Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 1 of 15
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`MIAMI DIVISION
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`Yesenia Valiente, individually and on behalf of
`all others similarly situated,
`
`
`
`Plaintiff,
`
`Class Action Complaint
`
`- against -
`
`Jury Trial Demanded
`
`Unilever United States, Inc.,
`
`Defendant
`
`
`
`
`
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`Plaintiff alleges upon information and belief, except for allegations pertaining to Plaintiff,
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`which are based on personal knowledge:
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`1. Unilever United States, Inc. (“Defendant”) sells antiperspirant deodorant with added
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`moisturizers containing natural oil under the Dove Advanced Care brand (“Product”).
`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`MIAMI DIVISION
`
`Yesenia Valiente, individually and on behalf of
`all others similarly situated,
`
`
`
`Plaintiff,
`
`Class Action Complaint
`
`- against -
`
`Jury Trial Demanded
`
`Unilever United States, Inc.,
`
`Defendant
`
`
`
`
`
`
`Plaintiff alleges upon information and belief, except for allegations pertaining to Plaintiff,
`
`which are based on personal knowledge:
`
`1. Unilever United States, Inc. (“Defendant”) sells antiperspirant deodorant with added
`
`moisturizers containing natural oil under the Dove Advanced Care brand (“Product”).
`
`
`
`
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`
`
`
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 2 of 15
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`2.
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`The label statements include “¼ moisturizers with natural oil,” “go fresh,” a picture
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`of a fruit or vegetable with seeds, and identification of the active ingredient, “Aluminum
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`Zirconium Tetrachlorohydrex GLY.”
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`I.
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`NATURAL CLAIMS ARE IMPORTANT TO CONSUMERS
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`3.
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`Sales of cosmetics based on natural ingredients are growing twice the rate of
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`traditional cosmetics and exceed $50 billion per year.
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`4.
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`Consumers understand front label cosmetic claims of natural ingredients to mean the
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`entire product does not contain synthetic ingredients and/or all the ingredients of the type identified
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`in the product are natural.
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`5. According to Nielsen, whether a cosmetic product contains natural instead of
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`synthetic ingredients is very important to almost fifty percent of the public.
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`6. A recent academic publication concluded that consumers would pay at least ten
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`percent more for cosmetics with claims highlighting the presence of natural ingredients.
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`7.
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`There are several reasons why consumers prefer cosmetics with natural, instead of
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`synthetic ingredients.
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`8.
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`First, over three-quarters of U.S. adults believe cosmetics with synthetic ingredients
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`are associated with detrimental impacts on health and the environment.
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`9.
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`This is because such ingredients are highly processed with chemical additives and
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`solvents, which can cause irritation, allergic reactions, and other harmful effects.
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`10. Second, one scholar posited “the preference for natural products appeals to a moral
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`ideology and offers a moral satisfaction.”
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`II. NATURAL OIL CLAIM IS MISLEADING
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`11. Consumers interpret cosmetic claims and descriptions using the word “natural”
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`broadly.
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`12. The Product’s statement of “¼ moisturizers with natural oil” is understood by
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`consumers to mean the absence of any synthetic and/or synthetically derived ingredients.
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`13. The Product’s statement of “¼ moisturizers with natural oil” is understood by
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`consumers to mean all the oil ingredients are not synthetic, not produced through chemical
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`synthesis or by using chemical compounds, even if these any synthetic ingredients are purportedly
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`absent from the final ingredient.
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`A. Small Amount of Oil Ingredients
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`14. Despite the front label emphasis on “natural” oil, the two oils, “Hydrogenated Castor
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`Oil” and “Helianthus Annuus (Sunflower) Seed Oil,” are the sixth and twelfth ingredients in order
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`of predominance by weight.
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`
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`Active ingredient
`Purpose
`Aluminum Zirconium
`Tetrachlorohydrex GLY (15.2%)
`… antiperspirant
`Inactive ingredients
`Stearyl Alcohol, C12-15 Alkyl
`Benzoate, Cyclopentasiloxane,
`Isopropyl Palmitate, PPG-14
`Butyl Ether, Hydrogenated Castor
`Oil, PEG-8, Fragrance (Parfum),
`Dimethicone, Silica,
`Polyethylene, Helianthus Annuus
`(Sunflower) Seed Oil, Steareth-
`100, BHT.
