BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    AB 2827


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          Date of Hearing:  April 26, 2016


                           ASSEMBLY COMMITTEE ON JUDICIARY


                                  Mark Stone, Chair


          AB 2827  
          (Levine) - As Amended March 18, 2016


          SUBJECT:  ADVERTISING: MADE IN THE U.S.A. LABEL: VIOLATIONS:  
          CURE 


          KEY ISSUES:  


          1)Should BUsinesses that label their products with "made in the  
            u.s.a," "made in america," or "made in california" be given 33  
            days to cure "de Minimus" violations of the state law that  
            governs use of those labels?  


          2)SHOULD THE LEGISLATURE PROVIDE A RIGHT TO CURE "DE MINIMUS"  
            VIOLATIONS of the labeling law even though there is no  
            definition of the term "De Minimus," no mechanism for deciding  
            when violations have been "Cured," no details about how  
            labeling VIOLATIONs WOULD BE addressed for products THAT ARE  
            in commerce or the supply chain at the TIME WHEN the 33-day  
            period BEGINS, AND NO evidence that THE PROVISION WOULD SAVE  
            judicial resources?


          3)SHOULD THE LEGISLATURE UNDERMINE A LESS THAN ONE-YEAR-OLD  
            CONSUMER PROTECTION LAW ON A STATEWIDE BASIS IN REACTION TO  
            REPORTS THAT ONE ATTORNEY MAY HAVE FILED HUNDREDS OF CIVIL  








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            CLAIMS WHEN OTHER LEGAL TOOLS ARE AVAILABLE TO END LITIGATION  
            AND STOP VEXATIOUS LITIGIANTS AND UNETHICAL ATTORNEYS FROM  
            FILING FRIVOLOUS LAWSUITS?


                                      SYNOPSIS


          California's "Made in U.S.A." law, revised just last year in  
          order to be more flexible, not only protects consumers against  
          false or misleading advertising, but also protects domestic  
          businesses and the market value of the "Made in America" label  
          by ensuring that companies cannot gain a competitive advantage  
          through false or misleading advertising.  Until January 1, 2016,  
          California was the only state in the nation that required  
          product manufacturers to source 100 percent of their products  
          domestically before using the "Made in USA" or "Made in America"  
          label.  This requirement applied to all components and  
          subcomponents.  Thus, the entire supply chain was required to be  
          located within the United States.  California departed from this  
          historic and unique labeling requirement when it enacted Senate  
          Bill 633 ((Hill), Chapter 238, Statutes of 2015) which relaxed  
          the standards for use of the labels.  SB 633 allows a  
          manufacturer to use the Made in the U.S.A. label if 95 percent  
          of its product is domestically-produced, or 90 percent if the  
          remaining content could not be made or obtained within the  
          United States. 


          The author claims that at least one attorney has been busy in  
          the five months since SB 633 was enacted, stating that within  
          days of SB 633 taking effect, "hundreds" of demand letters were  
          sent out.  The letters demand that the companies do the  
          following: (1) cease and desist sales; (2) initiate a corrective  
          action advertising campaign; and (3) pull all products off the  
          shelves and refund purchases.  The author further states that  
          complying with these egregious demands would put the companies  
          out of business.  Further, although the letter invites companies  
          to "enter into discussions to resolve the demands," the author  








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          asserts that many companies view this as a shakedown.  This bill  
          provides that notwithstanding any other law, a person or  
          business may cure an alleged "de minumus" violation of the "Made  
          in U.S.A." or "Made in California" statutes in existing law  
          within 33 days of receiving written notice of the alleged  
          violation. 




          The analysis points out a number of philosophical and practical  
          problems with the bill.  First, there is no indication in the  
          legislative history of SB 633 that the Legislature intended to  
          make the labeling provisions irrelevant or unenforceable,  
          despite the greater flexibility offered under the new  
          legislation.  Second, the problem appears to be extremely small  
          in terms of numbers, involving possibly just one attorney.  If  
          even one thousand complaints (far more than the number estimated  
          by the author) regarding labeling violations had been filed in  
          the past year, those complaints would represent approximately  
          one eighth of one percent (.12%) of the total number of lawsuits  
          filed in the state.  Third, there are many other more  
          appropriate remedies to deal with vexatious litigants and  
          unethical attorneys.  A litigant (including an attorney) can be  
          declared "vexatious" and required to overcome pre-filing hurdles  
          before being allowed to file future lawsuits (such tactics have  
          been implemented specifically to stop litigation of frivolous  
          "Made in U.S.A." or "Made in California" claims); attorneys who  
          are deceptive, dishonest, or otherwise unethical are subject to  
          discipline (including dis-barrment in extreme cases) by the  
          State Bar; and once a case is before a court, there are myriad  
          opportunities for the matter to be dismissed, on either a  
          procedural or substantive basis.  Fourth, the bill fails to  
          define a crucial term, "de minimis," making it impossible to  
          determine what type of violation would trigger the 33-day right  
          to cure a violation.  Fifth, there are a number of practical  
          questions about implementation, including the following:  How  
          would a business "cure" a labeling violation when there is no  
          violation?  Who decides that the violation has been cured?  How,  








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          when, and by whom is that determination made?   If the parties  
          end up in court, how does this proposal save judicial resources?  
           Would this bill, in fact, make litigation more expensive  
          because there would be a new issue at trial about whether the  
          defendant had been given an opportunity to cure, and whether the  
          defendant had, in the 33-day period, cured all violations of the  
          law?  How would the "cure" be implemented on products that are  
          already in the supply chain or in commerce?


