Yamasaki v. Natrol, LLC
3:23-cv-00182
N.D. Cal.Jul 17, 2023Background
- Plaintiff Venus Yamasaki sued Natrol, LLC over advertising for "Cognium" brain-health products, alleging false claims about memory and brain benefits.
- Complaint alleges silk protein hydrolysate is the sole active ingredient, is digested in the gut, cannot cross the blood–brain barrier, and thus the products are inert/placebo.
- Natrol moved to transfer the case to the Central District of California under 28 U.S.C. § 1404(a), citing a similar prior case (Scarpo) in that district.
- Plaintiff informed the court that Scarpo was dismissed and closed; court found no reason to assume assignment to the same judge and denied transfer.
- Natrol also moved for partial judgment on the pleadings under Rule 12(c), arguing Yamasaki lacks Article III standing for injunctive relief because she pleads the product is impossible to work.
- Court dismissed plaintiff’s CLRA and UCL injunctive-relief claims for lack of standing (with leave to amend), and dismissed UCL restitution without prejudice for lack of equitable jurisdiction; amended complaint due August 18, 2023.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Transfer under § 1404(a) | Northern District is proper; Scarpo is closed | Transfer to Central District conserves resources / prevents forum shopping (Scarpo was similar) | Denied — Natrol failed to show Central District is more appropriate; Scarpo closed and no guarantee same judge would be assigned; plaintiff’s forum choice considered |
| Article III standing for injunctive relief (CLRA and UCL) | Seeks injunctive relief to prevent continued false advertising | No standing because plaintiff pleads the product is scientifically incapable of working, so she will not reasonably repurchase | Held: No Article III standing for injunctive relief on these facts; claims dismissed with leave to amend |
| UCL equitable restitution | Seeks restitution under UCL | Court lacks equitable jurisdiction because CLRA provides adequate legal remedy | Held: UCL restitution dismissed without prejudice for lack of equitable jurisdiction |
Key Cases Cited
- Atlantic Marine Const. Co., Inc. v. U.S. District Court for Western District of Texas, 571 U.S. 49 (2013) (governs § 1404(a) transfer analysis; focus on interests of justice)
- Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (plaintiff’s choice of forum and defendant’s burden to show more appropriate forum)
- Lou v. Belzberg, 834 F.2d 730 (9th Cir. 1987) (plaintiff’s forum choice is entitled to deference but not dispositive)
- Davidson v. Kimberly-Clark Corp., 889 F.3d 956 (9th Cir. 2018) (standing for injunctive relief requires plausible likelihood of future injury/purchase)
- Guzman v. Polaris Industries Inc., 49 F.4th 1308 (9th Cir. 2022) (court lacks equitable jurisdiction over restitution when adequate legal remedy exists under CLRA)
- Sonner v. Premier Nutrition Corporation, 971 F.3d 834 (9th Cir. 2020) (equitable relief requires lack of adequate remedy at law)