Noticing Party:
Environmental Research Center, Inc.
Plaintiff Attorney:
Environmental Research Center
Alleged Violators:
Simple Health LLC, individually and dba Tosi
60-Day Notice Document
Civil Complaint
Case Name:
Environmental Research Center, Inc. v. Simple Health, et al.
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Simple Health LLC, individually and dba Tosi
Contact Organization:
Environmental Research Center, Inc.
Address:
3111 Camino Del Rio North, 400
Settlement
Settlement Date:
12/15/2023
Case Name:
Environmental Research Center, Inc. v. Simple Health LLC
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Simple Health LLC, individually and dba Tosi
Injunctive Relief:
3.1 Beginning on the Effective Date, Simple Health 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 (collectively referred to as “California
Sales Practices”), any Covered Product that exposes a person to a “Daily Lead Exposure
Level” of more than 0.5 micrograms of lead per day unless it meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 100.00
Attorney(s) Fees and Costs:
$ 400.00
Payment in Lieu of Penalty:
$ 0.00
Will settlement be submitted to court?
Contact Organization:
Environmental Research Center
Address:
3111 Camino Del Rio North, Suite 400
City, State, Zip:
San Diego, CA 92108
Phone Number:
(619) 500-3090
Judgment
Judgment Date:
03/19/2024
Settlement reported to AG:
Case Name:
Environmental Research Center, Inc. v. Simple Health LLC
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Simple Health LLC, individually and dba Tosi
Injunctive Relief:
3.1 Beginning on the Effective Date, Simple Health 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 (collectively referred to as
“California Sales Practices”), any Covered Product that exposes a person to a “Daily
Lead Exposure Level” of more than 0.5 micrograms of lead per day unless it meets
the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 100.00
Attorney(s) Fees and Costs:
$ 400.00
Payment in Lieu of Penalty:
$ 0.00
Is Judgment Pursuant to Settlement?
Contact Organization:
Environmental Research Center
Address:
3111 Camino Del Rio North, Suite 400
City, State, Zip:
San Diego, CA 92108
Phone Number:
(619) 500-3090
* 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.