Plaintiff brings this class action lawsuit on behalf of herself and other similarlysituated consumers (“Class Members”) who purchased Defendant’s products containing (i) aSustainability Profile or (ii) a Sustainability Misrepresentation (the “Products”). In short,Defendant takes advantage of consumers’ interest in products that are sustainable and that do notharm the environment. By falsifying the Sustainability Profiles and making the SustainabilityMisrepresentations, Defendant has misrepresented the nature of its products, at the expense ofconsumers who pay a price premium in the belief that they are buying truly sustainable andenvironmentally friendly clothing. Plaintiff is a purchaser of the Products who asserts claims forunjust enrichment and violations of the consumer protection laws of the state of New York, onbehalf of herself and all similarly situated purchasers of the Products

In addition to its Sustainability Profiles, H&M makes various othermisrepresentations concerning the purportedly sustainable nature of its products: H&M claimsthat its products are “conscious,” a “conscious choice,” a “shortcut to sustainable choices,” madefrom “sustainable materials,” “close the loop,” and that H&M will prevent its textiles “fromgoing to landfill” through its recycling program (collectively, the “SustainabilityMisrepresentations”). These representations are made through the use of green hang tags,in-store signage, and online marketing. The goal of H&M’s advertising scheme is to market andsell products that capitalize on the growing segment of consumers who care about theenvironment, but H&M does so in a misleading and deceptive way

dress was made with 20% less water on average, when it was actually made with 20% morewater.