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`
`
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`15. The amount of “natural” and synthetic oils in the Product is de minimis, relative to
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`the most predominant ingredients of “Stearyl Alcohol [and] C12-15 Alkyl Benzoate.”
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 4 of 15
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`B. Oils are Not Natural
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`16. Despite the promise of “natural oil,” the most predominant oil in the Product is
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`“Hydrogenated Castor Oil,” a synthetic ingredient.
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`17. Hydrogenated castor oil consists of synthetic polyethylene glycol and castor oil.
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`18. This is produced through ethoxylation, a chemical reaction in which ethylene oxide
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`is added to the substrate of castor oil.
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`19. Hydrogenated castor oil is added not for moisturizing but because it is a surfactant,
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`which lowers the surface tension between two substances.
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`20.
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`It is misleading to promote the Product with the claim of “natural oil” when its most
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`predominant oil, hydrogenated castor oil, is a synthetic ingredient.
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`21. While “Helianthus Annuus (Sunflower) Seed Oil,” produced from sunflower seeds,
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`may appear to be more “natural” than hydrogenated castor oil, it is made using chemical reactions
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`and industrial petrochemicals.
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`22. To obtain oil from sunflower seeds involves seed preparation, mechanical extraction,
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`and solvent extraction from the ground oilcakes or expanded material known as “collets.”
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`23. The solvent used to extract the oil is n-hexane.
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`24. N-hexane is an industrial chemical obtained from petroleum through fractional
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`distillation.
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`25. N-hexane contains structural isomers and chemicals, such as methyl pentane and
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`methyl cyclopentane, which are synthetic compounds.
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`26. N-hexane is recognized by public health authorities as a common skin irritant, which
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`can cause redness, blistering and superficial burns.
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`27. Medical authorities advise that anyone who may have come into contact with n-
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`hexane should immediately seek medical advice.
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 5 of 15
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`28. Disposal of n-hexane causes environmental damage to the air and water sources.
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`29.
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`It is misleading to promote the Product as made with “natural oil” because even
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`though sunflower seeds are a natural source, obtaining sunflower seed oil requires the ingredient
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`to undergo a manufacturing process replete with chemical reactions and the use of n-hexane, an
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`industrial petrochemical solvent.
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`30. Reasonable consumers do not expect sunflower seed oil, promoted as a “natural oil,”
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`to be made using synthetic compounds and undergo industrial manufacturing.
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`31. Since consumers prefer natural ingredients in products due to their beneficial health
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`and environmental effects over synthetic ingredients, it is misleading to highlight a “natural oil”
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`made using a synthetic chemical solvent, which in fact has detrimental health and environmental
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`effects.
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`32. Defendant makes other representations and omissions with respect to the Product
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`which are false and misleading.
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`33. Reasonable consumers must and do rely on a company to honestly and lawfully
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`market and describe the components, attributes, and features of a product, relative to itself and
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`other comparable products or alternatives.
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`34. The value of the Product that Plaintiff purchased was materially less than its value
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`as represented by Defendant.
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`35. Defendant sold more of the Product and at higher prices than it would have in the
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`absence of this misconduct, resulting in additional profits at the expense of consumers.
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`36. Had Plaintiff known the truth, she would not have bought the Product or would have
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`paid less for it.
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`37. As a result of the false and misleading representations, the Product is sold at a
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 6 of 15
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`premium price, approximately no less than $5.99 per 2.6 oz, excluding tax and sales, higher than
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`similar products, represented in a non-misleading way, and higher than it would be sold for absent
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`the misleading representations and omissions.
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`Jurisdiction and Venue
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`38.
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`Jurisdiction is proper pursuant to Class Action Fairness Act of 2005 (“CAFA”). 28
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`U.S.C. § 1332(d)(2).
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`39. The aggregate amount in controversy exceeds $5 million, including any statutory
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`damages, exclusive of interest and costs.
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`40. Plaintiff Yesenia Valiente is a citizen of Florida.
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`41. Defendant Unilever United States, Inc. is a Delaware corporation with a principal
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`place of business in Sylvan, Bergen County, New Jersey.
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`42. The class of persons Plaintiff seeks to represent includes persons who are citizens of
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`different states from which Defendant is a citizen
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`43. The members of the class Plaintiff seeks to represent are more than 100 because the
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`Product has been sold with the representations described here, in thousands of locations, in the
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`states covered by Plaintiff’s proposed classes.
