Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 1 of 16
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`
`Stephanie Soto, individually and on behalf of all
`others similarly situated,
`
`Case No. 1:21-cv-01271
`
`Plaintiff,
`
`
`
`- against -
`
`Class Action Complaint
`
`Nurture, Inc.,
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`
`
`Defendant
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`Jury Trial Demanded
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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. Nurture, Inc. (“defendant”) manufactures, distributes, labels and sells flavored rice
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`puffs to babies in numerous varieties (“Products”).
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`
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`
`Stephanie Soto, individually and on behalf of all
`others similarly situated,
`
`Case No. 1:21-cv-01271
`
`Plaintiff,
`
`
`
`- against -
`
`Class Action Complaint
`
`Nurture, Inc.,
`
`
`
`Defendant
`
`Jury Trial Demanded
`
`Plaintiff alleges upon information and belief, except for allegations pertaining to plaintiff,
`
`which are based on personal knowledge:
`
`1. Nurture, Inc. (“defendant”) manufactures, distributes, labels and sells flavored rice
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`puffs to babies in numerous varieties (“Products”).
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`
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`
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 2 of 16
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`I. The Products are Marketed to Developing Children
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`2. Defendant’s front and back labels tout its health attributes, through the following:
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`Pictures of fruits and vegetables
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`“Organics”
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`“Happy Baby”
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`“Superfood”
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`“Gluten Free”
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`We are a team of real parents, pediatricians & nutritionists on a mission to bring
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`health and happiness to our little ones and the planet.
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`We create nutritious meals and snacks that make eating enlightened, effortless, and
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`delicious. From our happy family to yours!
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`Come meet our dedicated team and learn more about our carefully crafted products
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`at happyfaimlyorganics.com.
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`Our enlightened nutrition philosophy.
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`25 mg choline per serving to support brain & eye health.
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`Antioxidant vitamins c & e 10% per serving.
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`Vitamin b12 20% dv per serving.
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`Made without cane syrup.
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`3. Defendant’s online and print marketing further tout the Products’ suitability for
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`developing children:
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`•
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`•
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`Superfood Puffs: Parents, meet your pantry’s unsung hero Happy Baby Puffs are a
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`melt-in-your-mouth Organic Snack fortified with Choline for eye & brain health;
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`Irresistible in taste & texture, they’re perfect for teaching babies tactility & self-
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 3 of 16
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`feeding!
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`Organic Snacks For Baby: Happy Baby goes beyond baby food with delicious,
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`Superfood Puffs;
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`Babies may be ready for our delicious snacks when they can crawl on their hands
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`and knees, without their tummy touching the ground;
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`At Happy Baby Organics, we provide organic and delicious options for your baby's
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`nutritional journey;
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`We develop premium organic recipes perfectly matched with your child's age and
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`stage This is enlightened nutrition for every family;
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`Mindfully Made: We develop premium organic recipes perfectly matched with
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`your child's age and stage;
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`Explore our snacks & meals for growing babies, toddlers & kids, from baby food
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`pouches to freeze-dried yogurt treats, organic Cereals & Toddler Snacks.
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`4. However, nowhere in the labeling, advertising, statements, warranties, and/or
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`packaging does defendant disclose that the Products contains significant levels of arsenic, mercury,
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`lead, cadmium, and perchlorate1 – all known to pose health risks to humans and especially infants.
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`5.
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`Parents trust manufacturers like defendant to sell baby food that is safe, nutritious,
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`and free from harmful toxins, contaminants, and chemicals.
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`6.
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`They certainly expect the food they feed their infants and toddlers to be free from
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`heavy metals, substances known to have significant and dangerous health consequences.
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`7. However, consumers lack the scientific knowledge necessary to determine whether
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`1 Healthy Babies Bright Future, What’s In My Baby’s Food?, What's In My Baby's Food?, (January 10, 2021).
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`3
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 4 of 16
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`the defendant’s products do in fact contain heavy metals or to know or ascertain the true nature of
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`the ingredients and quality of the products.
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`8.
