Food labeling class actions continue to plague food manufacturers and retailers, with the Northern District of California being the favored forum for these claims.  Indeed, in The New Lawsuit Ecosystem:  Trends, Targets and Players (Oct. 2013), the U.S. Chamber Institute for Legal Reform identified food labeling class actions brought by plaintiffs, public interest groups, and attorneys general as one of the primary emerging liability threats facing American businesses.  One of the favorite allegations of such claims centers on the use of “all natural” or similar words on food labels.  Very often, a plaintiff alleges that a product contains ingredients from genetically modified soybean or corn, so the product allegedly cannot be considered “natural.”  With California’s liberal consumer protection laws, these claims often survive motions to dismiss, with courts reasoning that plaintiffs adequately plead that reasonable consumers will read “all natural” labels and conclude that the product does not contain genetically