          This bill is distinguishable from the limited number of prior  
          laws where the Legislature has offered some ability to reduce  
          damages by taking corrective action.  It is also distinguishable  
          from prior legislature measures that have evened out the  
          bargaining power between parties by favoring the "little guy."   
          Because of these distinctions and concerns, the Committee may  
          wish to consider whether it is appropriate to weaken a consumer  
          protection law that applies to the entire state, amended just  
          one year ago, when the problem identified by the author seems to  
          involve a very small number of attorneys who could be subject to  
          either court order or State Bar discipline for repeatedly filing  
          frivolous lawsuits and there are many mechanisms to dismiss  
          meritless claims.  This bill is supported by a number of  
          business groups, including the California Chamber of Commerce,  
          and is opposed by consumer groups, labor unions, animal welfare  
          organizations, and the Consumer Attorneys of California.


          SUMMARY:  Prohibits a civil action against a person or business  
          that is alleged to have violated the provisions of the "Made in  
          U.S.A." or "Made in California" statutes unless written notice  
          of the alleged violations is provided and the person or business  
          has not cured the alleged violation within 33 days of receiving  
          the notice.  Specifically, this bill:  


          1)Provides that notwithstanding any other law, a person or  
            business may cure an alleged "de minumus" violation of the  
            "Made in U.S.A." or "Made in California" statutes in existing  








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            law within 33 days of receiving written notice of the alleged  
            violation. 


          2)Provides that the action taken to cure the violation may  
            include, but is not limited to, the prospective discontinued  
            use of the words "Made in U.S.A.," "Made in California," or  
            similar words and phrases on any merchandise, article, unit,  
            or part thereof.


          3)Provides that notwithstanding any law, no civil action may be  
            commenced unless the person or business is provided written  
            notice of the alleged violation and the person or business has  
            not cured the violation within 33 days of receiving the  
            notice.


          EXISTING LAW:   Existing State Law:


          1)Protects consumers and competitors against unlawful, unfair or  
            fraudulent business acts or practices and unfair, deceptive,  
            untrue, or misleading advertising.  (Business & Professions  
            Code (BPC) Section 17200 et seq.)
          2)Makes it unlawful for any person, firm, corporation or  
            association, or any employee thereof, to make or disseminate  
            before the public in this state, in any newspaper or other  
            publication or in any other manner or means whatever, any  
            statement concerning personal property which is untrue or  
            misleading, and which is known, or which by the exercise of  
            reasonable care should be known, to be untrue or misleading.   
            (BPC Section 17500 et seq.)


          3)Makes it unlawful for any person, firm, corporation or  
            association to sell or offer for sale in this state any  
            merchandise on which merchandise or on its container there  
            appears the words "Made in U.S.A.," "Made in America,"  








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            "U.S.A.," or similar words when the merchandise or any  
            article, unit, or part thereof, has been entirely or  
            substantially made, manufactured, or produced outside of the  
            United States.  (BPC Section 17533.7.)


          4)Provides that merchandise made, manufactured, or produced in  
            the United States that has one or more articles, units, or  
            parts from outside of the United States may be labeled "Made  
            in U.S.A.," "Made in America," "U.S.A.," or similar words if  
            all of the articles, units, or parts of the merchandise  
            obtained from outside the United States constitute not more  
            than five percent of the final wholesale value of the  
            manufactured product.  (BPC Section 17533.7 (b).)


          5)Provides that merchandise made, manufactured, or produced in  
            the United States that has one or more articles, units, or  
            parts from outside of the United States may be labeled "Made  
            in U.S.A.," "Made in America," "U.S.A.," or similar words if  
            both of the following apply:


             a)   The manufacturer of the merchandise shows that it can  
               neither produce the article, unit, or part within the  
               United States nor obtain the article, unit, or part of the  
               merchandise from a domestic source; and


             b)   All of the articles, units, or parts of the merchandise  
               obtained from outside the United States constitute not more  
               than 10 percent of the final wholesale value of the  
               manufactured product.  (BPC Section17533.7 (c)(1)(A)(B).)


          1)Provides that California's domestic origin labeling law shall  
            not apply to merchandise sold for resale to consumers outside  
            of the State of California.  (BPC Section 17533.7 (d).)









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          2)States that merchandise sold or offered for sale outside of  
            the State of California shall not be deemed mislabeled if the  
            label conforms to the law of the forum state or country within  
            which they are sold or offered for sale.  (BPC Section 17533.7  
            (e).)


          3)Prohibits, under the Consumer Legal Remedies Act (CLRA), any  
            unfair methods of competition, acts or practices by any person  
            which either results in or is intended to result in the sale  
            or lease of goods or services to any consumer.  (Civil Code  
            Section 1770.)
          4)Makes it unlawful to represent that a product is made in  
            California, by using a specified "Made in California" label,  
            unless the product complies with the requirements of the Made  
            in California Program established by the Governor's Office of  
            Business and Economic Development and registers for the  
            program and states that the purpose of the "Made in  
            California" Program is to encourage consumer product awareness  
            and foster purchases of high-quality products made in this  
            state.  (Government Code Section 12098.10.)


          5)Authorizes the Governor's Office of Business and Economic  
            Development to issue and make effective marketing agreements,  
            including, but not limited to, issuance of a "Made in  
            California" label that California companies can voluntarily  
            participate via funding or in-kind contributions into the Made  
            in California Program.  (Government Code Section 12098.10  
            (d).)


          6)Ensures that the finished product is substantially made within  
            California and that the product can lawfully use a "Made in  
            U.S.A." label and not violate Section 17533.7 of the Business  
            and Professions Code.  (Government Code Section 12098.10  
            (b)(1)(A)(B).)
          7)Defines "substantially made" as completing an act that adds at  








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            least 51% of a final product's wholesale value by manufacture,  
            assembly, fabrication, or production to create a final,  
            recognizable product; and specifies that the definition does  
            not include the act of packaging a product.  (Government Code  
            Section 12098.10 (b)(2).)


