In Goldrich v. Natural Y Surgical Specialties, Inc. (1994) 25 Cal.App.4th 772, plaintiff alleged defendants falsely and fraudulently represented breast implants were safe for use in breast surgery, posed no dangerous risks, and would nor require frequent removal. These representations were false and the true facts were that the product was dangerous and required frequent removal. Defendants knew the representations were false and made them with in order to "defraud and deceive" plaintiff and to induce her to use the product. The court found it proper to dispose of this cause of action by demurrer or motions for judgment on the pleadings. "This is not the stuff of which a fraud claim is made." (Id. at p. 782.) The complaint lacked the required specificity. Plaintiff's "conclusory allegations offer no facts at all and it is impossible to determine what was said or by whom or in what manner. We don't know whether the statements were made in writing (in package inserts or advertisements or otherwise) or orally (by executives or sales representatives or others) or by one or all of the defendants. Reliance is alleged in equally insufficient terms, with no explanation about how Mrs. Goldrich could have relied upon something she cannot now describe in any fashion." (Goldrich, supra, 25 Cal.App.4th at p. 783.)