1 Labeling Cases Filed in November and December .............................................................................................2 Court Pulls the Plug on Some Heavy Metal Claims, But Allows Others to Rock On ..............................................3 Ninth Circuit Affirms Juicy Decision in Favor of Fruit-Cup Manufacturer .............................................................4 Licorice Lover Receives Not-So-Sweet Motion to Dismiss ..................................................................................4 Court Corrects Conclusion About “Carbon-Neutral” Claims ...............................................................................5 What’s in Your Granola? ....................................................................................................................................5 Mac-and-Cheese Blues .....................................................................................................................................6 Cracker Consumers Crackdown on Cornstarch ..................................................................................................7 Acid Redux: Another “No Preservative” Citric Acid Case ....................................................................................7 Empty Space in My Cracker Box? Fuhgeddaboudit ............................................................................................8 Tussle over Toddler Formula ..............................................................................................................................8 New Year, New … Oh Wait! Malic Acid Mania Continues ....................................................................................8 Making a Great Pear!.........................................................................................................................................9 Plaintiff Cries over Labeling Claims on Food Allegedly for Babies .......................................................................9 A Juicy Ending to 2024 ...................................................................................................................................10 Will Cage-Free Egg Claims Crack Under the Pressure of Class Action Litigation? ..............................................10 Emergen-See You in Court ..............................................................................................................................11 ImPEACHing Claims of Natural Flavors ............................................................................................................11 Protein Bar Purchases Leave Plaintiff Feeling Salty..........................................................................................11 Petits Fours ....................................................................................................................................................12 Contributing Authors ......................................................................................................................................13 JANUARY 2025
2 For an amuse-bouche, we’ve gathered the details and served up a chart highlighting the variety of 43 new suits filed in November and December— a taste of the latest labeling claims. 21 “Natural” Ingredient Claims 5 Nutrient Content Claims 9 Flavor/Ingredient Claims 1 Health & Wellness Claims 1 Slack-fill 5 Foreign Substances 1 Environmental, Social & Governance Claims
3 Case Decisions Court Pulls the Plug on Some Heavy Metal Claims, But Allows Others to Rock On Raya v. Mead Johnson Nutrition Co., No. 1:24-cv-04696 (N.D. Ill. Dec. 2, 2024). An Illinois consumer accused a leading manufacturer of infant formula of breaking the law, breaking the law by failing to disclose that its products purportedly contained, or had a material risk of containing, heavy metals that allegedly pose health risks to toddlers. While the court sent the plaintiff’s fraudulent omission and warranty claims off to never-never land, her complaint ultimately did not suffer a megadeath— the court found that her Illinois Consumer Fraud Act (ICFA) claim survived. But it is difficult to square the court’s reasoning in dismissing the fraud claim and allowing the ICFA claim to proceed, leaving at least this humble reader thunderstruck at the decision. Let me explain. In Raya, the court recognized that the plaintiff’s fraud claim depended on whether the manufacturer had a duty to disclose. That duty can arise in several situations, including when the defendant’s concealment results in the presentation of half-truths. The court identified the specific statements on the packaging— “Brain Building DHA [docosahexaenoic acid],” “Non-GMO,” “No artificial growth hormones”—and then found that the presence of heavy metals in the infant formula did not render any of these statements untrue. No half-truths, no duty to disclose, no fraud claim. However, turning to the ICFA claim, the court found that these same statements on the packaging, “in context and in absence of a warning label … are misleading.” The court accepted the plaintiff’s theory that, by calling out healthy ingredients on the packaging, the manufacturer conveyed that its product was safe and nutritious when it was not, due to the presence of heavy metals. That sure sounds like a finding that the statements were less than the full truth in the absence of a fair warning. And for the manufacturer, that seemingly inconsistent reasoning may be a bitter pill to swallow.
