L1600
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`8
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 11 of 22
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`prominently labelled “FACE” and include the same prominent face-specific representations:
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`“Won’t Run Into Eyes” and “Oil Free.”
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`B.
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`The Coppertone Sport Mineral FACE label is misleading to reasonable
`consumers.
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`18.
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`Based on the prominent “FACE” marking and face-specific representations on the
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`front label of the Coppertone Sport Mineral FACE products, reasonable consumers believe that
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`the lotion is specifically formulated for use on the face. In other words, reasonable consumers
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`believe that there is something different about the Coppertone Sport Mineral FACE lotion that
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`makes it better suited for use on the face, as compared to regular Coppertone Sport Mineral
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`lotion.
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`19.
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`The pricing of Coppertone Sport Mineral FACE reinforces this reasonable belief.
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`Per ounce, Coppertone Sport Mineral FACE costs twice as much as regular Coppertone Sport
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`Mineral. For example, Walmart sells 2.5-ounce containers of SPF 50 Coppertone Sport Mineral
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`FACE for $9.98—$3.99/ounce. 6 And it sells 5-ounce containers of regular SPF 50 Coppertone
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`Sport Mineral for $9.98—$1.99/ounce. 7 The same is true for other retailers: per ounce, “FACE”
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`costs twice as much as regular Coppertone Sport Mineral. 8
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`20.
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`The difference in pricing further indicates to reasonable consumers that the FACE
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`product is specially formulated for the face, while the regular product is not, thus justifying the
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`difference in price.
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`6 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Face-Sunscreen-Lotion-SPF-
`50-2-5oz/789123873?athbdg=L1600
`7 https://www.walmart.com/ip/Coppertone-Sport-Mineral-Sunscreen-SPF-50-Lotion-
`Zinc-Oxide-UVA-UVB-Protection-5-fl-oz/286215538
`8 For example, on Amazon.com, regular Coppertone Sport Mineral and Coppertone Sport
`Mineral FACE are $9.98—even though the bottle of regular Coppertone Sport Mineral is twice
`as large. Likewise, on Walgreens.com, regular Coppertone Sport Mineral and Coppertone Sport
`Mineral FACE are both $11.99—even though the bottle of regular Coppertone Sport Mineral is
`twice as large.
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`9
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 12 of 22
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`21.
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`The truth, however, is different. Coppertone Sport Mineral FACE is not specially
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`formulated for the face. Nor is it more expensive to manufacture. Quite the opposite, it is
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`identical to regular Coppertone Sport Mineral, which costs half as much. Defendant is taking the
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`same exact product and putting it in two different bottles, one prominently marked “FACE” and
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`one not. And then it is charging twice as much for the sunscreen in the bottle marked “FACE.”
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`In short, Defendant is tricking consumers into thinking they are buying sunscreen lotion specially
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`formulated for the face, when in reality, they are just buying Defendant’s regular Sport Mineral
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`sunscreen in a smaller—and far more expensive—bottle.
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`22.
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`That Defendant is able to charge twice as much for Coppertone Sport Mineral
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`sunscreen when it is prominently labelled “FACE” and includes face-specific representations
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`demonstrates that Defendant’s labelling is misleading. No reasonable consumer who understood
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`that Coppertone Sport Mineral FACE is identical to regular Coppertone Sport Mineral would
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`choose to pay twice as much for it. So the very fact that Defendant is able to sell Coppertone
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`Sport Mineral FACE sunscreen demonstrates that its labelling is misleading consumers.
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`C.
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`23.
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`Plaintiff was misled by Defendant’s misrepresentations.
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`In or around June 2022, Ms. Akes bought a 2.5-ounce bottle of Coppertone Sport
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`Mineral FACE at a Walmart Supercenter in Fresno, CA. The package said “FACE” prominently
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`on the label. The product also stated “Won’t Run Into Eyes” and “Oil Free.” A picture of the
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`bottle is shown below:
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`10
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 13 of 22
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`24. Ms. Akes read and relied on the “FACE” statement, as well as the additional face-
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`specific representations on the front label of the product, when she purchased the product. Based
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`on these representations, Ms. Akes believed that the product was specially formulated for use on
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`the face, and bought it specifically for this reason. Ms. Akes would not have purchased this
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`product if she had known that the product was, in fact, identical to regular Coppertone Sport
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`Mineral FACE, which costs half as much. Moreover, the price Ms. Akes paid for this product
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`was inflated due to the misleading FACE and face-specific representations. Had she known the
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`truth, Ms. Akes could have purchased the same product for half as much per ounce as she paid.
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`11
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 14 of 22
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`V.
