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

13.2     In the alternative, Plaintiffs assert that the aforementioned conduct of Defendants constitutes negligent misrepresentation. Defendants represented to the public that their products possessed certain characteristics and benefits. Said representations involved material facts concerning the characteristics and benefits of Defendants' products, which Defendants knew or should have known to be inaccurate or untrue. Plaintiffs relied upon said representations. Defendants' misrepresentations were a producing cause, or in the alternative, a proximate cause of the damages sustained by Plaintiffs.