4 Case Decisions Ninth Circuit Affirms Juicy Decision in Favor of Fruit-Cup Manufacturer Bryan v. Del Monte Foods Inc., No. 23-3685 (9th Cir. Nov. 22, 2024). In an unpublished decision less than three pages long, the Ninth Circuit still packs a punch in affirming a lower-court ruling finding a fruit-cup label could not have misled a reasonable consumer. In the underlying complaint, the plaintiff alleged that a fruit cup snack manufacturer’s use of the phrase “fruit naturals®” was misleading to a reasonable consumer because it led consumers to believe the fruit cups lack synthetic ingredients. In rejecting the consumer’s claim, the court first established that the front label is unambiguous due to (1) the presence of a registered trademark symbol in the allegedly deceptive phrase that suggests the phrase is “just the name of the product”; and (2) the presence of imagery on the front label and the added phrase “in extra light syrup,” which implies that while “the fruit itself is natural, the syrup may not be.” The court also rejected survey evidence offered by the plaintiff, which it found “uninformative” because it asked what respondents “thought ‘natural’ should mean” rather than “what they thought it actually did mean as used on these labels.”From there, the court relied on well-established Ninth Circuit law holding that an ambiguous label permits a court to consider both the front and back of the packaging when determining if a label is deceptive. The back label, the court noted, peels back the truth by “accurately and clearly disclos[ing] several synthetic ingredients.” Armed with this clarifying information, the court held that the consumer’s complaint fails as a matter of law. Licorice Lover Receives Not-SoSweet Motion to Dismiss Trammell v. KLN Enterprises Inc., No. 3:23-cv-01884 (S.D. Cal. Sept. 12, 2024). A California plaintiff has reached the end of his (sweet, red) rope. The plaintiff accused a defendant food manufacturer of misleading licorice consumers by labeling its stringy treat with the claims “Natural Strawberry & Raspberry Flavored Licorice,”“Naturally Flavored,” and “Free of … Artificial Colors & Flavors” when the licorice contains malic acid. The first amended complaint alleged that malic acid was used as a flavoring in the products and that independent testing determined that the malic acid used was artificial. The court granted the defendant’s motion to dismiss without leave to amend, determining that the plaintiff failed to meet Rule 9(b)’s heightened pleading requirements despite the allegation of independent test results. Asserting that the licorice candy contained DL-malic acid wasn’t enough to allege with sufficient particularity what is false or misleading about the presence of malic acid in a candy product that is not labeled “all natural,” “100% natural,” or “free of artificial ingredients.” The plaintiff’s reasonable consumer arguments were also twisted—the court found that nothing about this “brightly colored, shelf-stable licorice candy” would make a reasonable consumer believe that the product did not contain artificial ingredients.
5 Case Decisions Court Corrects Conclusion About “Carbon-Neutral” Claims Dorris v. Danone Waters of America, No. 7:22-cv-08717 (S.D.N.Y. Nov. 14, 2024). There was nothing neutral about a recent S.D.N.Y. opinion dismissing the balance of the plaintiffs’ claims of greenwashing against a bottled water manufacturer, which readers might recall related to representations that the products were “carbon neutral.” Last year, the court denied in part the defendant’s motion to dismiss, holding that the phrase “carbon neutral” was an ambiguous term that could plausibly mislead a reasonable consumer into thinking that the products were “carbon zero” or “carbon free.” After a second look, however, the court held that Massachusetts and California case law demanded a different result, and that without a fixed and widely understood meaning of “carbon neutral,” precedent required it to conclude that a reasonable consumer would be expected to investigate that phrase’s meaning, including by looking to the product’s back label for more information. The court also washed away any notion that a reasonable consumer would consider the product, which was packaged and transported from Europe, to be “carbon zero.”Although the court granted the plaintiffs leave to amend their complaint by December 13, they failed to do so, suggesting that this lawsuit might be deep underwater. What’s in Your Granola? Hicken v. The Quaker Oats Co., No. 1:22-cv-06043 (N.D. Ill. Dec. 2, 2024). An Illinois federal court poured out claims that a consumer was misled by front-of-pack imagery and label claims on a popular breakfast brand’s boxed granola product. The plaintiff alleged that the label on granola boxes was deceptive and misleading because consumers expect— based on the front label’s use of the word “simply” before the word“granola”and the succeeding words“oats, honey, raisins & almonds”—that the product will contain only those frontof-pack-identified ingredients. According to the complaint, had the consumer known the product actually contained additional ingredients, she would not have purchased it or would have paid less for it. Ordering up a serving of common sense, the court rejected that argument as “unreasonable and fanciful” and explained that “using the word ‘simply’ to describe the granola does not mean, when viewed from the perspective of a reasonable consumer, that the ingredients would be limited to that front-of-the package list.” Spoon feeding its reasoning to the plaintiff, the court explained that images on the front of packaging would be extremely crowded if reasonable consumers expected to see every single ingredient featured in the product, including those that are not even visible. Critical to the court’s decision was the fact that the plaintiff did not challenge that the granola product actually contained the four featured ingredients, making the ingredient list consistent with the front label and the product labeling incapable of misleading a reasonable consumer.
