False advertising claims under California’s Unfair Competition Law (“UCL”) require plaintiffs to plead and prove injury in fact and a loss of money or property as a result of the alleged violation. Alleged false representations that a product was “Made in the U.S.A.,” without more, do not meet the latter requirement, said the Court of Appeal in Kwikset v. Superior Court (Benson), __ Cal.App.4th __, 2009 WL 457921 (No. G040675, Feb. 25, 2009). Instead, a diminution in the value received, or a higher cost paid, is required.
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