Conn. Gen. Stat. § 42-110b

A single unfair or deceptive act can support a claim under § 42-110b; repeated misconduct is not required.

Krolikowski v. Ge Life Annuity Assce., No. Cv99 0174898 S (Jun. 12, 2000) · filed 2000-06-12(b)

This court therefore concludes, once again, that "a single act is sufficient to support a CUTPA claim." Id.

A single negligent act may violate § 42-110b(a) if it sufficiently meets the criteria for unfairness.

Vuoso v. Department of Consumer Protection, No. Cv 99-0267844 (Feb. 2, 2001) · filed 2001-02-02(a)

The language of the statute and the case law clearly indicate that a single act of negligence may be sufficient to sustain a finding of a CUTPA violation.

Section 42-110b(a) allows a CUTPA claim to be based on a single unfair act.

Walk v. Lupia Renovating Co., Inc., No. Cv-000504205s (Apr. 18, 2001) · filed 2001-04-18(a)

This court finds most persuasive the reasoning of those cases that have determined that a CUTPA violation can be based upon a single act of misconduct.

Section 42-110b(a) permits a CUTPA claim based on a single act of misconduct; repeated acts need not be alleged.

Turner v. Allstate Ins. Co., No. Cv00-0177471 S (May 11, 2001) · filed 2001-05-11(a)

Consequently, viewing the allegations in a light most favorable to the plaintiffs, this court finds that a single act of misconduct is sufficient to allege a violation of CUTPA.

Section 42-110b can apply to a single transaction in the conduct of trade or commerce.

Russo v. Danziger Homes, Inc., No. Cv99 033 63 16 S (Feb. 23, 2001) · filed 2001-02-23(a)

This court agrees with the reasoning of the majority of decisions on this issue that have held CUTPA to be applicable to a single transaction that occurs in the conduct of any trade or commerce.

A single alleged transaction is insufficient to establish a general business practice that violates CUTPA.

Equicredit Corp. v. Braese, No. Cv01 007 42 56 (Oct. 19, 2001) · filed 2001-10-19

The court has previously held that, although there is a split of authority on the issue, more than an allegation of a single transaction by a party is needed to constitute a general business practice which would violate CUTPA. ... There is nothing in the facts of the counterclaim, as pleaded, which would cause the court to change its previous position.

Section 42-110b(a) requires more than a single act to state a CUTPA claim.

Benchmark Investments LLC v. Elms at Mystic LLC, No. 555579 (Jan. 11, 2002) · filed 2002-01-11(a)

This court has therefore repeatedly concluded that the allegation of a single act is insufficient to state a claim for violation of CUTPA. ... The court sees no reason to depart from its previous holdings on this issue.

Section 42-110b(a) can apply to a single sale of a business even when the seller is not in the business of selling businesses.

Neato, LLC v. Soundview Partners, No. Cv01-0450989 (May 30, 2002) · filed 2002-05-30(a)

Additionally, there appears to be no good reason, whether based upon the wording of the act or its purpose which would make CUTPA inapplicable to a single transaction such as that alleged in this case.

Section 42-110b(a) requires more than a single act, as opposed to a more general business practice, to state a CUTPA claim.

Golliff v. Allstate Life Insurance Company, No. 559316 (Jul. 8, 2002) · filed 2002-07-08(a)

This court has therefore repeatedly concluded that the allegations of a single act, as opposed to a more general business practice, is insufficient to state a claim for violation of CUTPA.

Section 42-110b requires plural acts or practices for a CUTPA violation, so a single act is insufficient.

Church v. Rent-A-Center, No. 559970 (Jul. 12, 2002) · filed 2002-07-12

This court has already held that plural acts or practices, such as those that have been alleged in the present case, are sufficient to sustain a CUTPA violation.

A single act of misconduct can violate § 42-110b; a pattern of similar conduct is not required.

Hart v. Carruthers · filed 2003-06-24

In so doing, we made it clear that a single act of misconduct may constitute a violation of CUTPA.

Section 42-110b(a) addresses unfair or deceptive trade practices, so a CUTPA claim may accompany a product liability claim.