6 Case Decisions Mac-and-Cheese Blues Hayes v. Kraft Heinz, No. 1:23-cv-16596 (N.D. Ill. Nov. 13, 2024). A Northern District of Illinois judge allowed a proposed class action to proceed against the “No Artificial Flavors, Preservatives or Dyes” claim on Kraft Mac & Cheese products due to the alleged presence of artificial citric acid and sodium phosphates. In pursuing dismissal, the defendant argued that the plaintiffs did not plausibly allege that the ingredients are artificial and that even if they had, the plaintiffs did not plausibly allege that the ingredients function as preservatives. The court rejected both arguments, finding dismissal on either basis to be inappropriate. The court contrasted its prior holding in Tarzian v. Kraft Heinz Food Co., finding that unlike there, the plaintiff in this case provided sufficient factual support to plausibly allege the product contains artificial citric acid. The court explained that the plaintiff’s allegations were sufficient to establish a connection between the industry practice of using artificial citric acid and the defendant’s practices here. As with citric acid, the court found that the plaintiffs plausibly alleged that the sodium phosphates were artificial by describing the process by which sodium phosphates are synthesized, overcoming the defendant’s argument that sodium phosphates can occur naturally in nature. The judge also rejected the defendant’s argument that the plaintiffs failed to adequately allege that the ingredients acted as preservatives in the macaroni and cheese products, pointing to scholarly articles and FDA guidance the plaintiff cited that described citric acid as a preservative.
7 New Complaints Cracker Consumers Crackdown on Cornstarch Blanco v. Mondelēz International Inc., No. 1:24-cv-13193 (N.D. Ill. Dec. 23, 2024). Bringing a host of consumer protection claims on behalf of a multistate class, or alternatively Illinois and Florida state subclasses, two cracker consumers allege they were deceived by a snack product’s representation that it’s “100% whole grain.” Instead, the plaintiffs contend the inclusion of cornstarch in the snack makes the product less than “100% whole grain” because they claim cornstarch qualifies as a “refined grain.” The plaintiffs argue the “100% whole grain” representation is included in several places on the product packaging and is a “pillar” of the product’s brand. As a result, the plaintiffs state that the grain advertisements misled them and caused them to pay a premium for the product that they otherwise would not have had they known the true grain makeup of the product. Does this case ring a bell? We previously wrote about a suit in the Northern District of California making the same allegations against the snack’s manufacturer. The Illinois plaintiffs were likely watching that docket closely because just three months before they filed this complaint, the Northen District of California certified a class of California purchasers. Acid Redux: Another “No Preservative” Citric Acid Case Rodriguez v. Sazerac Co., No. 2:24-cv-08206 (E.D.N.Y. Nov. 26, 2024). Someone cue DJ Khaled, because we’ve got another one. Another case claiming a product’s “No Preservatives” claim is false because it contains citric acid, that is. We’ve seen the plaintiffs’ bar go after Emeril pasta sauces, Ocean Spray cranberry juices, Pepperidge Farm Goldfish, Mr. & Mrs. T Original Bloody Mary mix, and a host of other products. Here, the target is Sazerac’s “Stirrings” line of cocktail mixes, and— stop me if you’ve heard this before—the plaintiff claims that the product’s “No Preservatives” representation is false and misleading because citric acid functions as a preservative regardless of the defendant’s subjective purpose or intent in adding citric acid to the product, including as a flavoring agent. The continued trend of citric acid litigation should come as no surprise, given the relative success plaintiffs have had defeating motions to dismiss. Courts have typically found that the issue of whether a certain ingredient (citric acid) functions in a certain way (as a flavor enhancer or a preservative) is not properly resolved on a motion to dismiss. But as a recent S.D.N.Y. decision reminds us, plaintiffs who have advanced past the pleadings stage may have won a battle, but they have not won the war. In Kelly v. Beliv LLC, No. 1:21-cv-08134 (S.D.N.Y. Mar. 12, 2024), the court granted summary judgment in the defendant’s favor after finding that the plaintiff failed to proffer evidence that the product he received was anything less than what he contended he was promised. The defendant provided unrebutted evidence that the product did not
