62. Just as an apple cannot be called a pear, an omega-3 acid ethyl ester cannot be called fish oil. This Product is a fatty acid ethyl ester. Labeling and selling it as fish oil is false, misleading, deceptive and unlawful.
70. As demonstrated in great detail herein, Fish Oil and Omega-3 Acid Ethyl Esters are not the same. They are different on a molecular level and have different common and usual names.
24. Defendant Nature’s Bounty Inc., is a New York Corporation with its principal place of business in Ronkonkoma, New York. Nature’s Bounty is the flagship brand of The Bountiful Company, a family of wellness brands “committed to providing people with high quality products to complement their lifestyles and physical health.”3 NBI sells a variety of vitamins and supplements including the Product at issue in this litigation.
25. Defendant The Bountiful Company (“TBC”) is a Delaware Corporation with its principal place of business in Ronkonkoma, New York. TBC is a manufacturer, marketer and seller of vitamins, minerals, herbal and other specialty supplements. It owns several vitamin/supplement brands including Defendant Nature’s Bounty.
26. In August 2021, Nestle Health Science completed its acquisition of The Bountiful Company and its subsidiaries including NBI, for $5.75 billion.
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