Noticing Party:
Environmental Research Center, Inc.
Plaintiff Attorney:
Aqua Terra Aeris Law Group
Alleged Violators:
Chameleon Cold Brew, LLC
Groundforce Capital Management, LLC, individually and dba PowerPlant Partners
SYSTM Brands LLC, individually and dba SYSTM Foods, Inc.
Chemicals:
Lead and lead compounds
Mercury and mercury compounds
60-Day Notice Document
Supplemental Complaint
Case Name:
Environmental Research Center vs. Chameleon Cold Brew LLC
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Aqua Terra Aeris Law Group
Defendant:
Chameleon Cold Brew, LLC
Groundforce Capital Management, LLC, individually and dba Powerplant Partners
Systm Brands LLC, individually and dba Systm Foods, Inc.
Relief Sought:
Warning
Civil Penalty
Injunctive and Declaratory Relief
Contact Organization:
Aqua Terra Aeris Law Group
Civil Complaint
Case Name:
Environmental Research Center, Inc. v Chameleon Cold Brew
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Aqua Terra Aeris Law Group
Defendant:
Chameleon Cold Brew, LLC
Groundforce Capital Management, LLC, individually and d.b.a. PowerPlant Partners
Systm Brands LLC, individually and d.b.a. Systm Foods, Inc.
Contact Organization:
Aqua Terra Aeris Law Group
Address:
4030 Martin Luther King Jr. Way
Settlement
Settlement Date:
05/14/2025
Case Name:
Environmental Research Center vs. Chameleon Cold Brew LLC
Court Name:
Alameda County Superior Court
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Aqua Terra Aeris Law Group
Defendant:
Chameleon Cold Brew, LLC
Groundforce Capital Management, LLC, individually and dba Powerplant Partners
Systm Brands LLC, individually and dba Systm Foods, Inc.
Injunctive Relief:
Beginning on the Effective Date, Chameleon Cold Brew 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 Lead Covered Product that
exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of lead per
day and/or any Mercury Covered Product that exposes a person to a “Daily Mercury Exposure
Level” of more than 0.3 micrograms of mercury per day unless the Lead Covered Product
and/or Mercury Covered Product meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 7,500.00
Attorney(s) Fees and Costs:
$ 67,500.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 75,000.00
Will settlement be submitted to court?
Contact Organization:
Aqua Terra Aeris Law Group
City, State, Zip:
Oakland, CA 94611
Phone Number:
(416) 568-5200
* 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.
