CLASS ACTION COMPLAINT - 1 -
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Civil Case No.: 0:13-cv-62496
TODD BARRON, ADELE FERRERA, MATTHEW MCDONOUGH, and DAVID KORN, individually, and on behalf of all others similarly situated, Plaintiffs, vs. SNYDER’S-LANCE, INC., a North Carolina corporation, Defendant.
CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiffs, Todd Barron, Adele Ferrera, Matthew McDonough, and David Korn
(collectively, “Plaintiffs”), individually and on behalf of all others similarly situated, by and
through their undersigned attorneys, hereby bring this Complaint against Snyder’s-Lance, Inc.
(“Snyder’s” or “Defendant”), and allege as follows:
Plaintiffs bring this action on behalf of themselves and nationwide classes seeking
declaratory and injunctive relief pursuant to Federal Rule of Civil Procedure (“Rule”) 23(a) and
(b)(2) for violations of the statutory and common law of the State of Florida, and monetary
damages pursuant to Rule 23(a) and (b)(3) for violations of the statutory and common law of the
State of Florida.
Alternatively, Plaintiffs bring this action on behalf of themselves and a multi-state class of
residents of the States of Florida, New York, and California seeking declaratory and injunctive
relief pursuant to Rule 23(a) and (b)(2) for violations of the statutory and common law of the State
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See Fish Genes into Tomatoes: How the World Regulates Genetically Modified Foods
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e.g.
See The Planet Versus Monsanto
available at
have had their genetic makeup
altered to exhibit traits that are not naturally theirs
express novel traits that normally would not appear in
nature
has been altered in a way that does not occur
naturally
available at
Bacillus thuringiensis
available at
selection
insertion
available at
Id.
Id.
i.e.
Canola Oil and Soybean Oil
Extraction:
Alkalineutralization:
Bleaching:
Deodorizing:
Conditioning:
Enriched Flour
Niacin
Thiamine Mononitrate
Folic Acid N
L
Yellow Corn (enriched with thiamine, riboflavin, niacin, iron, folic acid) and
White Corn (enriched with thiamine, riboflavin, niacin, iron, folic acid)
Maltodextrin
Dextrose
Disodium Phosphate
See
Oleoresin Paprika, Paprika Extract, Caramel Color, and Annatto Extract
available at
Frito-Lay turns to nature’s path
available at
Id.
See
et seq.
et seq.
et seq.
et seq.
et seq.
et seq.
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