60 Day Notice 2026-02451

AG Number: 
2026-02451
Notice PDF: 
Date Filed: 
05/22/2026
Noticing Party: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Environmental Research Center
Alleged Violators: 
Outlier Health, Inc., individually and dba Complement
Chemicals: 
Perfluorooctanoic Acid (PFOA)
Source: 
Complement Vanilla Organic Protein Plant-Based Protein Powder Made with Real Food Ingredients

60-Day Notice Document

Settlement
AG Number:
2026-02451
Settlement PDF: 
Settlement Date:
08/12/2026
Case Name: 
Environmental Research Center, Inc. vs. Outlier Health, Inc.
Court Name: 
Out of Court Settlement
Court Docket Number: 
N/A
Plaintiff: 
Environmental Research Center, Inc.
Plaintiff Attorney: 
Environmental Research Center
Defendant: 
Outlier Health, Inc., individually and dba Complement
Injunctive Relief: 
Beginning on the Effective Date, Outlier 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, any Covered Product which exposes a person to a “Daily Lead Exposure Level” of more than 0.5 micrograms of lead per day and/or any Covered Product that exposes a person to a quantifiable level of PFOA that can be reliably achieved using industry standard methods for testing, unless the product meets the warning requirements under Section 3.2. Nothing in this Section 3 shall require the re-labeling, recall, or removal of Covered Products manufactured, packaged, and “introduced into the stream of commerce” prior to the Effective Date — including units in transit or held in third-party fulfillment or retail inventory — and such units may be sold through in their existing packaging. The term “introduced into the stream of commerce” means that the Covered Product is no longer in the possession of or under the control of Outlier Health.
*Non-Contingent Civil Penalty:
$ 5,000.00
Attorney(s) Fees and Costs:
$ 20,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 25,000.00
Will settlement be submitted to court?
No
Contact Name: 
Charles Poss
Contact Organization: 
Environmental Research Center
Address: 
3111 Camino Del Rio North, Ste 400
City, State, Zip:
San Diego, CA 92108
Phone Number:
(619) 500-3090
Comments: 
This Settlement Agreement also includes AG number 2026-02800.


* 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.