Pom Wonderful sued Coca-Cola under the Lanham Act and California unfair competition and false advertising laws, alleging that the name and labeling of Coca-Cola's Pomegranate Blueberry juice blend—which consisted mostly of cheaper apple and grape juices—misled consumers into believing it contained primarily pomegranate and blueberry juices. The district court dismissed the Lanham Act claim as to the product's name and labeling on the ground that it would improperly challenge or require interpretation of FDA regulations under the Food, Drug, and Cosmetic Act, while allowing other advertising claims to proceed and finding state claims preempted to the extent they differed from federal rules. The Ninth Circuit affirmed the bar on the Lanham Act name-and-labeling claim, holding that Congress had entrusted such juice-beverage labeling matters to the FDA and that courts must respect the agency's regulatory choices. The court vacated the judgment on the state-law claims and remanded for reconsideration of statutory standing in light of intervening California Supreme Court precedent.

business & regulatory