          Existing Federal Law:


          1)Authorizes the Federal Trade Commission to regulate country of  
            origin claims pursuant to authority granted to it under the  
            Federal Trade Commission Act, which prohibits "unfair or  
            deceptive acts or practices."  (15 U.S.C. Sec. 45.)  
          2)Requires that a "Made in U.S.A." label be consistent with  
            orders and decisions of the Federal Trade Commission.  (15  
            U.S.C. Sec. 45 (a).)


          3)Provides that a product may be labeled as "Made in U.S.A." if  
            the product is all or virtually all made in the United States,  
            however a product using such a label may contain-in a  
            negligible amount-components made outside of the United  
            States.  (Federal Trade Commission, Enforcement Policy  
            Statement on U.S. Origin Claims, 62 Fed. Reg. 63756, 63765  
            (Dec. 2, 1997).)
          FISCAL EFFECT:  As currently in print this bill is keyed  
          non-fiscal.


          COMMENTS:  The Legislature has long considered consumer  
          protection to be a matter of high public importance.  State law  
          is replete with statutes aimed at protecting California  
          consumers from unfair, dishonest, or harmful market practices.   
          The Consumer Legal Remedies Act (Civ. Code Sec. 1750 et seq.),  
          for example, was enacted "to protect the statute's beneficiaries  
          from deceptive and unfair business practices," and to provide  
          aggrieved consumers with "strong remedial provisions for  
          violations of the statute."  (Am. Online, Inc. v. Superior Court  








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          (2001) 90 Cal.App.4th 1, 11.)  Similarly, California's Unfair  
          Practices Act (BPC Section 17000 et seq.) has protected  
          California consumers from "unlawful, unfair or fraudulent  
          business act[s] or practice[s]" for over 70 years.  (BPC Section  
          17200.)


          Until January 1, 2016, California was the only state in the  
          nation that required product manufacturers to source 100 percent  
          of their products domestically before using the "Made in USA" or  
          "Made in America" label.  This requirement applied to all  
          components and subcomponents.  Thus, the entire supply chain was  
          required to be located within the United States.  California  
          departed from this historic and unique labeling requirement when  
          it enacted Senate Bill 633 ((Hill), Chapter 238, Statutes of  
          2015) which relaxed the standards for use of the labels.  SB 633  
          allows a manufacturer to use the Made in the U.S.A. label if 95  
          percent of its product is domestically-produced, or 90 percent  
          if the remaining content could not be made or obtained within  
          the United States. 


          Despite the relaxed labeling standards, consumer protection  
          regarding country of origin labeling is a matter of important  
          public policy.  California consumers who care about truthful  
          labels suffer an economic loss when they purchase a product they  
          would not otherwise have purchased, had not the label accurately  
          stated the product's origins. Further, California's "Made in  
          U.S.A." law protects domestic businesses and the market value of  
          the "Made in America" label by ensuring that companies cannot  
          gain a competitive advantage through false or misleading  
          advertising. 


          The value of a "Made in America" label in the manufacturing  
          sector is substantial.  Studies show that Americans will pay a  
          premium to purchase products exclusively manufactured in the  
          United States and that consumers rely on the "Made in USA" or  
          "Made in America" label to guide their purchases. Manufacturers  








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          seem to understand the value of these labels to consumers, as  
          demonstrated by the fact that California's largest corporation,  
          Apple Inc., recently shifted production of its Mac Pro personal  
          computer line to the United States as part of a "$100 million  
          'made in the USA' push."  (Burrows, Apple Kicks Off "Made in  
          USA" Push with Mac Pro (Dec. 18, 2013) The San Francisco  
          Chronicle  
           (as of January 4, 2014).)   
          Announcing the company's shift to domestic production, Chief  
          Executive Officer Tim Cook said "[w]e don't want to just  
          assemble the Mac Pro here, we want to make the whole thing here.  
          This is a big deal." (Ibid.)  Apple's decision reflects the  
          market reality that products advertised or labeled as "Made in  
          U.S.A." have a decisive marketplace advantage over their foreign  
          counterparts. Indeed, an April 2013 Gallup poll found that 45  
          percent of Americans surveyed had made a recent special effort  
          to buy products that were made in the U.S.A., and that 64  
          percent of those surveyed would pay more to buy an American-made  
          product than a similar product made in another country.  (Jones,  
          Patriotism, Jobs Primary Motivations for 'Buying American' (Apr.  
          30, 2013) Gallup Economy <  
          http://www.gallup.com/poll/162110/patriotismjobs-primary-motivati 
          ons-buying-american.aspx> (as of January 5, 2014).)


          Author's Stated Need for the Bill.  The author claims that at  
          least one attorney has been busy in the five months since SB 633  
          was enacted, stating that within days of SB 633 taking effect,  
          "hundreds" of demand letters were sent out.  The letters demand  
          that the companies do the following: (1) cease and desist sales;  
          (2) initiate a corrective action advertising campaign; and (3)  
          pull all products off the shelves and refund purchases.  The  
          author further states that complying with these egregious  
          demands would put the companies out of business. Further,  
          although the letter invites companies to "enter into discussions  
          to resolve the demands," the author asserts that many companies  
          view this as a shakedown. 









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          Further, the author has given the Committee an example of a  
          lotion manufacturer in his district whose principle market is  
          overseas that was sued because its label complied with foreign  
          labeling rules, but not California's "Made in the U.S.A." laws.


          The author of this bill also states that SB 633 was not intended  
          to require companies to pull all their products off the shelves.  
           Rather, the intent of SB 633 was to "help promote manufacturing  
          in California, to encourage the establishment of small  
          businesses, and to help create jobs in the state and to make the  
          "Made in U.S.A." or "Made in California" labeling standard  
          consistent with the "all or virtually all" standards used by all  
          49 other states and the federal government."    