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`44. Venue in this District is proper because a substantial part of the events or omissions
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`giving rise to these claims occurred in Miami-Dade County, including Plaintiff’s purchase,
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`consumption, transactions and/or use of the Product and awareness and/or experiences of and with
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`the issues described here.
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`Parties
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`45. Plaintiff, Yesenia Valiente, is a citizen of Miami-Dade County, Florida.
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`46. Defendant, Unilever United States, Inc., is a Delaware corporation with a principal
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 7 of 15
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`place of business in Sylvan, New Jersey, Bergen County.
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`47. Defendant is the world’s largest consumer packaged goods company, which owns
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`hundreds of iconic brands, from Ben and Jerry’s Ice Cream to Axe Body Spray to Dove cosmetic
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`and personal care products.
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`48. The Product is available to consumers from third party vendors, which includes
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`grocery stores, dollar stores, warehouse club stores, drug stores, convenience stores, big box stores,
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`and/or online, and from Defendant's website.
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`49. Plaintiff purchased the Product on one or more occasions within the statutes of
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`limitations for each cause of action alleged herein, at stores including Costco, 7795 W Flagler St
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`#01, Miami, FL 33144, between January 2022 and May 2022, and/or among other times.
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`50. Plaintiff believed and expected the Product to contain only natural oil ingredients,
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`that the highlighted ingredients were natural, and that it contained a non-de minimis amount of the
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`highlighted ingredients because that is what the representations and omissions said and implied on
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`the front label and in the absence of any reference or statement elsewhere on the Product.
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`51. Plaintiff relied on the words, terms coloring, descriptions, layout, placement,
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`packaging, tags, and/or images on the Product, on the labeling, statements, omissions, claims,
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`statements, and instructions, made by Defendant or at its directions, in digital, print and/or social
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`media, which accompanied the Product and separately, through in-store, digital, audio, and print
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`marketing.
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`52. Plaintiff bought the Product at or exceeding the above-referenced price.
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`53. Plaintiff would not have purchased the Product if she knew the representations and
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`omissions were false and misleading or would have paid less for it.
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`54. Plaintiff chose between Defendant’s Product and products represented similarly, but
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 8 of 15
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`which did not misrepresent their attributes, requirements, instructions, features, and/or
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`components.
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`55. The Product was worth less than what Plaintiff paid and she would not have paid as
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`much absent Defendant's false and misleading statements and omissions.
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`56. Plaintiff intends to, seeks to, and will purchase the Product again when she can do so
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`with the assurance the Product's representations are consistent with its abilities, attributes, and/or
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`composition.
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`57. Plaintiff is unable to rely on the labeling and representations not only of this Product,
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`but other similar antiperspirant deodorants made with natural oil ingredients, because she is unsure
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`whether those representations are truthful.
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`Class Allegations
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`58. Plaintiff seeks certification under Fed. R. Civ. P. 23 of the following classes:
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`Florida Class: All persons in the State of Florida
`who purchased the Product during the statutes of
`limitations for each cause of action alleged; and
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`Consumer Fraud Multi-State Class: All persons in
`the States of Alabama, Mississippi, Tennessee,
`Arkansas, South Carolina and Utah who purchased
`the Product during the statutes of limitations for each
`cause of action alleged.
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`59. Common questions of issues, law, and fact predominate and include whether
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`Defendant’s representations were and are misleading and if Plaintiff and class members are entitled
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`to damages.
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`60. Plaintiff's claims and basis for relief are typical to other members because all were
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`subjected to the same unfair, misleading, and deceptive representations, omissions, and actions.
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`61. Plaintiff is an adequate representative because her interests do not conflict with other
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`members.
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 9 of 15
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`62. No individual inquiry is necessary since the focus is only on Defendant’s practices
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`and the class is definable and ascertainable.
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`63.
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`Individual actions would risk inconsistent results, be repetitive and are impractical
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`to justify, as the claims are modest relative to the scope of the harm.
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`64. Plaintiff's counsel is competent and experienced in complex class action litigation
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`and intends to protect class members’ interests adequately and fairly.
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`65. Plaintiff seeks class-wide injunctive relief because the practices continue.
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`Florida Deceptive and Unfair Trade Practices Act
`(“FDUTPA”), Fla. Stat. § 501.201 et seq.