8 New Complaints need preservatives because of the pasteurization process it underwent and that the citric acid was used only as an acidulant to increase palatability or taste. That meant the plaintiff received precisely what was advertised: a product containing no preservatives. So just like in investing, past performance (in surviving a motion to dismiss) is not a guarantee of future success. Empty Space in My Cracker Box? Fuhgeddaboudit Chico v. Blue Diamond Growers, No. 817619/2024E (N.Y. Sup. Ct. Nov. 2, 2024). A Bronx plaintiff has hopped on the slack-fill bandwagon— or more accurately, the D Train to 161st Street. In the latest Spencer Sheehan special, served up hotter than a bodega chopped cheese on Grand Concourse, a putative class representative takes aim at Almond Nut-Thins crackers, alleging that their packaging is about 75% thin air. And although that air might serve to protect the crackers from becoming crumbs, the plaintiff cites numerous customers who were crushed to find their crackers broken to bits anyway. The plaintiff therefore alleges that there was no justification for the empty space and that customers were indefensibly deceived into thinking they were purchasing more crackers than they actually did, in violation of New York’s General Business Law. Tussle over Toddler Formula Schavrien v. Abbott Laboratories, No. 3:24-cv-09452 (N.D. Cal. Dec. 26, 2024). Sneaking in the door between Christmas and New Year’s was a new variation on an old argument—formula is chockfull of additives and lacking in nutrition. In the past, we’ve seen this claim with baby formula. Now, formula for older children is toddling into the fray. Two California consumers allege that the defendant, a leading formula manufacturer, is misleading consumers by marketing “toddler milk” as a healthy addition to the diets of children ages 1–2. According to the complaint, the manufacturer is using terms such as “grow” and “gain” along with representations about “nutrition” to entice its customers into buying more toddler formula, but the customers did not know that the toddler milk was high in sugar and other carbohydrates. The plaintiffs contend that this so-called sugary substitute should not be marketed as a healthy supplement to their kiddos’ diets. They bring California state-law claims for false advertising and consumer protection violations, as well as for purported breach of warranty and unjust enrichment. They request both a permanent injunction and monetary relief and seek to represent both a nationwide class of consumers and a subclass of California consumers who purchased the product within the past four years. New Year, New … Oh Wait! Malic Acid Mania Continues Venezia v. Aldi Inc., No. 502081/2024 (N.Y. Sup. Ct. Nov. 26, 2024). Dominguez v. Aldi Inc., No. 817773/2024E (N.Y. Sup. Ct. Nov. 6, 2024). It’s 2025, folks, but if you’d like to take a trip down memory lane, look no further than Spencer Sheehan’s continued attempt to attack the use of malic acid. Like the citric acid redux, malic acid cases are not going away anytime soon, and Sheehan is again contending that advertising products as containing “natural flavoring” is false when the products contain malic acid. This time, Sheehan represents two New
9 New Complaints York consumers in parallel suits, each alleging that they would not have purchased the product—each a variation on a granola bar—had they known that the bars contained synthetic DL-malic acid. According to the complaints, and in line with claims Sheehan’s plaintiffs have previously made, the granola bars are marketed as “naturally flavored” with “no artificial flavors,” leading the plaintiffs to believe that the granola bars did not contain any synthetic ingredients. This time around, Sheehan’s plaintiffs direct their claims at a new defendant—a major grocer that purportedly sells the granola bars through its private-label store brand. The plaintiffs allege that they purchased this “private label product” because it was believed to be of high quality, and they contend they would not have paid the same price had they known the granola bars contained unnatural or unhealthy ingredients. Each plaintiff seeks to bring claims on behalf of New York consumers who purchased the product within the requisite statute of limitations. While one plaintiff brings a single claim for violations of New York General Business Law Sections 349 and 350, the other adds a claim in the alternative for purported violation of Connecticut’s consumer protection statute. Making a Great Pear! Gillus v. Arizona Beverages USA LLC, No. 530971/2024 (N.Y. Sup. Ct. Nov. 15, 2024). A juice-loving consumer looks to put the squeeze on a popular beverage manufacturer in a putative class action targeting a “fruit juice cocktail” purportedly prepared with kiwi and strawberry juices. Despite the packaging’s representations and imagery of kiwis and strawberries, the plaintiff claims the product is misbranded and misleading because it is predominantly flavored with pear juice, not the more expensive kiwi and strawberry juices. The