          SB 633's Goal to Provide Flexibility to Manufacturers of  
          Products That are Virtually, but not Completely, 100% Made in  
          California or the United States. It is curious that the author  
          draws a connection between SB 633 and increased litigation when  
          logic would dictate that the relaxed labeling standards in SB  
          633 would decrease, rather than increase, litigation.  The  
          author of SB 633 pointed out, in the background materials about  
          that bill (according to the Assembly Privacy and Consumer  
          Protection Committee analysis of SB 633), in the earlier,  
          preceding opinion from the California Court of Appeal (Fourth  
          District) in Benson v. Kwikset from June 2007, which upheld the  
          trial court's narrow reading of the Made in the U.S.A. statute,  
          the majority raised the possibility of a legislative solution: 


               We also share our dissenting colleague's angst about both  
               the effect of this law, particularly in an age of global  
               trade, and the potential for abuse that may arise under the  
               unfair competition law.  If we had the power to do so, we  
               would rewrite the statute to address those concerns.  But  
               our Supreme Court has cautioned 'the judicial role in a  
               democratic society is fundamentally to interpret laws, not  








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               to write them.  The latter power belongs primarily to the  
               people and the political branches of government. [Citation]  
                It cannot be too often repeated that due respect for the  
               political branches of our government requires us to  
               interpret the laws in accordance with the expressed  
               intention of the Legislature.  This court has no power to  
               rewrite the statute so as to make it conform to a presumed  
               intention which is not expressed.


          There is no indication in the legislative history of SB 633,  
          however, that the Legislature intended to make the labeling  
          provisions irrelevant or unenforceable, despite the greater  
          flexibility offered under the new legislation. 
    

          Scope of the Reported Problem Appears to be Limited in Terms of  
          the Numbers of Civil Claims and the Attorneys Responsible for  
          Filing Them.  According to the author, "[s]everal legal actions  
          have recently been taken against businesses accused of  
          misleading their customers by declaring that their products were  
          Made in California or Made in America."  The plaintiffs' lawyer,  
          according to the author, has sent letters to the businesses,  
          demanding various remedies, including but not limited to the  
          recall of all products for all product lines from the shelves of  
          retail outlet, and has stated that "hundreds" of these letters  
          were sent.  


          To put the figure of "hundreds" of lawsuits in perspective, a  
          total of 800,091 lawsuits were filed in the state in 2013,  
          according to the Judicial Council of California.  Meanwhile,  
          California has approximately 3.3 million small businesses.   
          These figures mean that a miniscule portion of less than one  
          percent of small businesses (and a far smaller percentage of all  
          businesses) have been sued for "Made in U.S.A." or "Made in  
          California" labeling violations.  If even one thousand  
          complaints (far more than the number estimated by the author)  
          regarding labeling violations had been filed in one year, those  








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          complaints would represent approximately one eighth of one  
          percent (.12%) of the total number of lawsuits filed in the  
          state.


          Other Remedies Available to Deal with Vexatious Litigants and  
          Unethical Attorneys. The law is replete with options for courts  
          and parties to deal with vexatious litigants and unethical  
          attorneys: 


          "Vexatious" litigants.  A "vexatious litigant" is a person who  
          repeatedly litigates unmeritorious claims, files unmeritorious  
          motions, pleadings, or other papers, conducts unnecessary  
          discovery, or engages in other tactics that are frivolous or  
          solely intended to cause unnecessary delay.  (See CCP Section  
          391 (b).)  Once a person is found by a court to be a vexatious  
          litigant, the person is subject to many barriers to bringing and  
          pursuing new claims.  The rationale is that because of the  
          person's history of bringing unmeritorious claims, he or she is  
          presumed to not have valid claims in the future and should  
          therefore have to overcome procedural hurdles before using court  
          resources.  For example, a defendant sued by a vexatious  
          litigant may ask that the court order the plaintiff to furnish  
          security or seek an order dismissing the litigation when there  
          is evidence to show that the plaintiff is a vexatious litigant  
          and that there is not a reasonable probability that he or she  
          will prevail in the litigation against the moving defendant.   
          (CCP Section 391.1.)  The court may also, on its own motion or  
          the motion of any party, enter a "prefiling order" which  
          prohibits a vexatious litigant from filing any new litigation in  
          the courts of this state without first obtaining leave of the  
          presiding justice or presiding judge of the court where the  
          litigation is proposed to be filed.  (CCP Section 391.7(a).)   
          The Judicial Council is required to maintain a record of  
          vexatious litigants subject to those prefiling orders and shall  
          annually disseminate a list of those persons to the clerks of  
          the courts of this state.  (CCP Section 391.7(f).)









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          In fact, such tactics have been implemented specifically to stop  
          litigation of frivolous "Made in U.S.A." or "Made in California"  
          claims.  A disbarred lawyer who has made it his mission to  
          promote American-manufactured products is facing opposition that  
          would block him from filing lawsuits in California.  According  
          to the National Law Journal, Joel Joseph, chairman of the Made  
          in the USA Foundation in Los Angeles (who was disbarred in 2011  
          in Maryland) has continued to file suits as a pro se (on behalf  
          of himself) plaintiff against companies like Costco Wholesale  
          Corp., Trader Joe's Co. and CVS Pharmacy Inc. over the labeling  
          of ground meat and generic pharmaceuticals. The cases were filed  
          in California, where Joseph used a private attorney general  
          action under the state's consumer laws to assert the products  
          were mislabeled in violation of the Tariff Act or other federal  
          laws.  
          (  http://www.nationallawjournal.com/id=1202750158962/Dogged-Made-i 
          n-USA-Advocate-is-Vexatious-CVS-Argues#ixzz46P6JaEcG  .)  After  
          CVS Pharmacy, Inc. filed a motion to declare Mr. Joseph a  
          "vexatious litigant," based upon 10 matters in the past seven  
          years that Mr. Joseph lost, plus "repeated frivolous,  
          misleading, and dilatory tactics" in other cases, the court  
          granted the motion and placed Mr. Joseph on the vexatious  
          litigant list.  (  http://www.courts.ca.gov/documents/vexlit.pdf  .)


