“Defendant’s yogurt product affirmatively claims to contain ‘Only Natural Ingredients’ while disclaiming the presence of any artificial flavoring and sweeteners and preservative.”

💡 This shows Chobani made prominent, unqualified claims about natural purity that allegedly contradicted the actual product composition.

“Recent third-party testing revealed that the Products contain multiple plastic chemicals, including di-2-ethylhexyl phthalate (‘DEHP’), diethyl phthalate (‘DEP’), dibutyl phthalate (‘DBP’), and phthalate substitute called di-2-ethylhexyl terephthalate (‘DEHT’).”

💡 Independent laboratory analysis found four distinct synthetic chemicals in products marketed as containing only natural ingredients.

“These chemicals have also been reported as probable human carcinogens by the EPA.”

💡 Federal authorities recognize at least one detected chemical as likely to cause cancer in humans, contradicting safety implied by natural labeling.

“These phthalates are endocrine-disrupting chemicals ‘mainly used as plasticizers added to polyvinyl chloride (PVC) plastics for softening effects’ which ‘are detrimental to human health.'”

💡 The chemicals found are industrial plasticizers with documented harmful effects on human hormonal systems, not natural food ingredients.

“DEHP is best known as an endocrine disruptor (ED). An endocrine disrupter is an exogenous substance or mixture that alters the function(s) of the endocrine system and consequently causes adverse health effects…. DEHP is highly toxic.”

💡 Scientific literature establishes the severe toxicity of a primary chemical detected in Chobani’s allegedly natural yogurt.

“California law prohibits the manufacture, sale, or distribution of children’s toys and child care articles containing DBP at levels greater than 0.1%.”

💡 A chemical so dangerous it is banned from children’s toys at low concentrations was allegedly present in yogurt marketed to health-conscious consumers.

“Once [DEP] enters your body, it breaks down into other chemicals, some of which are harmful. This harm can androgen-independent male reproductive toxicity (i.e., sperm effects) as well as developmental toxicity and hepatic effects, with some evidence of female reproductive toxicity.”

💡 DEP causes documented reproductive harm in both men and women, plus developmental and liver toxicity, yet was allegedly in natural yogurt.

“Most Chobani yogurt cups—including Plaintiff’s—are made from #5 plastic, known chemically as polypropylene. And ‘[p]thalates are commonly used as a catalyst in the polymerization of propylene to polypropylene.'”

💡 The complaint identifies a clear pathway for chemical contamination from packaging materials that Chobani selected and controlled.

“Defendant, as the manufacturer, is likely aware of the type of plastic used to create the container and is likely in possession of, or capable of obtaining, purity reports and testing from its plastic manufacturers. Defendant either did so, or negligently or willingly failed to do so.”

💡 Chobani had the ability and responsibility to know about contamination risks but allegedly failed to act on that knowledge.

“Ms. Wysocki reasonably understood Defendant’s representations and warranties to mean the Product is free of non-natural toxic chemicals, like phthalates and therefore expected that the Product can be purchased and consumed as marketed and sold.”

💡 Ordinary consumers interpreted natural ingredients claims as excluding synthetic toxic chemicals, forming the basis of their purchasing decisions.

“When poll respondents don’t see ‘natural’ on food packaging, 52% of them assume the product must have chemicals in it. Another 43% deduce that the product is highly processed. Some 42% assumed that the food is unhealthy or full of preservatives.”

💡 Research demonstrates that natural labeling powerfully influences consumer perceptions and willingness to purchase, creating strong profit incentives.

“Consumers [are] vastly more likely to purchase a product with the natural label[.]. In fact, ‘1 in 3 global consumers consider natural ingredients to be one of the most important aspects of healthy food and beverages, second only to freshness.'”

💡 Natural labeling directly translates to increased sales and market advantage, providing financial motivation for potentially misleading claims.

“Defendant’s untrue representations were part of the basis of the bargain in that she would not have purchased the Product, or would not have purchased it on the same terms, if the true facts had been known.”

💡 The natural ingredients claim was central to the purchase contract, meaning consumers would not have paid the same price if properly informed.

“On January 21, 2025, prior to filing this complaint, Defendant’s Counsel received Plaintiff’s demand letter via certified mail. The letter advised Defendant that it was in violation of the CLRA with respect to the presence of phthalates in the Product, and demanded that they 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.”

💡 Chobani was formally notified of legal violations and consumer harm but chose not to take corrective action before lawsuit filing.

“Physicians, researchers, and public health experts have called for the elimination of phthalates from consumer products, including food packaging and materials that come in contact with food, due to their adverse effects on neurological development.”

💡 Medical and scientific communities have concluded these chemicals should not be in food contact materials due to developmental harm risks.