...America’s largest and most profitable food conglomerates should not tolerate child labor, much less child slave labor, anywhere in their supply chains. These companies should not turn a blind eye to known human rights abuses or shirk from investigating and preventing potential human rights abuses by their suppliers, especially when the companies consistently and affirmatively represent that they act in a socially and ethically responsible manner. When these food conglomerates fail to uphold their responsibility for ensuring the absence of child and slave labor in their supply chains, their misconduct has the profound consequence of supporting and encouraging such labor. And when these food conglomerates fail to disclose the use of child and slave labor in their supply chains to consumers, they are deceived into buying products they would not have otherwise and thereby unwittingly supporting child and slave labor themselves through their product purchases. Such food conglomerates should be required to make restitution to the consumers they have deceived and to ensure the absence of child and slave labor in their supply chains in the future.

..FACTUAL ALLEGATIONS

A. The Worst Forms of Child Labor in the Ivory Coast Are Used to Produce Nestlé’s Chocolate Products. ..B. Nestlé Fails to Disclose the Use of the Worst Forms of Child Labor in Its Supply Chain... C. Nestlé Recognizes that the Use of Child or Slave Labor in its Supply Chain Is Wrong...D. Nestlé’s Use of the Worst Forms of Child Labor in Its Chocolate Products Supply Chain Is Material to Consumers Who Are Generally Left Unaware Without Disclosure at the Point of Sale

....CAUSES OF ACTION...COUNT I VIOLATION OF THE MASSACHUSETTS CONSUMER PROTECTION ACT...COUNT II UNJUST ENRICHMENT ....

...JURY TRIAL DEMAND ......