“Defendant markets the Product as plant-based and great for everyday use. On Defendant’s Product page, these claims are presented with images of a smiling mother using the wipes to clean her baby, as well as an image of a seemingly happy, healthy baby, whose face is being wiped with the Product.”

💡 This shows Kimberly-Clark actively encouraged daily use on vulnerable babies while concealing contamination.

“Independent testing conducted by Plaintiff’s counsel, utilizing a Department of Defense ELAP-certified laboratory, revealed that the Product contains 305 parts of trillion (PPT) of dangerous PFAS chemicals.”

💡 Certified laboratory testing proves the wipes contain toxic forever chemicals at measurable dangerous levels.

“Furthermore, the Centers for Disease Control and Prevention (CDC) outlined a host of health effects associated with PFAS exposure, including liver damage, decreased fertility, and increased risk of asthma.”

💡 Government health authorities confirm PFAS pose serious documented health threats.

“Children are more vulnerable to environmental pollutants like PFAS than adults because of lower body weight, differences in water and food intake, developing organ systems and longer lifespans during which toxic effects might manifest.”

💡 Medical experts confirm babies face greater PFAS risks than adults, making contaminated baby wipes especially dangerous.

“Defendant claims that consumers’ baby’s skin is [its] priority. That’s why [it] carefully select[s] each ingredient that goes into the Product. Notably missing from this list is the mention of PFAS or PFAS-compounds.”

💡 Kimberly-Clark claimed to prioritize baby skin safety while omitting disclosure of toxic chemicals.

“A newborn’s skin is significantly thinner and more permeable than that of an adult and can more readily absorb chemicals.”

💡 Scientific evidence shows baby skin absorbs toxins more easily, making PFAS exposure particularly harmful.

“While it might make you gasp, [a parent will] need about 10,000-12,000 baby wipes yearly. Each application is a repeated, direct exposure to a small and vulnerable body.”

💡 Babies face thousands of PFAS exposures per year through normal wipe use, compounding health risks.

“Defendant made material misrepresentations and omissions during the putative class period, including prior to and at the time of Plaintiff’s and the Class Members’ purchases, despite Defendant’s knowing or reasonably should have known the risk that the Product contained, or risked containing, PFAS.”

💡 The lawsuit alleges Kimberly-Clark had knowledge of contamination but sold the product anyway.

“Prior to her purchase, Plaintiff Erickson reviewed and relied on Defendant’s representations, labeling, and packaging, and saw that the Product was warranted as safe for infants, babies, and toddlers and made with simply clean, gentle ingredients.”

💡 Consumers made purchasing decisions based on false corporate safety promises.

“The back of the Product packaging includes claims in another conspicuous red text box that the Product is Hypoallergenic, Dermatologically Tested, Alcohol Free, and Paraben Free. These claims are followed by a list of the purported contents of the Product, described by Defendant as Gentle ingredients. Nowhere on this list of gentle ingredients, is listed any compound of PFAS or risk that the Product may contain them.”

💡 The company highlighted certain excluded chemicals while hiding PFAS contamination.

“On April 22, 2024, prior to the filing of this complaint, Plaintiff’s counsel sent Defendant a CLRA notice letter via certified mail (with return receipt requested), which complies in all material respects with California Civil Code Section 1782(a). The letter advised Defendant that it was in violation of the CLRA with respect to the presence of PFAS in the Product and demanded that it cease and desist from such violations and make full restitution by refunding the monies received therefrom. Defendant failed to remedy the issues raised by the notice letter.”

💡 Kimberly-Clark received formal legal notice of violations but refused to stop selling contaminated wipes.

“Additionally, in children, PFAS has also been linked to [l]ower antibody response[s] to some vaccines, thereby rendering children more vulnerable to disease they would otherwise be immune from.”

💡 PFAS exposure undermines childhood vaccinations, leaving babies vulnerable to preventable diseases.

“Had Plaintiff Erickson known that the Product contained, or risked containing, dangerous levels of toxic PFAS chemicals, and therefore was not composed of gentle ingredients and safe for young children when used as intended, Plaintiff Erickson would not have purchased the Product or would have purchased it under substantially different terms.”

💡 Parents were deceived into purchases they would not have made with truthful information.

“In fact, the White House recently announced a plan to take aggressive action to tame peoples’ exposure to PFAS chemicals by directing the Environmental Protection Agency to create the first-ever national legally enforceable drinking water standard for PFAS, which will protect 100 million people from PFAS exposure, prevent tens of thousands of serious illnesses, and save lives.”

💡 Federal government recognizes PFAS as serious enough threat to require unprecedented regulatory action.

“PFAS are extremely toxic at doses as low as parts per trillion or quadrillion.”

💡 Scientific evidence shows PFAS cause harm even at the trace levels found in these baby wipes.