          Although vexatious litigants are generally not attorneys, an  
          attorney can be found to be a vexatious litigant when he or she  
          uses a client as a "strawman" plaintiff" while pursuing  
          "obsessive, meritless litigation" that demonstrates "a pattern  
          of using the judicial system as a weapon in an unrelenting quest  
          to get advantages that he does not deserve, imposing onerous  
          litigation costs on his opponents that he does not incur himself  
          because he is a lawyer."  (In re Kinney (2011) 201 Cal. App. 4th  
          951, 959.)  In Kinney, the court found that the attorney, who  
          repeatedly sued his neighbors over property disputes was someone  
          "for whom litigation has become a game" that he was no longer  
          allowed to play.  (Ibid.) Attorneys who file repeated,  
          unmeritorious claims (on behalf of themselves or "straw  
          clients") for violations of the Made in the U.S.A. labeling law  








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          "as a weapon," like Kinney, to extract settlements and impose  
          onerous litigation costs on their opponents, could likewise be  
          declared to be vexatious litigants.  

          Attorneys who are deceptive, dishonest, or otherwise unethical.   
          The California Rules of Professional Conduct apply to attorneys  
          and provide that attorneys are officers of the court and have an  
          ethical obligation to advise the court of legal authority that  
          is directly contrary to a claim being pressed.  (Batt v. City  
          and County of San Francisco (2007) 155 Cal.App.4th 65, 82, fn.  
          9, 65 Cal.Rptr.3d 716.)  Rule 5-200 of the Rules of Professional  
          Conduct addresses the issue and provides that, "[i]n presenting  
          a matter to a tribunal, a member: (A) Shall employ ... such  
          means only as are consistent with truth; [and] (B) Shall not  
          seek to mislead the judge ... by an artifice or false statement  
          of fact or law[.]"  (See also Southern Pacific Transp. v. P.U.C.  
          of State of Cal. (9th Cir.1983) 716 F.2d 1285, 1291 [failure to  
          cite opposing authority is a "dereliction of duty to the  
          court"].)  An attorney is "bound by ethical considerations not  
          to pursue unmeritorious or frivolous matters on behalf of a  
          prospective client [citation omitted].)  (In re Kinney, supra,  
          201 Cal. App. 4th at p. 959.)  "In representing a client, a  
          lawyer shall not use means that have no substantial purpose  
          other than to embarrass, delay, or burden a third person, or use  
          methods of obtaining evidence that violate the legal rights of  
          such a person." (Model Rules of Professional Conduct, Rule 4.4.)  
           Attorneys who violate these rules are subject to discipline  
          (including dis-barrment in extreme cases) by the State Bar.  In  
          2014, the Bar opened approximately 4,000 attorney discipline  
          cases and closed 5,000 cases (including approximately 1,000  
          opened prior to 2014).


          Abundant Opportunities to Dismiss Meritless Claims Before and  
          During Trial.  Once a case is before a court, there are myriad  
          opportunities for the matter to be dismissed, on either a  
          procedural or substantive basis.  For example, a defendant is  
          entitled to summary judgment in his or her favor if "all the  
          papers submitted show that there is no triable issue as to any  








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          material fact" alleged by the plaintiff.  (CCP Section 437c  
          (c).)  A motion for summary judgment may be made any time after  
          60 days have elapsed since the general appearance in the action  
          (CCP Section 437c (a)) or any time after the answer is filed  
          upon giving five days' notice (CCP Section 1170.7).   
          Furthermore, it has long been recognized in this State that a  
          court has inherent power, upon a sufficient factual showing, to  
          dismiss an action "shown to be sham, fictitious or without merit  
          in order to prevent abuse of the judicial process."  (Muller v.  
          Tanner (1969) 2 Cal.App.3d 438, 443, 82 Cal.Rptr. 734, quoting  
          from Lincoln v. Didak (1958) 162 Cal.App.2d 625, 629-630, 328  
          P.2d 498.)  


          This bill Fails to Define a Crucial Term, De Minimis, Making it  
          Impossible to Determine What Type of Violation Would Trigger the  
          33-day Right to Cure.  According to Merriam Webster, "de minimis  
          means lacking significance or importance:  so minor as to merit  
          disregard.  http://www.merriam-webster.com/dictionary/de%20minimis  .) But  
          what does it mean in relation to "Made in U.S.A." or "Made in  
          California" labeling requirements?  It is impossible to say with  
          certainty because the term is undefined in the bill.  It would  
          seem that the Legislature has already weighed in on what is a  
          "de minimis" variation from products that are made completely  
          and almost completely in the U.S.A. when it relaxed the  
          manufacturing standards from 100% to 95 (or 90)% in last year's  
          SB 633.  There is no indication in that legislation that the  
          Legislature intended to provide additional leeway to businesses  
          by allowing them to use a label when the percentage of domestic  
          components is lower than those levels.


          What does this term mean to the author?  It is difficult to say.  
           Despite repeated inquiries from the Committee, the author's  
          office has not provided a definition for the term "de minimis."   
          However, in response to inquiries from the Committee about some  
          of the practical issues raised by the bill (discussed in detail  
          below), the author provided the following information about when  








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          a business would be able to exercise its right to cure, shedding  
          some light on the author's intent.  It appears that the author  
          would allow the business to make any changes to the product or  
          the packaging that it deemed necessary.  "Remember, the bill  
          only applies to de minimus violations.  Curing a violation could  
          be achieved in a number of ways depending on the cases.  Change  
          the labels, change the ingredients, etc., depending on the  
          circumstances of the case."    


