In Spielhotz v. Superior Court (2001) 86 Cal.App.4th 1366, plaintiffs sued a wireless telephone service provider alleging that it falsely advertised a "seamless calling area" throughout Southern California and that it failed to disclose gaps or dead zones where wireless telephone users were unable to collect calls. (Id. at p. 1369.) The trial court granted defendants' motion to strike the allegations for monetary relief, ruling the damages claim was preempted by the federal statutory prohibition against state regulation of wireless telephone rates. (47 U.S.C. 332(c)(3)(A).) (86 Cal.App.4th at p. 1369.) The Court issued a writ of mandate reinstating the damages claim, ruling the federal statute does not preempt a state court from awarding monetary relief based on false advertising. (Ibid.) Spielholz commented "We construe the complaint liberally in connection with an attack on the pleading. (Code Civ. Proc., 452.)" (Spielholz, supra, 86 Cal.App.4th at p. 1380.) Without any elaboration, Spielholz then stated: "The complaint adequately alleges several tort causes of action based on false advertising . . . ." (Ibid.)