D'Alfonso v. Jacobs Suchard, Inc., No. Cv91-04440425 (May 17, 1991) · filed 1991-05-17(a)

General Statutes section 42-110b (a) provides: "No person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." CUTPA deals with actions that cause unjustified consumer injury rather than a personal injury based upon negligence. ... Since CUTPA and the Products Liability Statutes are legislative remedies serving to accomplish different objectives, they are not mutually exclusive of the other.

A deceptive marketing claim under § 42-110b may proceed alongside a product liability claim when it alleges distinct conduct and injury.

Utica Mutual Insurance v. Denwat Corp. · filed 1991-10-07(a)

Although the preceding allegations may state a cause of action under the PLA, Count Four may independently assert actionable conduct under CUTPA.

Section 42-110b requires an unfair or deceptive trade practice; allegations of physical injury from a defective product alone do not state a separate claim under it.

Cristy v. Soft Sheen Products, No. Cv 90-0277636 (Nov. 13, 1992) · filed 1992-11-13(a)

The plaintiff's CUTPA claim is predicated upon physical injuries caused by the product itself, and not upon unfair or deceptive business practices. thus there is no functional distinction between the wrongs asserted in the CUTPA claim and those in the product liability claim. It is not that a CUTPA claim cannot be brought contemporaneously with the PLA claim in this action but rather that the allegations as pled do not make out a legally sufficient CUTPA claim under sec. 42-110a .

Section 42-110b permits a CUTPA claim alongside a product liability claim when the alleged misconduct goes beyond the facts needed to support product liability.

Bertucci v. General Motors Corp., No. Cv95-0146602s (May 28, 1998) · filed 1998-05-28

Similar to the plaintiff's allegations in Geissler and Khouri, the present allegations are unnecessary to support a products liability, claim but are sufficient to maintain an action sounding in a violation of the CUTPA. Counts three and seven are legally sufficient. The motion to strike counts three and seven, therefore, is denied.

Section 42-110b supports a CUTPA claim alongside a product liability claim when the alleged conduct goes beyond what is needed to support product liability.

Bertucci v. General Motors Corporation, No. Cv95 0146602 S (May 29, 1998) · filed 1998-05-29

Similar to the plaintiff's allegations in Geissler and Khouri, the present allegations are unnecessary to support a products liability, claim but are sufficient to maintain an action sounding in a violation of the CUTPA. Counts three and seven are legally sufficient. The motion to strike counts three and seven, therefore, is denied.

CUTPA claims for property damage caused by a defective product are governed by the CPLA and are not barred by its commercial loss rule.

Mountain West Helicopter, LLC v. Kaman Aerospace Corp. · filed 2004-03-09

Applying these principles, the court concludes that the CUTPA cause of action and those brought pursuant to common law tenets concerning strict liability, negligence, breach of warranty, and misrepresentation are governed by the CPLA. ... The court therefore concludes that the CPLA governs the CUTPA cause of action and the strict liability, negligence, breach of warranty, and misrepresentation causes of action.

Section 42-110b(a) does not extend CUTPA to banking and other non-consumer transactions, including mortgage and land purchase agreements.

Matthews Group, Inc. v. Essex Savings Bank, No. 66719 (Mar. 15, 1993) · filed 1993-03-15(a)

The legislature did not intend to have CUTPA's application extended to banking and other non-consumer related transactions, such as mortgage and land purchase agreements. Therefore, the court grants the defendant's motion to strike count I of the plaintiff's complaint because the allegations of the plaintiff's CUTPA claim are legally insufficient to support the cause of action.

A § 42-110b(a) defense to foreclosure fails when nothing indicates that the lender's actions violated the statute.

Essex Savings Bank v. Navin, No. 51 61 39 (Jan. 2, 1992) · filed 1992-01-02(a)

There is nothing to indicate that plaintiff's actions are in violation of General Statutes Section 42-110b (a). There is no issue as to any material question of fact and plaintiff is entitled to judgment as a matter of law.

Section 42-110b(a) applies to banks.

Santamaria v. William Litwin Enterprises, No. 056805 (Apr. 13, 1992) · filed 1992-04-13(a)

This court has previously determined that CUTPA does apply to banks. See, e.g., Ebersol McCormick, supra; Connecticut National Bank v. Anderson, 5 CTLR 6 (October 21, 1991, Pickett, J.), and, adhers to its prior decisions. Therefore, the motion to strike the third special defense, is granted.

