6.1     Plaintiffs are consumers of Defendants' products who, in reliance upon Defendants' false and deceptive claims, marketing and advertising purchased and used Defendants' products for Plaintiffs' personal consumption or for their family members to cure lice infestation. Defendants' products failed to cure Plaintiffs' lice infestations.

7.1     Defendant Warner-Lambert Consumer Healthcare N.K.A. Pfizer, Inc. which manufactures, markets and sells “NIX Lice Treatment” and Defendant Bayer Corporation which manufactures, markets and sells “RID Lice Killing Shampoo” Defendant Del Pharmaceutical, Inc. and Defendant Del Laboratories, Inc. which manufactures, markets and sells “Pronto Lice Treatment,” and Defendant Care Technologies, Inc. which manufactures, markets and sells “Clear Lice Egg Remover” or “Clear Lice Killing Shampoo, made one or more of the following false, deceptive and unsubstantiated claims that: (1) their lice killing shampoos cure lice infestation in a single treatment; and (2) their lice killing product effectively cures lice infestation and lice eggs.

  8.1     Facts similar to those set forth in the above paragraphs apply to misconduct of Defendants toward all individuals who are members of this class, thereby entitling them to share in the relief sought by Plaintiffs in this action.

8.2     All of the class members have suffered or continue to suffer economic loss because of Defendants' product failure.