Noticing Party:
Environmental Research Center, Inc.
Chemicals:
Lead and lead compounds
Mercury and mercury compounds
60-Day Notice Document
Supplemental Complaint
Case Name:
Environmental Research Center, Inc. vs. Kize Concepts, Inc.
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Kize Concepts, Inc.
Kize Concepts, LLC
Relief Sought:
Warning
Civil Penalty
Injunctive and Declaratory Relief
Address:
25361 Commercentre Drive, Ste 150
Civil Complaint
Case Name:
Environmental Research Center, Inc. v. Kize Concepts, Inc.
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Relief Sought:
Warning
Civil Penalty
Injunctive and Declaratory Relief
Address:
25361 Commercentre Drive, Ste 150
Settlement
Settlement Date:
03/08/2024
Case Name:
Environmental Research Center, Inc. v. Kize Concepts, Inc.
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Kize Concepts, Inc.
Kize Concepts, LLC
Injunctive Relief:
Beginning on the Effective Date, Kize 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 Covered Product that exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of lead per day and/or “Daily Mercury Exposure Level” of more than 0.3 micrograms of mercury per day unless it meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 10,000.00
Attorney(s) Fees and Costs:
$ 55,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 65,000.00
Will settlement be submitted to court?
Address:
25361 Commercentre Drive, Ste 150
City, State, Zip:
Lake Forest, CA 92630
Phone Number:
(949) 452-1234
Judgment
Judgment Date:
07/08/2024
Settlement reported to AG:
Case Name:
Environmental Research Center, Inc. vs. Kize Concepts, Inc.
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Defendant:
Kize Concepts, Inc.
Kize Concepts, LLC
Injunctive Relief:
Beginning on the Effective Date, Kize 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 Covered Product that
exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of
lead per day and/or “Daily Mercury Exposure Level” of more than 0.3 micrograms of
mercury per day unless it meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 10,000.00
Attorney(s) Fees and Costs:
$ 55,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 65,000.00
Is Judgment Pursuant to Settlement?
Address:
25361 Commercentre Drive, Ste 150
City, State, Zip:
Lake Forest, CA 92630
Phone Number:
(949) 452-1234
* 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.