Section 42-110b applies to banks.

People's Bank v. Smulley, No. Cv 91-0283291 (Nov. 18, 1992) · filed 1992-11-18(a)

General Statutes section 42-110b (a) provides, in pertinent part, "[n]o person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." ... The Court adopts the majority view and holds that CUTPA does apply to banks.

Section 42-110b(a) does not cover a bank's commercial loan when the claimant has no consumer relationship with the bank.

Bank of Boston Connecticut v. Victoria Ct., Inc., No. 100526 (Jun. 29, 1994) · filed 1994-06-29(a)

In the present case, Country did not have a consumer relationship with BOBC or any direct dealing with BOBC. In addition, the loan from BOBC to Victoria was commercial, and therefore, not within the purview of CUTPA as applied to a bank.

Section 42-110b(b)’s direction to consult federal interpretations does not import the Federal Trade Commission Act’s exemption for banks; CUTPA applies to banks.

Normand Josef Enterprises, Inc. v. Connecticut National Bank · filed 1994-08-02(b)

It would be inconsistent with the remedial purposes of CUTPA for us to broaden the reference in § 42-110b (b) to § 5 (a) (1) of the Federal Trade Commission Act to incorporate the blanket exemption for banks that is contained in § 5 (a) (2) of the federal act.

Extending a loan’s repayment term with the borrower’s consent and without harm to the borrower does not violate § 42-110b(a).

Norwich Savings Society v. Caldrello · filed 1995-08-22(a)

Because the extension of the loan agreement to give the defendant more time to pay off the note did not preclude the defendant from paying off the loan at the original time, there was no harm to the defendant by the extension. The extension, whether secret or not, conferred on the defendant the benefit of having more time to meet his obligation. Therefore, the third prong of the cigarette rule is not satisfied. ... The trial court properly concluded that there was no violation of CUTPA by the plaintiff’s extension of the term of the loan to the defendant.

Section 42-110b permits an unfair trade practice claim when a mortgage servicer fails to correct an invalid release after payoff despite repeated requests.

Peterson v. Capstead, Inc., No. Cv99-0432823-S (Sep. 28, 2000) · filed 2000-09-28

They allege that having taken their money and then clouded the title to their property by recording an invalid mortgage release, Capstead would not correct the situation despite requests to do so from their attorney. Further, they claim that after being notified of the problem, Capstead left them in this situation for at least two years. Whether these allegations can be proved is another matter. For purposes of a motion to strike, however, they are adequate to support a claim of unfair trade practice in violation of CUTPA.

Violations of banking regulations can support a CUTPA claim when they breach Connecticut public policy.

Pabon v. Recko · filed 2000-11-17(a)

Violations of banking regulations, rather, can amount to a breach of public policy and, in turn, a violation of CUTPA.

Section 42-110b(a) does not support a CUTPA claim against a mortgage assignee for failing to record or correct a prior assignment when the assignee owed the mortgagor no duty to do so.

Owades v. Assoc. Home Equity Ser., No. Cv 01 0380582 S (Jul. 16, 2001) · filed 2001-07-16(a)

The plaintiffs' claims that AHES violated CUTPA are based on their argument that AHES owed them a duty to record or to correct the non-recording of the assignment from OFC to SPFC. As the court has held that AHES had no such duty, the plaintiffs' CUTPA must fail and the motion to strike count five should be granted.

Section 42-110b(a) permits a CUTPA claim based on allegedly oppressive foreclosure actions brought to obtain payments that were not yet owed.

Cais v. Citizens Savings Bank of Connecticut, No. 556544 (Sep. 17, 2001) · filed 2001-09-17(a)

These allegations, if proven, would be sufficient to show that the defendant acted in an oppressive manner because the defendant sought to receive funds it was not owed or take possession of the plaintiff's property through legal action and cause the plaintiff to either pay the funds the defendant demanded or incur substantial legal fees to defend against the foreclosure actions. Construed in the light most favorable to the plaintiff, these allegations are sufficient to make out a CUTPA claim. The defendant's motion to strike count six is, therefore, denied.

