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January 2015

A plaintiff does not need to demonstrate individualized reliance on specific misrepresentations to satisfy the reliance requirement. [W]here, as here, a plaintiff alleges exposure to a long-term advertising campaign, the plaintiff is not required to plead with an unrealistic degree of specificity that the plaintiff relied on particular advertisements or statements. Petterson testified to the general contents of the ads he saw and their locations, which sufficed under these circumstances