Yamasaki v. Natrol, LLC

Background

Venus Yamasaki sued Natrol, LLC over advertising and labeling for Natrol’s Cognium products. According to the allegations quoted in the order, the products’ only active ingredient was silk protein hydrolysate, which Yamasaki alleged could not cross the blood-brain barrier or provide the promised brain-health and memory benefits. Her claims included claims under the Consumer Legal Remedies Act (CLRA), the Unfair Competition Law (UCL), and a breach-of-express-warranty claim. She sought damages under the CLRA and injunctive relief under the CLRA and UCL, and sought restitution under the UCL.

Transfer Request

Natrol asked to transfer the case to the Central District of California under 28 U.S.C. § 1404(a), which permits transfer when another federal district is the more appropriate forum. Natrol relied mainly on a similar case that had been decided in that district. The court noted that the similar case had been dismissed and closed, and that there was no basis to assume this case would be assigned to the same judge. The court also found that Natrol had not shown that the Central District would be significantly more convenient or fair. The transfer request was denied.

Judgment on the Pleadings

Natrol also moved for partial judgment on the pleadings under Federal Rule of Civil Procedure 12(c). A judgment-on-the-pleadings motion asks whether the pleaded facts support a claim based on the complaint and the response to it.

The court held that Yamasaki lacked Article III standing for injunctive relief under the CLRA and UCL. Standing is the constitutional requirement that a plaintiff show a sufficient personal injury and a real stake in the requested relief. The court reasoned that Yamasaki had alleged categorically that Natrol’s products could never improve her memory or brain health. Because of those allegations, the court found that she could not plausibly claim that she would want to buy the products again or might buy them again if they were improved.

The court was not prepared to dismiss those injunctive-relief claims with prejudice because it wanted to give Yamasaki an opportunity to amend. The CLRA and UCL claims for injunctive relief were therefore dismissed with leave to amend. The UCL restitution claim was dismissed without prejudice for lack of equitable jurisdiction. The court relied on rulings that the CLRA provided an adequate remedy at law for the alleged injury. The order did not dismiss the identified CLRA damages claim or breach-of-express-warranty claim.

Disposition and Next Step

The transfer request was denied. The CLRA and UCL injunctive-relief claims were dismissed with leave to amend, and the UCL restitution claim was dismissed without prejudice. An amended complaint consistent with the order was due August 18, 2023; no additional claims or parties could be added without the court’s express permission. The scheduled hearing and initial case-management conference were vacated.