`(Consumer Protection Statute)
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`66. Plaintiff incorporates by reference all preceding paragraphs.
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`67. Plaintiff believed the Product contained only natural oil ingredients, the highlighted
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`ingredients were natural, and that it contained a non-de minimis amount of the highlighted
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`ingredients.
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`68. Defendant’s false, misleading and deceptive representations and omissions are
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`material in that they are likely to influence consumer purchasing decisions.
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`69. Defendant misrepresented the Product through statements, omissions, ambiguities,
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`half-truths and/or actions.
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`70. Plaintiff relied on the representations and omissions to believe the Product contained
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`only natural oil ingredients, the highlighted ingredients were natural, and that it contained a non-
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`de minimis amount of the highlighted ingredients.
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`71.
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` Plaintiff would not have purchased the Product or paid as much if the true facts had
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`been known, suffering damages.
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 10 of 15
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` Violation of State Consumer Fraud Acts
`(On Behalf of the Consumer Fraud Multi-State Class)
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`72. The Consumer Fraud Acts of the States in the Consumer Fraud Multi-State Class are
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`similar to the consumer protection statute invoked by Plaintiff and prohibit the use of unfair or
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`deceptive business practices in the conduct of commerce.
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`73. The members of the Consumer Fraud Multi-State Class reserve their rights to assert
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`their consumer protection claims under the Consumer Fraud Acts of the States they represent
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`and/or the consumer protection statute invoked by Plaintiff.
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`74. Defendant intended that members of the Consumer Fraud Multi-State Class would
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`rely upon its deceptive conduct.
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`75. As a result of Defendant’s use of artifice, and unfair or deceptive acts or business
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`practices, the members of the Consumer Fraud Multi-State Class sustained damages.
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`76. Defendant’s conduct showed motive and a reckless disregard of the truth such that
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`an award of punitive damages is appropriate.
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`Breaches of Express Warranty,
`Implied Warranty of Merchantability/Fitness for a Particular Purpose
`and Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.
`
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`77. The Product was manufactured, identified, marketed and sold by Defendant and
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`expressly and impliedly warranted to Plaintiff that it contained only natural oil ingredients, the
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`highlighted ingredients were natural, and that it contained a non-de minimis amount of the
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`highlighted ingredients.
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`78. Defendant directly marketed the Product to Plaintiff through its advertisements and
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`marketing, through various forms of media, on the packaging, in print circulars, direct mail,
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`product descriptions distributed to resellers, and targeted digital advertising.
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`79. Defendant knew the product attributes that potential customers like Plaintiff were
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 11 of 15
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`seeking and developed its marketing and labeling to directly meet those needs and desires.
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`80. Defendant’s representations about the Product were conveyed in writing and
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`promised it would be defect-free, and Plaintiff understood this meant that it contained only natural
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`oil ingredients, the highlighted ingredients were natural, and that it contained a non-de minimis
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`amount of the highlighted ingredients.
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`81. Defendant’s representations affirmed and promised that the Product contained only
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`natural oil ingredients, the highlighted ingredients were natural, and that it contained a non-de
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`minimis amount of the highlighted ingredients.
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`82. Defendant described the Product so Plaintiff believed it contained only natural oil
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`ingredients, the highlighted ingredients were natural, and that it contained a non-de minimis
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`amount of the highlighted ingredients, which became part of the basis of the bargain that it would
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`conform to its affirmations and promises.
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`83. Defendant had a duty to disclose and/or provide non-deceptive descriptions and
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`marketing of the Product.
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`84. This duty is based on Defendant’s outsized role in the market for this type of Product,
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`a trusted company known for its high-quality products.
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`85. Plaintiff recently became aware of Defendant’s breach of the Product’s warranties.
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`86. Plaintiff provided or will provide notice to Defendant, its agents, representatives,
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`retailers, and their employees.
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`87. Plaintiff hereby provides notice to Defendant that it breached the express and implied
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`warranties associated with the Product.
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`88. Defendant received notice and should have been aware of these issues due to
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`complaints by third parties, including regulators, competitors, and consumers, to its main offices,
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 12 of 15
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`and by consumers through online forums.
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`89. The Product did not conform to its affirmations of fact and promises due to
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`Defendant’s actions.
