Noticing Party:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Alleged Violators:
Rawnature5 Corporation, individually and dba Koia
Chemicals:
Perfluorooctanoic Acid (PFOA)
60-Day Notice Document
Supplemental Complaint
Case Name:
Environmental Research Center vs. Rawnature5 Corporation
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Defendant:
Rawnature5 Corporation, individually and dba Koia
Relief Sought:
Warning
Civil Penalty
Injunctive and Declaratory Relief
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
Supplemental Complaint
Case Name:
Environmental Research Center, Inc. vs. RawNature5
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Defendant:
RawNature5 Corporation, dba KOIA
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
Corrected Settlement
Settlement Date:
12/15/2025
Case Name:
Environmental Research Center vs. Rawnature5 Corporation
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Defendant:
Rawnature5 Corporation, individually and dba Koia
Injunctive Relief:
Beginning 45 days after the Effective Date (“Compliance Date”), Koia shall be
permanently enjoined from manufacturing for sale in the State of California, “Distributing into
the State of California,” or directly selling in the State of California, any Mercury Covered
Product that exposes a person to a “Daily Mercury Exposure Level” of more than 0.3
micrograms of mercury per day and/or any PFOA Covered Product that exposes a person to a
quantifiable level of PFOA that can be reliably achieved using industry standard methods for
testing in the PFOA Covered Products, unless such Covered Product meets the warning
requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 22,500.00
Attorney(s) Fees and Costs:
$ 127,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 150,000.00
Will settlement be submitted to court?
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
City, State, Zip:
Berkeley, CA 94704
Phone Number:
(510) 499-1992
Settlement
Settlement Date:
05/22/2025
Case Name:
Environmental Research Center vs. Rawnature5 Corporation
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Defendant:
Rawnature5 Corporation, individually and dba Koia
Injunctive Relief:
Beginning 45 days after the Effective Date (“Compliance Date”), Koia shall be
permanently enjoined from manufacturing for sale in the State of California, “Distributing into
the State of California,” or directly selling in the State of California, any Mercury Covered
Product that exposes a person to a “Daily Mercury Exposure Level” of more than 0.3
micrograms of mercury per day and/or any PFOA Covered Product that exposes a person to a
reportable level of PFOA that can be reliably achieved using industry standard methods for
testing in the PFOA Covered Products, unless such Covered Product meets the warning
requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 22,500.00
Attorney(s) Fees and Costs:
$ 127,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 150,000.00
Will settlement be submitted to court?
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
City, State, Zip:
Berkeley, CA 94704
Phone Number:
(510) 499-1992
Judgment
Judgment Date:
02/02/2026
Settlement reported to AG:
Case Name:
Environmental Research Center vs. Rawnature5 Corporation
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Defendant:
Rawnature5 Corporation, individually and dba Koia
Injunctive Relief:
Beginning 45 days after the Effective Date (“Compliance Date”), Koia shall be
permanently enjoined from manufacturing for sale in the State of California,
“Distributing into the State of California,” or directly selling in the State of
California, any Mercury Covered Product that exposes a person to a “Daily
Mercury Exposure Level” of more than 0.3 micrograms of mercury per day
and/or any PFOA Covered Product that exposes a person to a quantifiable
level of PFOA that can be reliably achieved using industry standard methods
for testing in the PFOA Covered Products, unless such Covered Product
meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 22,500.00
Attorney(s) Fees and Costs:
$ 127,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 150,000.00
Is Judgment Pursuant to Settlement?
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
City, State, Zip:
Berkeley, CA 94704
Phone Number:
(510) 499-1992
* A non-contingent civil penalty is the civil penalty that must be paid pursuant to the settlement, regardless of future events or actions of the defendant. If a settlement includes a contingent penalty, the plaintiff should report the additional penalty amount when it becomes due.