Christine Slowinski v. Beiersdorf, Inc.

Summary

The United States District Court for the Northern District of Illinois granted Beiersdorf, Inc.’s motion to dismiss Christine Slowinski’s putative class action concerning the labeling of Eucerin skincare products as “Natural Moisturizing Factors Enriched.” The court held that Plaintiff lacked standing to pursue claims concerning products she did not purchase and prospective injunctive relief, and that her ICFA, common-law fraud, and unjust-enrichment claims were inadequately pleaded. The court granted leave to amend by March 9, 2026.

Holdings

1. A plaintiff who purchased only one product lacks standing to pursue claims concerning other products when the products, labels, and alleged misrepresentations are not substantially similar. Plaintiff therefore lacked standing to challenge the Advanced Repair Cream and Advanced Repair Lotion, but could proceed, subject to other deficiencies, only on claims concerning the Intensive Repair Lotion she allegedly purchased.
2. Plaintiff lacked Article III standing to seek prospective injunctive relief because she did not plausibly allege a real and immediate threat of future injury or an interest in purchasing Defendant's products again.
3. The complaint did not plausibly allege that the phrase "Natural Moisturizing Factors Enriched" was deceptive as a matter of law.
4. The complaint did not plausibly allege actual pecuniary loss caused by the alleged deception, as required for a private ICFA claim.
5. The common law fraud claim failed because Plaintiff did not plausibly allege a false or deceptive statement likely to mislead a reasonable consumer or pecuniary damages resulting from reliance.
6. Under Illinois law, unjust enrichment is not a standalone cause of action, and Plaintiff's unjust enrichment claim could not proceed after dismissal of the other claims.

Questions Presented

1. Whether Plaintiff had Article III standing to pursue claims involving two Eucerin products she did not allege purchasing.
2. Whether Plaintiff had standing to seek prospective injunctive relief absent an allegation that she intended to purchase Defendant's products again.
3. Whether the amended complaint plausibly alleged a deceptive practice and actual pecuniary loss under the Illinois Consumer Fraud and Deceptive Business Practices Act.
4. Whether the amended complaint stated a claim for common law fraud.
5. Whether unjust enrichment could proceed as an independent claim after dismissal of the other claims.

Disposition

other