In Davis v. Hain Celestial Group, a plaintiff brought a putative class action alleging that the labeling of some of Hain's BluePrint juices misled consumers about whether the juices are "cold pressed." According to the plaintiff, consumers buy juices that are cold pressed because traditional methods of extracting juice create heat that negatively affects the enzymatic and nutritional content of the juice.
The product lines at issue in the case are BluePrint Cold Pressed Juices as well as BluePrint Organic juices, which are "crafted with cold pressed juice."
Among the various claims asserted, the plaintiff alleged that Hain's "cold pressed" claims were misleading because after the juices were cold pressed, they were subjected to an additional round of pressure (that does not involve heat), in order to extend the product's shelf life, comply with federal regulations, and kill potential bacteria. A federal district court in New York dismissed this claim, saying that the label makes clear that the juice was subjected to additional processing for food safety purposes ("BluePrint uses pressure instead of heat to keep our beverages raw and safe"). The court also said that, regardless, the description of the juice as "cold pressed" was still accurate, even though there were additional (non heat-related) steps in the juice's production process.
The plaintiff also alleged that the product labels were misleading because the products included thermally-processed lemon juice. (Hain denied this.) Accepting the plaintiff's allegations as true for purposes of the motion to dismiss, the court refused to dismiss this claim.
While it's unclear whether the plaintiff's remaining claims have any merit here, this case serves as an important reminder to make sure that broad claims about a product are true when each individual ingredient is considered.
in determining whether a reasonable consumer would have been misled by a particular advertisement, context is crucial