3.1.     Plaintiffs bring the claims alleged herein as a class action, pursuant to Tex.R.Civ.P. 42, on behalf of themselves and all other similarly situated consumers of Defendants’ products residing in Texas. The class will consist of Texas residents who purchased and used Warner-Lambert Consumer Healthcare’s N.K.A. Pfizer, Inc.’s. “NIX Lice Treatment,” Bayer Corporation’s “RID Lice Killing Shampoo,” Del Pharmaceutical, Inc.’s and Del Laboratories, Inc.’s “Pronto Lice Treatment,” and Care Technologies, Inc.’s “Clear Lice Egg Remover” or “Clear Lice Killing Shampoo”, and received no effective benefit from the use of such products.

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