In Anunziato v. eMachines, Inc. (C.D.Cal. 2005) 402 F. Supp. 2d 1133, the plaintiff alleged a line of the defendant's laptop computers had a defect causing some of them to overheat. (Anunziato, at p. 1135.) The plaintiff alleged the defendant made misrepresentations about the quality, reliability, and performance of its laptop computers in a press release and in each computer's user manual. (Id. at pp. 1139-1140.) The defendant argued the plaintiff lacked standing to pursue a UCL claim because he could not show he relied on any of the alleged misrepresentations in purchasing the computer. The court, rejecting that argument, held a plaintiff does not have to show actual reliance on the alleged misrepresentation to have standing to pursue a fraud-based claim under the UCL. (402 F.Supp.2d at pp. 1137-1138.) The court reasoned: " The Court can envision numerous situations in which the addition of a reliance requirement would foreclose the opportunity of many consumers to sue under the UCL and the FAL false advertising law. One common form of UCL or FAL claim is a 'short weight' or 'short count' claim. For example, a box of cookies may indicate that it weighs sixteen ounces and contains twenty-four cookies, but actually be short. Even in this day of increased consumer awareness, not every consumer reads every label. If actual reliance were required, a consumer who did not read the label and rely on the count and weight representations would be barred from proceeding under the UCL or the FAL because he or she could not claim reliance on the representation in making his or her purchase. Yet the consumer would be harmed as a result of the falsity of the representation." (Id. at p. 1137.) In Anunziato v. eMachines, Inc. (2005) the plaintiff, alleged inter alia, a violation of the UCL and FAL based on misrepresentations as to a computer that overheated. The Anunziato court found most of the defendant's representations were mere puffery but concluded the defendant's representation the computer had been subjected to the "most stringent of quality control tests? was actionable. (Id. at p. 1140.) Anunziato held that all class members, regardless of whether they had actually read or relied on the defendant's representation the computer had been subjected to quality control testing had suffered a cognizable injury in fact under the UCL. In the course of its discussion, Anunziato rejected an argument that it is necessary to prove each individual class member relied on the misrepresentation, explaining: "The goal of both the UCL and the FAL is the protection of consumers. However, the Court can envision numerous situations in which the addition of a reliance requirement would foreclose the opportunity of many consumers to sue under the UCL and the FAL. One common form of UCL or FAL claim is a 'short weight' or 'short count' claim. For example, a box of cookies may indicate that it weighs sixteen ounces and contains twenty-four cookies, but actually be short. Even in this day of increased consumer awareness, not every consumer reads every label. If actual reliance were required, a consumer who did not read the label and rely on the count and weight representations would be barred from proceeding under the UCL or the FAL because he or she could not claim reliance on the representation in making his or her purchase. Yet the consumer would be harmed as a result of the falsity of the representation." (Anunziato, supra, at p. 1137.)