Merrell

I. BACKGROUND

1 This summary of background facts is based on the allegations of the FAC. Defendant 2 Florida Crystals manufactures, markets, and sells the product lines at issue in this case: Florida 3 Crystals Regenerative Organic Certified Sugars and (2) Specialty Raw Cane Sugars. FAC ¶¶ 17, 4 31; see also id. ¶ 17 n. 1 (identifying specific products at issue). 5 Plaintiff Macy Merrell is domiciled in Santa Cruz, California, which is within this judicial 6 District. FAC ¶ 29a. She alleges that on several occasions between September 2021 and August 7 2024, she purchased Florida Crystals Regenerative Organic Raw Cane Sugar (two-pound bag 8 size), which the FAC defines as the “Purchased Products,” from a Safeway store in Santa Cruz. 9 FAC ¶ 29b. The FAC alleges that, “[i]n making her purchases, Plaintiff Merrell read the ‘Farming 10 to Help Save the Planet’ and ‘our farms help fight climate change & build healthy soil’ 11 representations on the Products’ label, leading Plaintiff Merrell to believe that the farming and 12 manufacture of the Products was helping rather than harming the planet.” FAC ¶ 29c. 13 Plaintiff filed this lawsuit on March 5, 2025. Dkt. 1. Florida…