12.1     The preceding factual statements and allegations are incorporated herein by reference.

12.2     Plaintiffs further allege that Defendants made false representations of material fact concerning the efficacy of their products, intending for Plaintiffs to act upon said representations. Plaintiffs, believing Defendants' the representations to be true, acted to their detriment in reliance upon said representations. Defendants' fraudulent acts were a producing cause, or in the alternative, a proximate cause of the damages sustained by Plaintiffs.