          Questions about the Practical Effect of the bill: What the Right  
          to Cure Means and Whether it Would Save Judicial Resources.  In  
          terms of implementation, there are a number of practical  
          concerns and questions with this bill:


          1)How would a business "cure" a labeling violation when there is  
            no violation?  According to the author, the companies that  
            have been sued "believe that they are already in full  
            compliance with the law and that the demand letters are a form  
            of a 'shake down'.  They believe that going to court to fight  
            it would cost them more than paying a settlement."  In fact,  
            it appears that the businesses have a very strong argument  
            that they are in compliance with existing law.  For example,  
            according to the author, a manufacturer of lotion was sued for  
            using a label that is required for export of the product  
            overseas.  BPC Section 17533.7 (e) specifies that "For  
            purposes of this section, merchandise sold or offered for sale  
            outside of California shall not be deemed mislabeled if the  
            label conforms to the law of the forum state or country within  
            which they are sold or offered for sale," which seems to give  
            the manufacturer a complete defense to the claim.  Assuming  
            that is the case, the defendant would certainly prevail at  
            trial (or in a summary judgment motion).  How would AB 2827  
            help such a defendant, if it were to become law?  The  
            manufacturer would have no violation to "cure" because the  
            manufacturer would already be in compliance with the law.  










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          2)Who decides that the violation has been cured?  By agreement  
            of the parties?  What if the plaintiff disagrees that the  
            violation has been cured?  Who has the burden of proving that  
            the violation has been cured, or not?  How, when, and by whom  
            is that determination made?  According to the author, "As with  
            any potential litigation like this, the parties would decide  
            whether there is compliance.  If they cannot agree, they could  
            pursue an action in court."  But why would a plaintiff who had  
            gone to the trouble to file a meritless lawsuit agree, without  
            going to court and without a financial settlement, that the  
            violation had been cured?  And if the parties end up in court,  
            how does this proposal save judicial resources?  Would this  
            bill, in fact, make litigation more expensive because there  
            would be a new issue at trial about whether the defendant had  
            been given an opportunity to cure, and whether the defendant  
            had, in the 33-day period, cured all violations of the law?


          3)How would the "cure" be implemented on products that are  
            already in the supply chain or in commerce?  If a manufacturer  
            is sued, would the manufacturer issue a recall to all products  
            that have been sent to distributers and retailers?  If so,  
            would the manufacturer be liable to distributors and retailers  
            for the cost of removing products from shelves and returning  
            them, and for the lost sales of products that cannot be sold?   
            If a retailer is sued, who would be responsible for relabeling  
            the product - the retailer, the distributor, or the  
            manufacturer?  And who would pay those costs?  And is it even  
            legal for a retailer or distributor to repackage or re-label a  
            product when packaging or labels could be protected by  
          trademark?  


          Other "Right to Cure" Laws.  The author and supporters argue  
          this bill is similar to other right-to-cure laws and thus  
          justify providing new opportunities for the right-to-cure in  
          other violations of the law.  However, each cited law can be  
          distinguished:









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          Civil Code Section 51.6 gives businesses a very limited  
          opportunity to cure non-compliance with the requirement that  
          they post a list of prices on the premises of their businesses. 


                 The business does not have an opportunity to cure the  
               underlying discrimination claim (charging different prices  
               based upon gender), however, and is liable for minimum  
               statutory damages of $4,000 per violation pursuant to Civil  
               Code §§ 51.6 (d), 52 (a).
                 The "cure" (posting one sign) is much easier to comply  
               with and verify than relabeling products that may or may  
               not already be in the supply chain.  
                 It is also easy to verify whether or not a business has  
               "cured" the violation.  Either the sign is posted on the  
               premises, or it's not.  If the business fails to comply  
               with the requirement to post their price list within 30  
               days of receiving a written notice to do so, the business  
               is liable for a civil penalty of $1,000.  


          Labor Code Section 2699 et seq. require an aggrieved worker to  
          give notice to the Labor and Workforce Development Agency and  
          the employer of the specific provisions of the Labor Code  
          alleged to have been violated, including the facts and theories  
          to support the alleged violation, and give the labor  
          commissioner the opportunity to take action against the employer  
          prior to filing an individual civil action against the employer  
          for such violations.


                 These provisions are distinguishable from this bill  
               because violations of the Labor Code, unlike the Civil  
               Code, are subject to enforcement by a statewide regulator  
               with broad powers of inspection, citation, and discipline:  
               the Commissioner of the Labor and Workforce Development  
               Agency. 
                 Violations of "Made in the U.S.A." or "Made in  








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               California," on the other hand, are not enforced by a state  
               or federal agency. 
                 Because there is no public entity regulator to inspect,  
               cite, or discipline businesses who violate these laws, the  
               only way to enforce the law is through the courts.  


          Civil Code Section 55.56 allows for reduced damages for  
          construction-related accessibility standards when a small  
          business has been previously inspected by certified  
          accessibility specialist) is distinguishable from AB 2827.


                 It does not relieve the defendant from liability. If a  
               defendant resolves a construction related disability access  
               violation their damages are merely reduced from $4,000 to  
               $1,000. 
                 Although their damages are reduced, defendants are still  
               held liable for the underlying violations.


          Civil Code Section 1782 requires a thirty day notification by a  
          consumer who suffers any damage as a result of the use or  
          employment by any person of a method, act, or practice declared  
          to be unlawful before commencing an action for damages is  
          distinguishable from AB 2827.


                 A consumer can still file an action for injunctive  
               relief without having to wait the 30 days.
                 After waiting the 30 days, the consumer can amend the  
               complaint to include a request for damages. 