plaintiff also takes issue with the “fruit juice cocktail” labeling statement, claiming it is ambiguous and does not adequately disclose the type of juices in the product. The complaint also claims the product is not as“all natural”as it purports to be. To pump up that claim, the plaintiff points to the ingredients panel, which lists a number of allegedly non-natural ingredients, including high fructose corn syrup, citric acid, and ester gum. Based on these allegations, the plaintiff claims he would not have paid as much for the product as he did had the true nature of the product been disclosed. The plaintiff seeks to represent a New York class of purchasers with claims that include violations of New York’s General Business Law. Plaintiff Cries over Labeling Claims on Food Allegedly for Babies Pflaumer vs. Hain Celestial Group Inc., No. 3:24-cv-07838 (N.D. Cal. Nov. 8, 2024). A California consumer filed a class action alleging that the defendant’s labeling of certain food products that are allegedly intended for consumption by babies and toddlers include nutrient content claims in violation of regulatory requirements. The plaintiff cites the defendant’s advertising and marketing, including using Sesame Street characters on the product labels and elsewhere; using hashtags such as #babyfood, #baby, and #toddler on social media; and placing the products in the“baby food”aisle at the grocery store (and the “baby food” section of grocery websites), as evidence that the products are intended for consumption by children
10 New Complaints oranges or yellow peaches are packed in “100% Fruit Juice.” Through multiple complaints with similar allegations filed in state courts across New York, the Sheehan-represented plaintiffs allege the fruit-cup fillers actually contain additives like water, concentrates, and preservatives, not “100% Fruit Juice.” In each suit, the plaintiffs claim violations of New York’s General Business Law and seek to represent a class of similarly situated New York consumers. Will Cage-Free Egg Claims Crack Under the Pressure of Class Action Litigation? Reimer v. Eggland’s Best Inc., No. 1:24-cv-11311 (N.D. Ill. Nov. 1, 2024). A concerned Illinois plaintiff is pecking a fight with a nationwide producer of cage-free eggs. The plaintiff alleges that label claims stating that every hen is in a “happy,” “pleasant,” and “natural” environment are false and misleading because the hens are kept tightly packed in enclosed warehouses with little natural light or ability to roam. The complaint leverages aerial footage of facilities and social media posts from suppliers to inform its allegations, claiming discovery is necessary to obtain direct evidence due to the difficulty of accessing egg production facilities. The plaintiff asserts two causes of action for violations of Illinois’s consumer protection laws and seeks to certify a class of similarly eggreived Illinois consumers. under the age of two. These products are not permitted to bear nutrient content claims on the product labels. The allegedly impermissible nutrient content claims cited include a claim about the number of grams of protein in a puree pouch and a claim that cookie products are an “excellent source” of specified vitamins and minerals. The complaint alleges that these and other similar claims “deceive reasonable consumers into believing Defendant’s products are a healthful and appropriate source of nutrients for their children under the age of two,” but the products are actually “ultra-processed foods that lack health value.” The plaintiff cites, among other factors, the allegedly high sugar and salt content of the products as evidence that they are harmful to children and contends that using a disclaimer indicating that the products are intended for “ages 2 and up” on the back of the product labels “does not negate the fact that the Products are intended specifically for children under two.” Based on those facts, the plaintiff alleges that these “Products are unlawful, misbranded, and violate the Sherman Law.” A Juicy Ending to 2024 Triesch v. Topco Associates LLC, Unassigned (NY Sup. Ct. Nov. 20, 2024). Michel v. Lidl US LLC, No. 725974/2024 (NY Sup. Ct. Dec. 2, 2024). Nimmons v. Weis Markets Inc., No. EFCA2024003516 (NY Sup. Ct. Dec. 12, 2024). Rounding out a very busy 2024, Spencer Sheehan found a bushel of plaintiffs to take aim at various companies for allegedly misleading consumers through advertising that their individually packaged fruit cups containing mandarin
