A court in the Northern District of Illinois recently denied a motion to dismiss a lawsuit alleging that the alleged inclusion of artificial citric acid in a product rendered the “No Artificial Flavors, Preservatives, or Dyes” representation on the front label false and/or misleading.  Hayes v. Kraft Heinz Co., 2024 WL 4766319 (N.D. Ill. Nov. 13, 2024). 

The court first held that plaintiffs sufficiently alleged that the citric acid was artificial.  Plaintiffs’ complaint cited articles explaining, for example, “the history of citric acid and how the artificial variety derived from Aspergillus niger has overtaken the natural variety.”  The court found that such allegations provided “a sufficient connection between the industry practice of using artificial citric acid” and the defendant’s alleged practices.  The court also distinguished Valencia v. Snapple Beverage Corp., 2024 WL 1158476 (S.D.N.Y. Mar. 18, 2024), which we previously covered here.  The court in Valencia dismissed plaintiff’s claims in part because that plaintiff did not allege how “artificial” citric acid derived from Aspergillus niger is chemically different from “natural” citric acid derived from fruits.  In this case, however, the court concluded plaintiffs had so alleged. 

The court then held that plaintiffs sufficiently alleged that the citric acid in the product functioned as a preservative.  The court credited plaintiffs’ citation of scholarly articles describing citric acid’s role in preserving food, as well as FDA guidance that describes citric acid as a preservative.  This decision marks a deviation from a recent run of cases in other courts that have dismissed citric and malic acid complaints, including on some of the same grounds that were asserted here.  In addition to Valencia, we have covered those cases here and here.

Photo of Cort Lannin Cort Lannin

Cortlin Lannin is a litigator who defends clients in high-stakes antitrust and consumer matters. Described by Chambers USA as “smart, detail-oriented and thorough,” Cort has a depth of experience helping his clients successfully navigate the entire lifespan of these matters, from leading internal…

Cortlin Lannin is a litigator who defends clients in high-stakes antitrust and consumer matters. Described by Chambers USA as “smart, detail-oriented and thorough,” Cort has a depth of experience helping his clients successfully navigate the entire lifespan of these matters, from leading internal investigations to defending government investigations and the class action litigation that routinely follows.

Cort is co-chair of the firm’s global Cartel Defense and Government Investigations practice group and represents companies and individuals facing criminal and civil antitrust investigations, including before the DOJ Antitrust Division and FTC. Cort is also an experienced class action litigator and has defended his clients in cases implicating the high-tech industry, alleged “no-poach” and wage-fixing agreements, price-fixing, and similar conduct. Cort has been recognized as a Top Antitrust Lawyer by the Daily Journal.

Cort has also defended some of the world’s largest consumer-facing companies in class action litigation across courts nationwide. This includes cases alleging false advertising and unfair trade practices under California’s UCL, FAL, and CLRA, and other states’ laws. He is experienced at heading off cases before any complaint is filed and, if necessary, efficiently defeating complaints.

Cort is a co-chair of Covington’s CovPride Resource Group and is deeply involved in the firm’s efforts to recruit, mentor, and promote diverse attorneys. He also maintains an active pro bono practice and is currently leading a team working to preserve transgender adolescents’ access to gender-affirming care.

Photo of Kaixin Fan Kaixin Fan

Kaixin Fan is a member of the Food, Drug, and Device Practice Group. She advises pharmaceutical, biotechnology, and medical device companies as well as trade associations in regulatory matters. She has experience in matters relating to FDA informed consent requirements, advertising and promotion…

Kaixin Fan is a member of the Food, Drug, and Device Practice Group. She advises pharmaceutical, biotechnology, and medical device companies as well as trade associations in regulatory matters. She has experience in matters relating to FDA informed consent requirements, advertising and promotion issues, and other aspects of U.S. federal and state regulation of pharmaceuticals, biologics, and medical devices. Kaixin also assists clients in navigating complex regulatory matters in China, and works closely with local counsel in other Asia-Pacific jurisdictions. She has supported life science transactions by evaluating regulatory compliance of companies and advising on commercial agreements.

Kaixin maintains an active pro bono practice, with experience in the areas of housing, reproductive rights, and gender-based violence.