The complaint alleges that defendants fraudulently induced plaintiff to purchase plastic bags from them by providing a "Certificate of Compliance" in which defendant Fung falsely represented that "all packaging and packaging components sold to [plaintiff] or its subsidiaries in the State(s) of USA comply with the requirements of the toxics in packaging law(s)," that "the sum of the incidental concentration levels of [regulated metals] present in any package or package component...
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