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`Reasonable consumers therefore must and do rely on defendant to honestly report
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`what its products contain.
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`9. A recent report by the U.S. House of Representatives’ Subcommittee on Economic
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`and Consumer Policy, Committee on Oversight and Reform reveals that parents’ trust has been
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`violated.
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`10. The Subcommittee’s investigation was spurred by “reports alleging high levels of
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`toxic heavy metals in baby foods” and the knowledge that “[e]ven low levels of exposure can cause
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`serious and often irreversible damage to brain development.”
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`11. The report revealed that “[i]nternal company standards permit dangerously high
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`levels of toxic heavy metals, and… that the manufacturers have often sold foods that exceeded
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`these levels.”
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`12. The Food and Drug Administration (“FDA”) and the World Health Organization
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`(“WHO”) declared arsenic, lead, cadmium, and mercury “dangerous to human health, particularly
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`to babies and children, who are most vulnerable to their neurotoxic effects.”2
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`13. These four heavy metals “can harm a baby’s developing brain and nervous system”
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`and cause negative impacts such as the “permanent loss of intellectual capacity and behavioral
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`problems like attention-deficit hyperactivity disorder (ADHD).”3
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`14. Even in trace amounts found in food, these heavy metals can alter the developing
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`2 See Baby Foods Are Tainted with Dangerous Levels of Arsenic, Lead, Cadmium, and Mercury, Staff Report (“House
`Report”), Subcommittee on Economic and Consumer Policy of the Committee on Oversight and Reform, at 2,
`February 4, 2021, available at https://oversight.house.gov/sites/democrats.oversight.house.gov/files/2021-02-
`04%20ECP%20Baby%20Food%20Staff%20Report.pdf.
`3 Healthy Babies Bright Futures Report, at 6.
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`4
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 5 of 16
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`brain and erode a child’s IQ and increase risk of future criminal and antisocial behavior in
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`children.4
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`15. Research continues to confirm that exposures to food containing arsenic, lead,
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`mercury, and cadmium causes “trouble risks for babies, including cancer and lifelong deficits in
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`intelligence.”5
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`A. Arsenic
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`16. When children are exposed to arsenic early in life, it causes “cognitive deficits among
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`school-age children exposed early in life, and neurological problems in adults who were exposed
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`to arsenic-poisoned milk as infants.”6
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`17. Arsenic exposure also creates a risk of “respiratory, gastrointestinal, hematological,
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`hepatic, renal, skin, neurological and immunological effects, as well as damaging effects on the
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`central nervous system.”7
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`18. The FDA has set the maximum allowable arsenic levels in bottled water at 10 ppb of
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`inorganic arsenic and is also considering limiting the action level or arsenic in rice cereal for infants
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`to 100 ppb.8
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`19. The FDA has set 100 ppb inorganic arsenic as the limit in infant rice cereal, though
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`Defendant’s internal standard is 15% higher than the FDA limit, at 115 ppb.
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`20. Defendant’s products contain as much as 180 parts per billion (ppb) inorganic arsenic
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`4 Id.
`5 Id.
`6 Id.
`7 House Report, at 10 (quoting Miguel Rodríguez-Barranco et al., Association of Arsenic, Cadmium and Manganese
`Exposure with Neurodevelopment and Behavioural Disorders in Children: A Systematic Review and Meta-Analysis
`(June 1, 2013) (online at https://pubmed.ncbi.nlm.nih.gov/23570911/)).
`8 FDA, Draft Guidance for Industry: Inorganic Arsenic in Rice Cereals for Infants: Action Level (Apr.2016),
`https://www.fda.gov/downloads/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/UCM49315
`2.pdf.
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`5
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 6 of 16
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`and over 25% of their products contained over 100 ppb inorganic arsenic.
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`B. Lead
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`21. Lead exposure can seriously harm children’s brain and nervous systems and is
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`associated with a range of negative health outcomes including “behavioral problems, decreased
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`cognitive performance, delayed development, and reduced postnatal growth.”9
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`22. Young children are particularly vulnerable to lead because the physical and
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`behavioral effects of lead occur at lower exposure levels in children than in adults.