          On the other hand, this Committee (and the Legislature) has  
          approved bills in the past that give a party the "right to cure"  
          some contract violations when the party in breach of the  
          contract is at a disadvantage in terms of bargaining power, such  
          as franchisees and farm equipment dealers.  In those cases, the  








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          Legislature decided that it needs to put its hand on the scale  
          to even out the balance of power between the parties because it  
          would be unfair to strictly enforce the contract.  The following  
          bills show how the Legislature is willing to provide a "Right to  
          Cure" in such cases:


          AB 525 (Atkins and Holden, Chap. 776, Stats. of 2015) gives  
          franchisees a 60-day opportunity to cure a breach of their  
          franchise agreement.  Supporters reported that franchisees are  
          often given as little as five days to cure noncompliance-an  
          unreasonable amount of time depending on the nature of the cure  
          needed-and therefore providing 60 days to cure is a reasonable  
          solution common to many other commercial transactions.  


          AB 585 (Negrete McLeod, Chap. 712, Stats. of 2005) provides that  
          in the case of a termination of a farm equipment dealership  
          agreement with a farm equipment supplier based upon the dealer's  
          consistent failure to meet and maintain the supplier's  
          reasonable performance objectives, the supplier must give at  
          least two years notice and the dealer would have that two-year  
          period to attempt to cure.


          This bill, on the other hand, does not provide any such similar  
          help to "the little guy."  Its provisions do not focus on small  
          businesses that are sued for these violations.  Instead, it  
          provides the right to cure to all businesses that are sued,  
          regardless of their size and financial resources.   


          Because of all of the concerns described above, the Committee  
          may wish to consider whether it is appropriate to weaken a  
          consumer protection law that applies to the entire state,  
          amended just one year ago, when the problem identified by the  
          author seems to involve a very small number of attorneys who  
          could be subject to either court order or State Bar discipline  
          for repeatedly filing frivolous lawsuits and there are many  








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          mechanisms to dismiss meritless claims.


          ARGUMENTS IN SUPPORT:  In support of the bill, the California  
          Small Business Association, states that:


               Small businesses respect the law and will continue to do  
               so.  They have not intentally (sic) broken them but often  
               the interpretation is at odds as well as information on new  
               regulations not communicated to the small business owners.   
               However, many of our small businesses have been subject to  
               threats of frivolous lawsuits and shakedowns.  This "right  
               to cure" is a giant step forward.


          In support of the bill, the California Manufacturers &  
          Technology Association, states that:


               Right-to-cure provisions represent a real, necessary  
               protection from predatory lawsuits that ultimately cost  
               California manufacturers to fight, win or lose. 


          The California Chamber of Commerce, states that:


               AB 2827 is a job creator as it will provide businesses with  
               a limited time period in which to resolve alleged labeling  
               violations regarding product "Made in the USA" or "Made in  
               California" without facing devastating litigation.  
               Consistent with other areas of the law, AB 2827 seeks to  
               limit litigation for alleged de minimums violations  
               regarding representation of where the product was made.  


               The Consumer Legal Remedies Act (CLRA) allows consumers to  
               pursue costly litigation against businesses for over 20  








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               different "unfair methods of competition," including  
               deceptive representations as to the geographical source of  
               the good.  This financial threat of litigation has created  
               an opportunity for attorneys to leverage businesses into  
               quick monetary settlements for alleged misrepresentations  
                                                                on labels of goods that represent "Made in USA" or Made in  
               California" or even a specific location in California.   
               While certainly there are egregious examples of where a  
               company has misrepresented the geographical source of a  
               good, there are numerous examples of where all, or the  
               majority of all ingredients, components or parts of the  
               product are sourced in the geographical location identified  
               and yet the threat of litigation is still leveraged against  
               these businesses. 


          In support of the bill, the Civil Justice Association of  
          California, states that:


               The right to cure concept is already found in a number of  
               California statutes, including the Consumer Legal Remedies  
               Act (see Civil Code § 1782), Private Attorneys General Act  
               (PAGA) (see Labor Code § 26993(c)(2)), and Civil Code  
               sections dealing with construction-related accessibility  
               complaints (see Civil Code § 55.56.) 


               AB 2827 is necessary because California companies have  
               recently received demand letters alleging violations of the  
               California Government Code § 12098.10 and Business and  
               Professions Code § 17533.  These letters include demands  
               that many companies would find impossible to meet without  
               going bankrupt: the examples we have seen called for ending  
               the sale of all disputed products, full recalls, refunds,  
               and advertising campaigns to inform consumers of the "true  
               nature" of disputed products.  Companies must choose  
               between meeting these unreasonable demands, settling out of  
               court and providing the plaintiff attorneys with a  








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               financial windfall, or engaging in costly litigation to  
               defend their labels.  AB 2827 is a practical way to protect  
               California manufacturers and businesses from abusive  
               litigation by allowing a company to cure an alleged  
               violation by including (but not limited to) changing the  
               label going forward.   


               By allowing a prospective label change and time to cure  
               prior to commencement of a civil action, this bill provides  
               a means to act on genuine concern about the accuracy of  
               information provided to consumers via origin labeling. At  
               the same time the bill removes the incentive for abusive  
               lawsuits intended to enrich litigators rather than protect  
               consumers. 