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`Class action allegations.
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`25.
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`Plaintiff brings certain claims on behalf of the proposed class of: all persons who
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`purchased a Coppertone Sport Mineral FACE Product in the United States during the applicable
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`statute of limitations (the “Nationwide Class”).
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`26.
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`For certain claims, Plaintiff brings those claims on behalf of a subclass of
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`consumers who live in certain identified states (the “Consumer Protection Subclass”).
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`27.
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`For certain claims, Plaintiff brings those claims on behalf of a subclass of
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`consumers who, like Plaintiff, purchased a Coppertone Sport Mineral FACE Product in
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`California (the “California Subclass”).
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`28.
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`The following people are excluded from the Class and the Subclasses: (1) any
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`Judge or Magistrate Judge presiding over this action and the members of their family; (2)
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`Defendants, Defendants’ subsidiaries, parents, successors, predecessors, and any entity in which
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`the Defendants or its parents have a controlling interest and their current employees, officers and
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`directors; (3) persons who properly execute and file a timely request for exclusion from the
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`Class; (4) persons whose claims in this matter have been finally adjudicated on the merits or
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`otherwise released; (5) Plaintiffs’ counsel and Defendants’ counsel, and their experts and
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`consultants; and (6) the legal representatives, successors, and assignees of excluded persons.
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`Numerosity
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`29.
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`The proposed class(es) contain members so numerous that separate joinder of
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`each member of the class is impractical. Based on the pervasive distribution of Coppertone
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`Sport Mineral FACE products, there are hundreds of thousands of proposed class members (or
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`more).
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`Commonality
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`30.
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`There are questions of law and fact common to the proposed class(es). Common
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 15 of 22
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`questions of law and fact include, without limitation:
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` Whether the Coppertone Sport Mineral FACE products are formulated
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`specifically for use on the face;
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` Whether Defendant’s labelling and pricing of the Coppertone Sport Mineral
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`FACE products is misleading;
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` Whether Defendant violated state consumer protection statutes;
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` Damages needed to reasonably compensate Plaintiff and the proposed class(es).
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`Typicality
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`31.
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`Plaintiff’s claims are typical of those of the proposed class(es). Like the proposed
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`class(es), Plaintiff purchased a Coppertone Sport Mineral FACE product. Like the proposed
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`class(es), Plaintiff would not have purchased the products, or would have paid less for them, had
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`she known the truth.
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`Predominance and Superiority
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`32.
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`The prosecution of separate actions by individual members of the proposed
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`class(es) would create a risk of inconsistent or varying adjudication with respect to individual
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`members, which would establish incompatible standards for the parties opposing the class. For
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`example, individual adjudication would create a risk that the same label is found to be actionably
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`misleading for some proposed class members, but not others.
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`33.
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`Common questions of law and fact predominate over any questions affecting only
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`individual members of the proposed class(es). These common legal and factual questions arise
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`from certain central issues which do not vary from class member to class member, and which
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`may be determined without reference to the individual circumstances of any particular class
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`member. For example, a core liability question is common: whether Defendant’s labelling is
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`misleading to reasonable consumers.
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`34.
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`A class action is superior to all other available methods for the fair and efficient
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`adjudication of this litigation because individual litigation of each claim is impractical. It would
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`be unduly burdensome to have individual litigation of thousands of individual claims in separate
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`lawsuits, every one of which would present the issues presented in this lawsuit.
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`VI. Claims.
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`Count I: Violations of State Consumer Protection Acts
`(on behalf of Plaintiff and the Consumer Protection Subclass)
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`35.
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`Plaintiff incorporates by reference each and every factual allegation set forth
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`above.
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`36.
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`As alleged below, Plaintiff (who lives in California) brings her individual and
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`certain subclass claims based on California consumer protection laws. At the motion to dismiss
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`stage (pre-certification), her claims are governed by California law. At certification, Plaintiff
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`intends to certify this count on behalf of the Consumer Protection Subclass, which includes
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`consumers who live in the states listed below, which have materially-similar laws.
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`
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`State
`California
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`Illinois
`Maryland
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`New York
`Missouri
`Washington
`Connecticut
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`Statute
`Cal. Bus. & Prof. Code § 17200, and the
`following; Id. §17500, and the following
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`Cal. Civ. Code §1750 and the following.
`815 ILCS § 501/1, and the following.
`Md. Code Ann. Com. Law, § 13-301, and the
`following.
`N.Y. Gen. Bus. Law § 349, and the following.
`Mo. Rev. Stat. § 407, and the following.
`Wash. Rev. Code § 19.86.010, and the following.