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`23.
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`In children, low levels of lead exposure have been linked to damage to the central
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`and peripheral nervous system, learning disabilities, shorter stature, impaired hearing, and
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`impaired formation and function of blood cells.10
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`24. EPA has set the maximum contaminant level goal for lead in drinking water at zero
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`because lead is toxic metal that can be harmful to human health even at low exposure levels.
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`25. Lead can bioaccumulate in the body over time, leading to the development of chronic
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`poisoning, cancer, developmental, and reproductive disorders, as well as serious injuries to the
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`nervous system, and other organs and body systems.11
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`26. The Agency for Toxic Substances and Disease Registry states that there may be no
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`threshold for lead with regards to developmental impact on children.
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`27. Yet, Defendant’s products have tested as high as 641 ppb lead and 20% of their
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`products contained over 10 ppb lead
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`C. Mercury
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`9 House Report, at 11.
`10 See https://www.cdc.gov/nceh/lead/prevention/pregnant.htm.
`11 See https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinkingwater.
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 7 of 16
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`28. Mercury increases the risk for cardiovascular disease and can cause vision,
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`intelligence, and memory problems for children exposed in utero.
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`29. Mercury has been linked to higher risk of lower IQ scores and intellectual disability.
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`30. The FDA has set a maximum mercury level in drinking water to 2 ppb.
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`31. Defendant has sold finished baby food products containing as much as 10 ppb
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`mercury.
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`D. Cadmium
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`32. Cadmium has been observed to cause anemia, liver disease, and nerve or brain
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`damage in animals eating or drinking cadmium.
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`33. Cadmium is linked to neurotoxicity, cancer, and kidney, bone, and heart damage.
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`34. Health and environmental regulatory bodies have set maximum cadmium levels in
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`drinking water to 3 and 5 ppb.
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`35. Sixty-five percent of Defendant’s products contained more than 5 ppb cadmium.
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`II. Defendant’s Standards Permit Dangerously High Levels of Toxic Heavy Metals
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`36. Defendant’s internal company standards permit dangerously high levels of toxic
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`heavy metals.
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`37. Though Defendant conducts some testing for these substances, the products sold to
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`consumers regardless of the level of heavy metals they contain.
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`38.
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` In fact, their testing is not even intended for the safety of their consumers –
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`developing children.
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`39. Defendant knows that its customers trust the quality of its products and that they
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`expect defendant’s products to be free of heavy metals.
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`40.
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`It also knows that all consumers seek out and wish to purchase baby foods that will
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 8 of 16
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`not cause harm or risk of harm, and that assurances of quality induces purchasers to pay more than
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`they otherwise would.
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`41. No reasonable consumer seeing defendant’s marketing would expect
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`the
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`contaminated baby foods to contain heavy metals or other undesirable toxins or contaminants.
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`42. Reasonable consumers, like plaintiff, would consider heavy metals at non-trace
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`levels a material fact when considering what baby food to purchase.
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`43. Not only do the Products not inform consumers they contain these components, their
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`labels specifically state what harmful elements they do exclude – GMOs, non-organic ingredients,
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`toxic persistent pesticides and packaging made without BPA, BPS, or phthalates.
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`44. Since Defendant knows consumers dislike plastic residues, it is logical and expected
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`they will dislike even more heavy metals which have harmful effects on children.
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`45. Defendant misrepresented the Products through affirmative statements, half-truths,
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`and omissions.
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`46. Defendant sold more of the Product and at a higher price than it would have in
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`absence of this misconduct, resulting in additional profits at the expense of consumers.
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`47. Had plaintiff and the proposed class members known the truth, they would not have
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`bought the Product or would have paid less for it.
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`48. As a result of the false and misleading representations, the Product is sold at a
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`premium price, approximately no less than no less than $3.39 for containers of 2.1 OZ, excluding
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`tax, compared to other similar products represented in a non-misleading way, and higher than it
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`would be sold for absent the misleading representations and omissions.
