In Buckland v. Threshold Enterprises, Ltd. (2007) 155 Cal.App.4th 798, a women's rights advocate bought skin creams that were allegedly sold by the defendants in violation of federal marketing laws. (Buckland, at pp. 804-805.) The plaintiff in Buckland acknowledged she had incurred " 'the cost of purchasing each of these products in order to meet the letter of the law to have ... economic damages that provide standing under the statutes by which I am proceeding in the case.' " (Id. at p. 805.) In considering whether the plaintiff had standing under the UCL, Buckland surveyed the post-Havens federal case law and concluded the federal circuits were divided on "whether the costs an organization incurs to pursue litigation are sufficient, in themselves, to establish an injury in fact." (Buckland, at p. 815.) Buckland adopted the rule of the majority of the circuits that, " 'an organization cannot ... manufacture the injury necessary to maintain a suit from its expenditure of resources on that very suit.' " (Ibid.) Buckland concluded its plaintiff did not have standing under that rule "because the costs were incurred solely to facilitate her litigation ... and to hold otherwise would gut the injury in fact requirement." (Buckland, at p. 816.) In sum, an individual and her organization brought an action to prevent the defendants from marketing their skin lotions and creams. The claims of the individual plaintiff were dismissed pursuant to a demurrer. One issue on appeal was whether Aladdin had standing to bring a UCL claim when the "only loss of money or property she identified was her expenditures of funds to buy respondents' allegedly defective products ... ." (Buckland, at p. 813.) Because the injury in fact standing requirement is rooted in the federal Constitution, the Buckland court consulted federal authority. (Buckland, supra, 155 Cal.App.4th at pp. 815-816.) It found that the circuit courts were divided "over whether the costs an organization incurs to pursue litigation are sufficient, in themselves, to establish injury in fact." (Id. at p. 815.) According to the Buckland court, the majority view is that "'an organization cannot, of course, manufacture the injury necessary to maintain a suit from its expenditure of resources on that very suit,'" but "funds expended independently of the litigation to investigate or combat the defendant's misconduct may establish an injury in fact. ." (Ibid.) The Buckland court adopted this rule and applied it to the individual plaintiff in that case. Ultimately, the court held that the plaintiff had not suffered an injury in fact because she purchased the defendant's product for the purpose of establishing standing and she could not identify any expenditure she made independently of the litigation. (Id. at p. 816.)