Noticing Party:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
60-Day Notice Document
Civil Complaint
Case Name:
Environmental Research Center, inc. vs. Just Ingredients
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
Settlement
Settlement Date:
10/21/2025
Case Name:
Environmental Research Center, inc. vs. Just Ingredients
Court Name:
Alameda County Superior Court - Hayward
Plaintiff:
Environmental Research Center, Inc.
Plaintiff Attorney:
Michael Freund & Associates
Defendant:
Just Ingredients, Inc.
Keystone Co-Pack Manufacturing, LLC f/k/a TKS Products, LLC
Injunctive Relief:
Beginning on the Effective Date, the Settling Defendants 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 unless it
meets the warning requirements under Section 3.2.
*Non-Contingent Civil Penalty:
$ 5,000.00
Attorney(s) Fees and Costs:
$ 65,000.00
Payment in Lieu of Penalty:
$ 0.00
Total Payments:
$ 70,000.00
Will settlement be submitted to court?
Contact Organization:
Michael Freund & Associates
Address:
1919 Addison Street, Suite 104
City, State, Zip:
Berkeley, CA 94704
Phone Number:
(510) 499-1992
* 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.