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`Delayed Discovery
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`49. Plaintiff and consumers would not have been able to discover Defendant's deceptive
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 9 of 16
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`practices and lacked the means to discover them given that, like nearly all consumers, they rely on
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`and are entitled to rely on the manufacturer's obligation to disclose material facts.
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`50. Furthermore, Defendant's labeling practices and nondisclosures impeded Plaintiff’s
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`abilities to discover the deceptive and unlawful labeling throughout the Class Period.
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`Jurisdiction and Venue
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`51.
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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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`52. Under CAFA, district courts have original federal jurisdiction over class actions
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`involving (1) an aggregate amount in controversy of at least $5,000,000; and (2) minimal diversity.
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`53. The home state exceptions to CAFA are not applicable.
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`54. Plaintiff Stephanie Soto is a citizen of New York who seeks to represent a class of
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`New York and Wyoming citizens.
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`55. Defendant Nurture, Inc. is a Delaware corporation with a principal place of business
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`in White Plains, Westchester County, New York.
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`56. Diversity exists because plaintiff Stephanie Soto seeks to represent a class of persons
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`which includes citizens of a state diverse from Defendant.
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`57. Upon information and belief, sales of the Products and any available statutory and
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`other monetary damages, exceed $5 million during the applicable statutes of limitations, exclusive
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`of interest and costs.
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`58. Venue is proper because a substantial part of the events or omissions giving rise to
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`the claim occurred here – plaintiff’s purchase of the Product.
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`59. Venue is further supported because many class members reside in this District.
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 10 of 16
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`Parties
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`60. Plaintiff Stephanie Soto is a citizen of Bronx, Bronx County, New York.
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`61. Defendant Nurture, Inc. is a Delaware corporation with a principal place of business
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`in White Plains, New York, Westchester County.
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`62. Defendant is an established maker baby food and touts its unique expertise, founded
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`by those who purported to bring real-world experience to development of children.
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`63. The Product is sold to consumers from retail and online stores of third-parties across
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`the country.
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`64. Plaintiff bought the Product on one or more occasions within the statute of limitations
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`for each cause of action alleged, from one or more locations, such asAmazon.com, Walmart and
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`Foodtown of Bainbridge, 283 E 204th St, The Bronx, NY 10467, within the past week and
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`throughout the past two years for the consumption of children.
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`65. Plaintiff bought the Product at or exceeding the above-referenced price because she
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`wanted to buy a product with the qualities and attributes represented herein and relied upon what
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`the label indicated or omitted.
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`66. Plaintiff would not have purchased the Products in the absence of Defendant’s
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`misrepresentations and omissions.
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`67. The Product were 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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`68. Plaintiff intends to, seeks to, and will purchase the Products again when she can do
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`so with the assurance that Products' labeling is consistent with its composition.
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 11 of 16
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`Class Allegations
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`69. The class will consist of all purchasers of the Products who reside in New York and
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`Wyoming during the applicable statutes of limitations.
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`70. Plaintiff seeks class-wide injunctive relief based on Rule 23(b) in addition to a
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`monetary relief class.
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`71. Common questions of law or fact predominate and include whether defendant’s
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`representations were and are misleading and if plaintiff and class members are entitled to damages.
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`72. Plaintiff's claims and basis for relief are typical to other members because all were
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`subjected to the same unfair and deceptive representations and actions.
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`73. Plaintiff is an adequate representative because her interests do not conflict with other
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`members.
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`74. 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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`75.
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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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`76. 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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`77. Plaintiff seeks class-wide injunctive relief because the practices continue.
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`New York General Business Law (“GBL”) §§ 349 & 350
`(Consumer Protection Statutes)
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`78. Plaintiff incorporates by reference all preceding paragraphs.
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`79. Plaintiff and class members desired to purchase products without high levels of toxic
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`heavy metals.
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 12 of 16
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`80. Defendant’s acts and omissions are not unique to the parties and have a broader
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`impact on the public.
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`81. Defendant misrepresented
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`the Products
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`through
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`its statements, omissions,
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`ambiguities, half-truths and/or actions.