          ARGUMENTS IN OPPOSITION:  The Animal Legal Defense Fund writes  
          the following in opposition to this bill:


               Giving businesses the right to "cure" errors on labels  
               would not only undermine consumer confidence that their  
               choices matter, it might also endanger the health of pets  
               in California, the more immediate threat to which I refer  
               above. You are likely aware that many pets died in 2007  
               after consuming adulterated products containing ingredients  
               imported from China. Many concerned pet owners and  
               guardians determined afterward to purchase only those  
               products labeled Made in the USA, which they believe to be  
               safer. While existing law enacted through S.B. 633 does  
               permit a producer to use the Made in the USA label even for  
               products in which 10% of the ingredients derive from  
               foreign sources, the threat to animals arising from that  
               policy choice is considerably less severe than the threat  
               to animals that A.B. 2827 might create-namely, that  
               dishonest producers, armed with a free pass, will peddle  
               their products as American-made even while they might be  
               substantially derived from foreign sources. Indeed, several  








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               lawsuits are currently working their way through federal  
               courts in California against major pet food retailers  
               alleged to have resorted to deceptive marketing. A.B. 2827  
               might enable these defendants to walk away, leaving the  
               injuries of the California consumer-plaintiffs unredressed.


          In opposition of the bill, the California Teamsters Public  
          Affairs Council states that: 


               This bill is premature given that California just enacted  
               laws dealing with these two labeling statutes and requiring  
               a new procedure to enforce them is not necessary. Further,  
               the "right to cure" violations expressed in the bill is  
               completely ambiguous.  There is no definition of how a  
               company would "cure" what is in essence fraud on the  
               consumer. 


          In opposition of the bill, the Consumer Attorneys of California  
          (CAOC) states: 


               This bill sets a bad precedent in the important area of  
               consumer tort law and the Consumers Legal Remedies Act.   
               The legislature passes laws with the intention that the  
               laws be followed and enforced. We must have faith in the  
               civil jury system to determine merit.  CAOC opposes notice  
               and opportunity to cure provisions on principle because  
               other businesses (e.g. employers who violate prevailing  
               wage laws) do not receive this special treatment to cure a  
               violation of the law. 


          In opposition of the bill, the Consumer Federation of California  
          (CFC) states: 










                                                                    AB 2827


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               On January 1, 2016, Senate Bill 633 (Hill) became law.  SB  
               633 lowered the standard to allow a product containing as  
               much as 10% imported content to be lawfully offered for  
               sale in California bearing a "Made in USA" or "Made in  
               America" label.  We believe the legislature should grant  
               this brand new law a reasonable time period to operate  
               before further weakening an important truth in advertising.  
                 This bill would create a perverse incentive for certain  
               business to take advantage of a blanket immunity from  
               enforcement of a consumer protection law.  


          SIMILAR PRIOR LEGISLATION:  AB 2624 (Medina, 2014) would have  
          made it unlawful to sell any product that contains the words  
          "Made in North America," "North American Made," or similar words  
          on the product or its container unless all or virtually all of  
          the product was made in the United States, Canada, or Mexico.   
          This bill would have also added misrepresenting a product as  
          made in North America to the list of unfair methods of  
          competition and unfair or deceptive acts or practices actionable  
          under the Consumers Legal Remedies Act.  This bill died on the  
          Senate Inactive File.


          SB 661 (Hill, 2014) would have provided that merchandise made,  
          manufactured, or produced in the United States that has an  
          article, unit, or part from outside of the United States may be  
          labeled and sold in California as "Made in U.S.A." or "Made in  
          America" if the following requirements are met:  (1) the  
          manufacturer of the merchandise certifies that it can neither  
          produce the article, unit, or part within the United States nor  
          obtain the article, unit, or part of the merchandise from a  
          domestic source; (2) the manufacturer's determination that the  
          article, unit, or part cannot be produced or obtained within the  
          United States from a domestic source is not based on the cost of  
          the article, unit, or part; and (3) the article, unit, or part  
          of the merchandise obtained from outside the United States  
          constitutes only a negligible part of the final manufactured  
          product.  This bill failed passage out of the Senate Judiciary  








                                                                    AB 2827


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          Committee on a 2-5 vote.


          AB 890 (Jones, 2013) would have provided that a product sold in  
          California could carry the label "Made in U.S.A." if it was  
          substantially made, manufactured, or produced in the United  
          States as measured by the following criteria: at least 90  
          percent of the components, parts, articles, or units of the  
          merchandise were manufactured in the United States; United  
          States manufacturing costs constitute at least 90 percent of the  
          total manufacturing costs for the merchandise; and the  
          merchandise was last substantially transformed or assembled in  
          the United States.  This bill failed passage out of the Senate  
          Judiciary Committee on a 2-5 vote.


          AB 858 (Jones, 2012) was substantially similar to SB 663 (Hill,  
          2015).  This bill failed passage out of the Senate Judiciary  
          Committee on a 2-3 vote.


          ABX6 8 (Beall, 2010) identical to AB 858, this bill was  
          introduced in the Sixth Extraordinary Session but was never  
          referred to a policy committee.


          SB 1004 (Holmdahl, Ch. 676, Stats. 1961) codified California's  
          "Made in the U.S.A." law, making it unlawful for any person,  
          firm, corporation, or association to sell or offer for sale any  
          merchandise that advertises itself as being made or manufactured  
          in the United States when any article, unit, or part of the  
          merchandise has been entirely or substantially made,  
          manufactured, or produced outside of the United States.


          REGISTERED SUPPORT / OPPOSITION:











                                                                    AB 2827


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          Support


          California Chamber of Commerce


          California Manufacturers & Technology Association


          California Retailers Association


          California Small Business Association


          Civil Justice Associations of California




          Opposition


          Animal Legal Defense Fund  


          California Conference Board of the Amalgamated Transit Union


          California Conference of Machinists


          California Teamsters Public Affairs Council


          Consumer Attorneys of California










                                                                    AB 2827


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          Consumer Federation of California


          Engineers & Scientists of California, Local 20, IFPTE Local 20,  
          AFL-CIO


          Professional & Technical Engineers, IFPTE Local 20, AFL-CIO


          UNITE-HERE, AFL-CIO


          Utilities Workers Union of America, Local 132, AFL-CIO




          Analysis Prepared by:Alison Merrilees / Amanda Hall / JUD. /  
          (916) 319-2334