CLASS ACTION COMPLAINT - 1 -

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Civil Case No.: 0:13-cv-62496

TODD BARRON, ADELE FERRERA, MATTHEW MCDONOUGH, and DAVID KORN, individually, and on behalf of all others similarly situated, Plaintiffs, vs. SNYDER’S-LANCE, INC., a North Carolina corporation, Defendant.

CLASS ACTION COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiffs, Todd Barron, Adele Ferrera, Matthew McDonough, and David Korn

(collectively, “Plaintiffs”), individually and on behalf of all others similarly situated, by and

through their undersigned attorneys, hereby bring this Complaint against Snyder’s-Lance, Inc.

(“Snyder’s” or “Defendant”), and allege as follows:

Plaintiffs bring this action on behalf of themselves and nationwide classes seeking

declaratory and injunctive relief pursuant to Federal Rule of Civil Procedure (“Rule”) 23(a) and

(b)(2) for violations of the statutory and common law of the State of Florida, and monetary

damages pursuant to Rule 23(a) and (b)(3) for violations of the statutory and common law of the

State of Florida.

Alternatively, Plaintiffs bring this action on behalf of themselves and a multi-state class of

residents of the States of Florida, New York, and California seeking declaratory and injunctive

relief pursuant to Rule 23(a) and (b)(2) for violations of the statutory and common law of the State

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have had their genetic makeup

altered to exhibit traits that are not naturally theirs

express novel traits that normally would not appear in

nature

has been altered in a way that does not occur

naturally

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Bacillus thuringiensis

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selection

insertion

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Id.

Id.

i.e.

Canola Oil and Soybean Oil

Extraction:

Alkalineutralization:

Bleaching:

Deodorizing:

Conditioning:

Enriched Flour

Niacin

Thiamine Mononitrate

Folic Acid N

L

Yellow Corn (enriched with thiamine, riboflavin, niacin, iron, folic acid) and

White Corn (enriched with thiamine, riboflavin, niacin, iron, folic acid)

Maltodextrin

Dextrose

Disodium Phosphate

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Oleoresin Paprika, Paprika Extract, Caramel Color, and Annatto Extract

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Frito-Lay turns to nature’s path

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Id.

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et seq.

et seq.

et seq.

et seq.

et seq.

et seq.

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