11 New Complaints Emergen-See You in Court Campos v. Alacer Corp., No. 4:24-cv-08057 (N.D.Cal. Nov. 16, 2024). Just in time for flu season, a class action complaint filed in the Northern District of California alleges that the makers of Emergen-C Vitamin C gummies misrepresented the amount of Vitamin C in their products. The plaintiff is sick over the fact that the defendants’ products contain less Vitamin C than advertised due to alleged degradation that occurs when the gummies are exposed to light, oxygen, and humidity. According to the plaintiff, the gummies’ transparent packaging contributes to this deficien-C. One study cited by the plaintiff found a new bottle of 750 mg Emergen-C gummies contained only 409 mg per serving. The plaintiff alleges fraud, unjust enrichment, and violations of California consumer protection laws and seeks to certify a nationwide class of individuals who purchased the gummies between November 2020 and the present. The complaint seeks damages, restitution, injunctive relief, and declaratory relief for the plaintiff and the proposed class of purchasers. ImPEACHing Claims of Natural Flavors Fogelson v. Snapple Beverage Corp., No. 1:25-cv-00033 (E.D.N.Y. Jan. 02, 2025). Spencer Sheehan, a mainstay of the plaintiffs’ labeling litigation bar (and this digest), has a peach to pick with a defendant’s popular fruit tea. The complaint, filed in New York state court, was recently removed to the Eastern District of New York and alleges that the defendant’s “Peach Tea” product is misleadingly labeled. The plaintiff is pitting himself against the defendant’s claim that its tea is “Naturally Flavored” when it contains DL-malic acid, an artificial flavor derived from petroleum, instead of natural L-malic acid, which is found in peaches. The complaint argues that this misrepresentation violates consumer protection laws, including New York’s General Business Law and the Federal Food, Drug, and Cosmetic Act, by misleading consumers into believing the product’s peachy flavor is derived from natural sources. The plaintiff seeks damages for economic injury, claiming the product was sold at a premium due to its misleading labeling. The complaint also seeks class certification for all New York consumers who purchased the product. Protein Bar Purchases Leave Plaintiff Feeling Salty Esoubiza v. Redcon1 LLC, No. 24STCV31598 (Cal. Super. Ct. Dec. 2, 2024). Instead of targeting the protein-packed labeling claims, a California consumer alleges a manufacturer is serving up a half-baked truth about the amount of salt in its protein bars. The plaintiff alleges that the salt content displayed on the nutrition information labeling for the product does not match the actual salt content of the product, which is far higher than declared on the product labels, rendering the product misbranded. The plaintiff relies on testing conducted at the direction of his attorney to support these allegations. Based on the misleading representations, the plaintiff asserts claims for violation of California consumer protection statutes on behalf of a proposed California class of consumers. We’ll keep you updated as this case continues to bake.
12 Petits Fours Presentations Angela Spivey will speak on the panel “On the Docket: The CPG Litigation Horizon,” and Sam Jockel will speak on the panel “What’s Coming Next Under a Trump Administration’s FDA and USDA” at the CPG Legal Forum, February 26–28. Kristi Boswell spoke on the panel “Perspectives on Labor Issues from Grower Groups” at the American Farm Bureau Convention, January 24–29. Publications & Media Sam Jockel was quoted by Packaging Dive in the article “What Packaging Designers Should Know About FDA’s Proposed Nutrition Info Box.” (January 15) Sam Jockel, Kristi Boswell, and Evan Collier wrote the Food & Beverage advisory “Updates to the Dietary Guidelines? HHS and USDA Request Public Input.” (January 10) Kristi Boswell appeared on the NPR Here & Now segment “Farmers and Their Workers Are Concerned About Mass Deportations.” (January 9) Angela Spivey, Sam Jockel, and Karly Bader wrote the Food & Beverage advisory “FDA’s Final Rule for ‘Healthy’ Claim Requirements: What Industry Should Know.” (January 2) Sam Jockel was quoted by Packaging Dive in the article “Trump’s FDA Poised to Make Mark on Food Packaging Regulation.” (December 4) Greg Berlin and Sam Burdick wrote the Environment, Land Use & Natural Resources advisory “Addition of Bisphenol S (BPS) to Proposition 65 List Has Sweeping Implications for Industry.” (November 22)
13 Contributing Authors Angela Spivey +1 404 881 7857 angela.spivey@alston.com Samantha Burdick +1 213 576 1190 sam.burdick@alston.com Rachel Lowe +1 213 576 2519 rachel.lowe@alston.com Amanda Newton Wellen +1 404 881 4809 amanda.wellen@alston.com Alan Pryor +1 404 881 7852 alan.pryor@alston.com Taylor Lin +1 404 881 7491 taylor.lin@alston.com Andrew Phillips +1 404 881 7183 andrew.phillips@alston.com Jonathan Hermann +1 404 881 7275 jon.hermann@alston.com Samuel Jockel +1 202 239 3037 sam.jockel@alston.com Sheena Hilton +1 404 881 7763 sheena.hilton@alston.com Troy Stram +1 404 881 7256 troy.stram@alston.com Jamie George +1 404 881 4951 jamie.george@alston.com
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