Settlement Date:
06/20/2025
Case Name:
Environmental Research Center vs. G.O.A.T. Fuel, Inc.
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Gonzalez Law Group, A.P.C.
Defendant:
G.O.A.T. Fuel, Inc.
G.O.A.T. Fuel LLC
Injunctive Relief:
Beginning on the Compliance Date, G.O.A.T. Fuel 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
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 Covered Product and/or Mercury
Covered Product meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 25,000.00
Attorney(s) Fees and Costs:
$ 44,010.00
Payment in Lieu of Penalty:
$ 18,490.00 (Amounts Rounded: Actual Amounts: $25,000.00, Fees and Costs: $44,010.05, and ASP $18,489.95. $18,489.95 shall be distributed to ERC as an Additional Settlement Payment
(“ASP”), which shall be subject to the Court’s ongoing judicial oversight pursuant to
California Code of Regulations, title 11, section 3204. ERC will utilize the ASP for activities
that address the same public harm as allegedly caused by Defendants in this matter. These
activities are detailed below and support ERC’s overarching goal of reducing and/or
eliminating hazardous and toxic chemicals in dietary supplement products in California. ERC’s
activities have had, and will continue to have, a direct and primary effect within the State of
California because California consumers will be benefitted by the reduction and/or elimination
of exposure to lead and/or mercury in dietary supplements and/or by providing clear and
reasonable warnings to California consumers prior to ingestion of the products.
Based on a review of past years’ actual budgets, ERC is providing the following list of
activities ERC engages in to protect California consumers through Proposition 65 citizen
enforcement, along with a breakdown of how ASP funds will be utilized to facilitate those
activities: (1) ENFORCEMENT (up to 65-80%): obtaining, shipping, analyzing, and testing
dietary supplement products that may contain lead and/or mercury and are sold to California
consumers. This work includes continued monitoring and enforcement of past consent
judgments and settlements to ensure companies are in compliance with their obligations
thereunder, with a specific focus on those judgments and settlements concerning lead and/or
mercury. This work also includes investigation of new companies that ERC does not obtain any recovery through settlement or judgment; (2) VOLUNTARY COMPLIANCE PROGRAM (up to 10-20%): maintaining ERC’s Voluntary Compliance Program by acquiring products
from companies, developing and maintaining a case file, testing products from these
companies, providing the test results and supporting documentation to the companies, and
offering guidance in warning or implementing a self-testing program for lead and/or mercury
in dietary supplement products; and (3) “GOT LEAD” PROGRAM (up to 5%): maintaining
ERC’s “Got Lead?” Program which reduces the numbers of contaminated products that reach
California consumers by providing access to free testing for lead in dietary supplement
products (Products submitted to the program are screened for ingredients which are suspected
to be contaminated, and then may be purchased by ERC, catalogued, sent to a qualified
laboratory for testing, and the results shared with the consumer that submitted the product).
ERC shall be fully accountable in that it will maintain adequate records to document
and will be able to demonstrate how the ASP funds will be spent and can assure that the funds
are being spent only for the proper, designated purposes described in this Consent Judgment.
ERC shall provide the Attorney General, within thirty days of any request, copies of
documentation demonstrating how such funds have been spent.)
Total Payments:
$ 87,500.00
Will settlement be submitted to court?
Contact Organization:
Gonzalez Law Group, A.P.C.
Address:
2625 Townsgate Rd, Ste 330
City, State, Zip:
Westlake Village, CA 91361
Phone Number:
(805) 576-7776