Second Circuit Upholds Summary Judgment For Defendants Against Allegations That "All Natural" Label Was Misleading

Yesterday, the Second Circuit upheld the district court's award of summary judgment in favor of the defendant concerning certain class actions claims that "the phrase 'All Natural' that appeared on the labels of [Defendant's] products is deceptive and misleading." Specifically, the court rejected the plaintiffs' allegations of fraud, as well as consumer protection and false advertising claims, since "plaintiffs had failed to establish how a reasonable consumer would understand the term 'all natural' . . . [and so] plaintiffs could not explain how or why they were materially deceived." Even though the claims here--that the label of "all natural" on Defendant's products was misleading--had survived a motion to dismiss, plaintiffs had failed to introduce sufficient evidence in support of their theories to avoid summary judgment.