`Conn. Gen. Stat. Ann. §§ 42-110, and the
`following.
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`37.
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`Each of these statutes is materially similar to California consumer protection law.
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`Each broadly prohibits deceptive conduct in connection with the sale of goods to consumers. No
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 17 of 22
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`state requires proof of individualized reliance, or proof of defendant’s knowledge or intent to
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`deceive. Instead, it is sufficient that the deceptive conduct is misleading to reasonable
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`consumers acting reasonably under the circumstances and that the conduct proximately caused
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`harm. As alleged in detail above, Defendant’s conduct violates each statute’s shared
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`prohibitions.
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`38.
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`Defendant’s conduct, including the misleading labelling of the Coppertone Sport
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`Mineral FACE products with the “FACE” representation and related face-specific
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`misrepresentations, and the sale of those products to Plaintiff and Class members, violates each
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`statute’s prohibitions. Plaintiff saw and relied on these representations.
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`39.
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`Defendant’s representations were material, i.e., a reasonable consumer would
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`consider them important in deciding whether to buy the Coppertone Sport Mineral FACE
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`products. As alleged in detail above, these misrepresentations are important to consumers and
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`affect their choice to purchase the products. And no reasonable consumer who knew the truth
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`would choose to pay twice as much for the same thing.
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`40.
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`Defendant’s misrepresentations were a substantial factor in Plaintiff’s purchase
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`decisions and the purchase decisions of class members, and were a substantial factor and
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`proximate cause in causing damages and losses to Plaintiff and class members, including the
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`price premium that Plaintiff and class members paid.
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`41.
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`Plaintiff and class members were injured as a direct and proximate result of
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`Defendant’s conduct because (a) they would not have purchased Coppertone Sport Mineral
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`FACE products if they had known the truth and (b) they overpaid for the products because the
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`products are sold at a price premium due to the misrepresentation.
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 18 of 22
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`Count II: Violation of California’s Unfair Competition Law (UCL)
`(on behalf of Plaintiff and the California Subclass)
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`42.
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`Plaintiff incorporates by reference and re-alleges each and every factual allegation
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`set forth above as though fully set forth herein.
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`43.
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`Plaintiff brings this cause of action on behalf of herself and members of the
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`California Subclass.
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`44.
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`Defendant has violated California’s Unfair Competition Law (UCL) by engaging
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`in unlawful, fraudulent, and unfair conduct (i.e., violating each of the three prongs of the UCL).
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`45.
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`The Unlawful Prong: Defendant engaged in unlawful conduct by violating the
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`California Sherman Act, Cal. Health & Safety Code § 110390, which prohibits drug and
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`cosmetics labelling that is “false or misleading in any particular.” In addition, Defendant
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`engaged in unlawful conduct by violating the FAL, as alleged below and incorporated here.
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`46.
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`The Fraudulent Prong: As alleged in detail above, Defendant’s representations
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`were false and misleading. Defendant’s misrepresentations were likely to deceive, and did
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`deceive, Plaintiff and reasonable consumers.
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`47.
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`The Unfair Prong: Defendant violated established public policy by violating the
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`CLRA and FAL, as alleged below and incorporated here. The unfairness of this practice is
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`tethered to a legislatively declared policy (that of the Sherman Act and FAL).
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`48.
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`The harm to Plaintiff and the Subclass greatly outweighs the public utility of
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`Defendant’s conduct. There is no public utility to misleading consumers into thinking that
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`sunscreen not specifically formulated for the face is formulated specifically for the face, and
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`overcharging them for it. This injury was not outweighed by any countervailing benefits to
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`consumers or competition. Misleading labels only injure healthy competition and harm
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`consumers.
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 19 of 22
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`49.
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`Defendant’s conduct, as alleged above, was immoral, unethical, oppressive,
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`unscrupulous, and substantially injurious to consumers.
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`50.
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`Plaintiff and the Subclass could not have reasonably avoided this injury. As
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`alleged above, Defendant’s representations were deceiving to reasonable consumers like
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`Plaintiff.
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`* * *
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`51.
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`For all prongs, Defendant’s misrepresentations were intended to induce reliance,
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`and Plaintiff saw, read and reasonably relied on them when purchasing Coppertone Sport
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`Mineral FACE sunscreen. Defendant’s misrepresentations were a substantial factor in Plaintiff’s
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`purchase decision.
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`52.
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`Classwide reliance can be inferred because Defendant’s misrepresentations were
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`material, i.e., a reasonable consumer would consider them important in deciding whether to buy
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`Coppertone Sport Mineral FACE sunscreen.
