60 Day Notice 2025-04765

Withdraw Notice Add a Complaint Add a Settlement Add a Judgment

AG Number: 
2025-04765
Notice PDF: 
PDF icon 2025-04765.pdf
Date Filed: 
11/21/2025
Noticing Party: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Environmental Research Center
Alleged Violators: 
Formulation Factory LLC
Chemicals: 
Lead and lead compounds
Source: 
Formulation Factory Crown of Glory 10-in-1 Follicle Maximizer
Formulation Factory Self Obsessed 10-in-1 Masculinity Maximizer
Formulation Factory She's Obsessed 10-in-1 Balance Maximizer
Formulation Factory Boss Mode 10-in-1 Mind Maximizer

60-Day Notice Document

Settlement
AG Number:
2025-04765
Settlement PDF: 
PDF icon 2025-04765S7601.pdf
Settlement Date:
05/05/2026
Case Name: 
Environmental Research Center, Inc. vs. Formulation Factory
Court Name: 
Out of Court Settlement
Court Docket Number: 
N/A
Plaintiff: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Environmental Research Center
Defendant: 
Formulation Factory LLC
Injunctive Relief: 
Beginning on the Effective Date, Formulation Factory 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 which exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of lead per day unless such Covered Product meets the warning requirements under Section 3.2 (using the test method specified herein). Covered Products already in the “Stream of Commerce” (as defined below) on the Effective Date are expressly subject to the release set forth in Paragraph 6.2. For purposes of this Agreement, the term “Stream of Commerce” means that the Covered Products have been manufactured and labeled for sale and are no longer in the possession of or under the control of Formulation Factory.
*Non-Contingent Civil Penalty:
$ 19,000.00
Attorney(s) Fees and Costs:
$ 26,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 45,000.00
Will settlement be submitted to court?
No
Contact Name: 
Charles Poss
Contact Organization: 
Environmental Research Center
Email Address:
myra.heptinstall@erc501c3.org
Address: 
3111 Camino Del Rio North, Ste 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.