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`90. The Product was not merchantable because it was not fit to pass in the trade as
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`advertised, not fit for the ordinary purpose for which it was intended and did not conform to the
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`promises or affirmations of fact made on the packaging, container or label, because it was marketed
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`as if it contained only natural oil ingredients, the highlighted ingredients were natural, and that it
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`contained a non-de minimis amount of the highlighted ingredients.
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`91. The Product was not merchantable because Defendant had reason to know the
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`particular purpose for which the Product was bought by Plaintiff, because she expected it contained
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`only natural oil ingredients, the highlighted ingredients were natural, and that it contained a non-
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`de minimis amount of the highlighted ingredients, and she relied on Defendant’s skill and
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`judgment to select or furnish such a suitable product.
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`92. Plaintiff would not have purchased the Product or paid as much if the true facts had
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`been known, suffering damages.
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`Negligent Misrepresentation
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`93. Defendant had a duty to truthfully represent the Product, which it breached.
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`94. This duty was non-delegable, based on Defendant’s position, holding itself out as
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`having special knowledge and experience in this area, a trusted company known for its high quality
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`products.
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`95. Defendant’s representations and omissions regarding the Product went beyond the
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`specific representations on the packaging, as they incorporated the extra-labeling promises and
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`commitments to quality, transparency and putting customers first, that it has been known for.
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 13 of 15
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`96. These promises were outside of the standard representations that other companies
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`may make in a standard arms-length, retail context.
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`97. The representations took advantage of consumers’ cognitive shortcuts made at the
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`point-of-sale and their trust in Defendant.
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`98. Plaintiff reasonably and justifiably relied on these negligent misrepresentations and
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`omissions, which served to induce and did induce, their purchase of the Product.
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`99. Plaintiff would not have purchased the Product or paid as much if the true facts had
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`been known, suffering damages.
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`Fraud
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`100. Defendant misrepresented and/or omitted the attributes and qualities of the Product,
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`that it contained only natural oil ingredients, the highlighted ingredients were natural, and that it
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`contained a non-de minimis amount of the highlighted ingredients.
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`101. Moreover, the records Defendant is required to maintain, and/or the information
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`inconspicuously disclosed to consumers, provided it with actual and constructive knowledge of
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`the falsity and deception, through statements and omissions.
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`102. Defendant knew of the issues described here yet did not address them.
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`103. Defendant’s fraudulent intent is evinced by its knowledge that the Product was not
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`consistent with its representations.
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`Unjust Enrichment
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`104. Defendant obtained benefits and monies because the Product was not as represented
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`and expected, to the detriment and impoverishment of Plaintiff and class members, who seek
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`restitution and disgorgement of inequitably obtained profits.
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`Jury Demand and Prayer for Relief
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`Plaintiff demands a jury trial on all issues.
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` WHEREFORE, Plaintiff prays for judgment:
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`1. Declaring this a proper class action, certifying Plaintiff as representative and the
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`undersigned as counsel for the class;
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`2. Entering preliminary and permanent injunctive relief by directing Defendant to correct the
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`challenged practices to comply with the law;
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`3. Injunctive relief to remove, correct and/or refrain from the challenged practices and
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`representations, and restitution and disgorgement for members of the class pursuant to the
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`applicable laws;
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`4. Awarding monetary damages, statutory and/or punitive damages pursuant to any statutory
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`claims and interest pursuant to the common law and other statutory claims;
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`5. Awarding costs and expenses, including reasonable fees for Plaintiff's attorneys and
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`experts; and
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`6. Other and further relief as the Court deems just and proper.
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`Dated: May 16, 2022
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`Respectfully submitted,
`
`/s/Alexander J. Korolinsky
`Alexander J. Korolinsky
`Florida Bar No.: 119327
`AJK Legal
`1001 Brickell Bay Dr Ste 2700
`Miami FL 33401
`Tel: (877) 448-8404
`korolinsky@ajklegal.com
`
`Sheehan & Associates, P.C.
`Spencer Sheehan*
`60 Cuttermill Rd Ste 412
`Great Neck NY 11021
`
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`Case 1:22-cv-21507-JAL Document 1 Entered on FLSD Docket 05/16/2022 Page 15 of 15
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`
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`Tel: (516) 268-7080
`spencer@spencersheehan.com
`*Pro Hac Vice Application Forthcoming
`
`15
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