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`53.
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`Defendant’s misrepresentations were a substantial factor and proximate cause in
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`causing damages and losses to Plaintiff and Subclass members.
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`54.
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`Plaintiff and Subclass members were injured as a direct and proximate result of
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`Defendant’s conduct because (a) they would not have purchased Coppertone Sport Mineral
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`FACE products if they had known the truth and (b) they overpaid for the products because the
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`products are sold at a price premium due to the misrepresentation.
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`Count III: Violation of California’s False Advertising Law (FAL)
`(on behalf of Plaintiff and the California Subclass)
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`55.
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`Plaintiff incorporates by reference and re-alleges each and every allegation set
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`forth above as though fully set forth herein.
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`56.
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`Plaintiff brings this cause of action on behalf of herself and members of the
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 20 of 22
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`California Subclass.
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`57.
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`As alleged more fully above, Defendant has falsely advertised Coppertone Sport
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`Mineral FACE products by falsely representing that the products were specifically formulated
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`for use on the face, when in fact the products are identical to regular Coppertone Sport Mineral.
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`58.
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`Defendant’s representations were likely to deceive, and did deceive, Plaintiff and
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`reasonable consumers. Defendant knew, or should have known through the exercise of
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`reasonable care, that these statements were inaccurate and misleading.
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`59.
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`Defendant’s misrepresentations were intended to induce reliance, and Plaintiff
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`saw, read and reasonably relied on them when purchasing a Coppertone Sport Mineral FACE
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`product. Defendant’s misrepresentations were a substantial factor in Plaintiff’s purchase
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`decision.
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`60.
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`Classwide reliance can be inferred because Defendant’s misrepresentations were
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`material, i.e., a reasonable consumer would consider them important in deciding whether to buy
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`Coppertone Sport Mineral FACE.
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`61.
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`Defendant’s misrepresentations were a substantial factor and proximate cause in
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`causing damages and losses to Plaintiff and Subclass members.
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`62.
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`Plaintiff and Subclass members were injured as a direct and proximate result of
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`Defendant’s conduct because (a) they would not have purchased Coppertone Sport Mineral
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`FACE products if they had known the truth and (b) they overpaid for the products because the
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`products are sold at a price premium due to the misrepresentation.
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`Count IV: Quasi-Contract / Unjust Enrichment
`(on behalf of Plaintiff and a Nationwide Class)
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`63.
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`Plaintiff incorporates by reference and re-alleges each and every allegation set
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`forth above as though fully set forth herein.
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 21 of 22
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`64.
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`65.
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`Plaintiff alleges this claim individually and on behalf of a Nationwide Class.
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`As alleged in detail above, Defendant’s false and misleading labelling caused
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`Plaintiff and the Nationwide Class to purchase Coppertone Mineral Sport FACE to pay twice as
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`much for these products.
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`66.
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`In this way, Defendant received a direct and unjust benefit, at Plaintiff and the
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`Nationwide Class’s expense.
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`67.
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`Plaintiff and the Nationwide Class seek restitution.
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`VII. Jury demand.
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`68.
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`Plaintiff demands a jury trial on all issues so triable.
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`VIII. Relief.
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`69.
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`Plaintiff seeks the following relief individually and for the proposed class(es):
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` An order certifying the asserted claims, or issues raised, as a class action;
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` A judgment in favor of Plaintiff and the proposed class(es);
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` Damages;
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` Restitution;
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` Disgorgement, and other just equitable relief;
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` Pre- and post-judgment interest;
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` Reasonable attorneys’ fees and costs, as allowed by law;
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` Any additional relief that the Court deems reasonable and just.
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`Case 3:22-cv-00869-AVC Document 1 Filed 07/11/22 Page 22 of 22
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`Date: July 11, 2022
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`Respectfully submitted,
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`By: /s/ Craig A. Raabe
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`IZARD, KINDALL & RAABE LLP
`Craig A. Raabe (ct04116)
`Seth R. Klein (ct18121)
`29 South Main Street, Suite 305
`West Hartford, CT 06107
`T: (860) 493-6292
`F: (860) 493-6290
`craabe@ikrlaw.com
`
`DOVEL & LUNER, LLP
`Simon Franzini (Cal. Bar No. 287631)*
`simon@dovel.com
`Jonas B. Jacobson (Cal. Bar No. 269912)*
`jonas@dovel.com
`201 Santa Monica Blvd., Suite 600
`Santa Monica, California 90401
`T: (310) 656-7066
`F: (310) 656-7069
`
`Counsel for Plaintiff
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`*Pro Hac Vice Forthcoming
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`20
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