In POM Wonderful v. Coca-Cola Co. (2014) 573 U.S. 189 L. Ed. 2d 141, 134 S.Ct. 2228, the question was whether a suit under the Lanham Act (15 U.S.C. 1125) alleging that Coca-Cola, the plaintiff's business competitor, used a deceptive and misleading label on Coca-Cola's product, was precluded by the Federal Food, Drug, and Cosmetic Act (FDCA) (21 U.S.C. 331, 343), that forbids the misbranding of food, including by false and misleading labeling, and places enforcement of misbranding of food and drink in the hands of the Food and Drug Administration (FDA). (POM Wonderful, supra, 573 U.S. 134 S.Ct. at p. 2233.) The Ninth Circuit Court of Appeals held the FDCA precluded the Lanham Act claim, reasoning that Congress decided to entrust matters of juice beverage labeling to the FDA, which promulgated comprehensive labeling regulations that did not impose the requirements the plaintiff sought to impose on Coca-Cola. (POM Wonderful, supra, 573 U.S. 134 S.Ct. at p. 2236.) The Ninth Circuit did not believe it should act where the FDA had not, as to do so would risk undercutting the FDA's expert judgment and authority. (Ibid.) The Supreme Court reversed, finding preclusion did not apply, as (1) there was no statutory text or established interpretive principle to support preclusion, (2) nothing relating to either statute showed a congressional purpose or design to forbid such suits, and (3) to the contrary, the statutes complemented each other in the federal regulation of misleading food and beverage labels. (POM Wonderful, supra, 573 U.S. 134 S.Ct. at p. 2233.) The court first explained that neither statute contained a provision that disclosed a purpose to bar unfair competition claims like that asserted by the plaintiff. (POM Wonderful, supra, 573 U.S. 134 S.Ct. at p. 2237.) The court found this absence of "special significance" because the two statutes had coexisted for 70 years, and if Congress had concluded that Lanham Act suits could interfere with the FDCA, it might have enacted a provision addressing the issue. (573 U.S. 134 S.Ct. at p. 2237.) The court noted that while Congress had enacted amendments to the FDCA and Lanham Act, including an amendment that added an express preemption provision with respect to state laws addressing food and beverage misbranding, it did not enact a provision addressing the preclusion of other federal laws in this area; in the court's view, this constituted "'powerful evidence that Congress did not intend FDA oversight to be the exclusive means' of ensuring proper food and beverage labeling." (573 U.S. 134 S.Ct. at p. 2237.) The court further found that the complex preemption provision added to the FDCA in 1990, which was the closest the statutes had come to addressing the preclusion of the plaintiff's Lanham Act claim, suggested that Lanham Act suits are not precluded. (573 U.S. 134 S.Ct. at pp. 2237-2238.)