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`82. Defendant intended that Plaintiff and the Class rely upon Defendant’s deceptive
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`conduct, and a reasonable person would in fact be misled by this deceptive conduct.
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`83. Defendant knew or should have known that its representations about the Product’s
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`flavoring source were material and likely to mislead consumers.
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`84. Plaintiff and class members would not have purchased the Products or paid as much
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`if the true facts had been known, suffering damages.
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`Breaches of Express Warranty, Implied Warranty of Merchantability
`and Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.
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`85. Plaintiff incorporates by reference all preceding paragraphs.
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`86. The Product was manufactured, labeled and sold by defendant and warranted to
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`plaintiff and class members that it possessed substantive, functional, nutritional, qualitative,
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`compositional, organoleptic, sensory, physical and health-related attributes which it did not.
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`87. The absence of toxic heavy metals was impliedly warranted because of the numerous
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`health-related statements, among other things.
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`88. 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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`89. This duty is based on Defendant’s outsized role in the market for this type of Product.
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`90. Plaintiff provided or will provide notice to defendant, its agents, representatives,
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`retailers and their employees.
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`91. Defendant received notice and should have been aware of these misrepresentations
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 13 of 16
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`due to numerous complaints by consumers to its main office over the past several years regarding
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`the Product.
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`92. The Product did not conform to its affirmations of fact and promises due to
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`defendant’s actions and were not merchantable.
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`93. Plaintiff and class members would not have purchased the Product or paid as much
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`if the true facts had been known, suffering damages.
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`Negligent Misrepresentation
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`94. Plaintiff incorporates by reference all preceding paragraphs.
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`95. Defendant had a duty to truthfully represent the Products, which it breached.
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`96. This duty is based on defendant’s position, holding itself out as having special
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`knowledge and experience in the sale of the product type.
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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, a well-known and respected brand or entity in this sector.
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`98. Plaintiff and class members reasonably and justifiably relied on these negligent
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`misrepresentations and omissions, which served to induce and did induce, the purchase of the
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`Products.
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`99. Plaintiff and class members would not have purchased the Products or paid as much
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`if the true facts had been known, suffering damages.
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`Fraud
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`100. Plaintiff incorporates by reference all preceding paragraphs.
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`101. Defendant misrepresented and/or omitted the attributes and qualities of the Products.
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`102. Defendant’s fraudulent intent is evinced by its failure to accurately disclose the issues
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`described herein, when it knew not doing so would mislead consumers.
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`103. Plaintiff and class members would not have purchased the Products or paid as much
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`if the true facts had been known, suffering damages.
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`104. Plaintiff incorporates by reference all preceding paragraphs.
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`Unjust Enrichment
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`105. Defendant obtained benefits and monies because the Products were not as
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`represented and expected, to the detriment and impoverishment of plaintiff and class members,
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`who seek 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 damages pursuant to any statutory claims and
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`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: February 11, 2021
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`Respectfully submitted,
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 15 of 16
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`Sheehan & Associates, P.C.
`/s/Spencer Sheehan
`Spencer Sheehan
`60 Cutter Mill Rd Ste 409
`Great Neck NY 11021-3104
`Tel: (516) 268-7080
`Fax: (516) 234-7800
`spencer@spencersheehan.com
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`15
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`Case 1:21-cv-01271 Document 1 Filed 02/11/21 Page 16 of 16
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`1:21-cv-01271
`United States District Court
`Southern District of New York
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`Stephanie Soto, individually and on behalf of all others similarly situated,
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` - against -
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`Plaintiff,
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`Nurture, Inc.,
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` Defendant
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`Class Action Complaint
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`Sheehan & Associates, P.C.
`60 Cutter Mill Rd Ste 409
`Great Neck NY 11021-3104
`Tel: (516) 268-7080
`Fax: (516) 234-7800
`
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`
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`Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of
`New York State, certifies that, upon information, and belief, formed after an inquiry reasonable
`under the circumstances, the contentions contained in the annexed documents are not frivolous.
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`Dated: February 11, 2021
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` /s/ Spencer Sheehan
` Spencer Sheehan
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