CLASS ACTION COMPLAINT

CLASS ACTION COMPLAINT WlTH JURY DEMAND

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PlaintiffEnzo Forcellati ("Plaintiff'), by his attorneys, makes the following

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allegations pursuant to the investigation of his counsel and based upon infonnation

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and belief, except as to allegations specifically pertaining to himself and his counsel,

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which are based on personal knowledge.

NATURE OF ACTION

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1.

This is a class action against Hyland's, Inc., Standard Homeopathic

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Laboratories, Inc., Standard Homeopathic Company and Does I-I 00 (collectively

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"Hyland's" or "Defendants") arising out of the sale of homeopathic cold and flu

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remedies sold over the counter ("OTC"), including Hyland's Cold 'n Cough 4 Kids

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("Cold 'n Cough"), Cough Syrup with 100% Natural Honey 4 Kids ("Cough

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Syrup"), Snifiles 'n Sneezes 4 Kids ("Sniffles 'n Sneezes"), Cold Relief Strips 4

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Kids with Zinc ("Cold Strips"), Complete Flu Care 4 Kids ("Flu Care"), and

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Nighttime Cold 'n Cough 4 Kids ("Nighttime Cold") (collectively "Cold and Flu

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Remedies").

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2.

Hyland's represents that its homeopathic Cold and Flu Remedies offer

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children "Fast acting," "Safe & Effective," "Multi-symptom" relief from cold and flu

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symptoms, including runny noses, sore throats, coughs, headaches, body aches, flu

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and congestion. In fact, Hyland's Cold and Flu Remedies are nothing more than

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sweetened, flavored water with only highly diluted concentrations of the products'

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so-called "active ingredients."

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3.

As a direct and proximate result of Hyland's false and misleading

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advertising claims and marketing practices, Plaintiff and the members of the Class,

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as defined herein, purchased Hyland's Cold and Flu Remedies to treat cold and flu

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symptoms for which the drugs were not fast acting or efficacious as they were

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marketed and advertised.

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CLASS ACTION COMPLAINT

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