Section 42-110b(a) does not treat isolated erroneous denials of HAMP loan modification applications as unfair or deceptive practices without a pattern of unethical conduct.

Speer v. US National Bank · filed 2024-03-26(a)

Even if the Defendants’ denials of Ms. Speer’s HAMP applications were in fact erroneous, those individual denials would be more similar to “isolated instance[s] of misinterpretation by the defendant of its obligations,” which Connecticut courts have distinguished from unfair or deceptive acts or practices that violate CUTPA.

Routine foreclosure and default actions do not violate § 42-110b(a) without an identified unfair or deceptive act.

Rothermel v. U.S. Bank National Association · filed 2025-07-25(a)

As the Court has discussed in the context of Plaintiff’s fraud claim above and the numerous federal law claims in the prior ruling, see Rothermel, 2025 WL 950718, at *10–15, Plaintiff has not identified any unfair or deceptive act on the part of U.S. Bank, SPS, or Attorney Cheverko. Rather, it appears that these three Defendants engaged in routine foreclosure proceedings and default actions in foreclosing on Plaintiff’s property. For these reasons, the Court finds that Plaintiff’s CUTPA cause of action as to U.S. Bank, SPS, and Attorney Cheverko fails to state a claim, and is dismissed without leave to replead.

A bank does not violate § 42-110b(a) by collecting default interest, late charges, and attorney’s fees that it is entitled to collect after borrowers default.

Smithfield Associates, LLC v. Tolland Bank · filed 2004-11-16(a)

Because the plaintiffs had breached the agreement by not paying the balance of the two notes on or before November 30, 2000, the defendant was entitled to require the plaintiffs to pay the charges at issue at the time of the closing. The court’s finding that the defendant had violated CUTPA was clearly erroneous.

A borrower's claim that a lender unfairly retained letter-of-credit proceeds and collected rents without authority can proceed under § 42-110b(a) when material facts remain disputed.

Kings Lane Ass'n v. the Trav. Ins. Co., No. Cv94 31 29 90 S (Aug. 16, 1996) · filed 1996-08-16(a)

In the present case, Kings lane alleges unfair and deceptive practices on the part of Travelers in its retention of funds from three separate letters of credit and the collection of rents from tenants of the property without authority. The court finds that there exist genuine issue(s) of material fact(s) as to these counts (two, four, six, nine and eleven) and the motion for summary judgment is denied as to them.

Section 42-110b claims challenging an ERISA health plan’s removal of participating physicians are preempted by ERISA because CUTPA is not specifically directed at insurance companies.

Hollis v. Cigna Healthcare of Connecticut, No. 705357 (Dec. 5, 1994) · filed 1994-12-05(a)

The case for preemption here is even stronger than in the case of CUIPA, because the CUTPA claims, like the common-law claims about to be discussed, do not fall within the scope of the saving clause.

Section 42-110b provides a civil enforcement remedy for unfair trade practices, but its use as an alternative enforcement mechanism for ERISA plan rights is preempted.

Glynn v. Bankers Life & Casualty Co. · filed 2003-12-11

Applying these principles, the court concludes that, although CUTPA does not specifically refer to ERISA, the CUTPA cause of action is preempted as it has a clear connection with a plan in that it provides an alternative enforcement mechanism.

Violations of the Home Improvement Act and Home Solicitation Sales Act are per se unfair trade practices under § 42-110b.

Baskin v. Portnoy, No. Cv94 0136911 S (Mar. 7, 1995) · filed 1995-03-07

General Statutes § 20-427 (b) and General Statutes § 42-141 (b) provide that any violations of the HIA and the HSSA are deemed unfair trade practices under General Statutes § 42-110b .

A violation of § 35-1 is a per se violation of § 42-110b(a), so a plaintiff need not plead that the conduct satisfies the cigarette rule.

Wilton Ymca, Inc. v. Deangelis, No. Cv9 40 31 24 97 (May 24, 1995) · filed 1995-05-24(a)

Therefore, the plaintiff, in pleading that the defendant violated § 35-1 , need not plead that the defendant's conduct violated one of the prongs of the "cigarette rule," as a violation of § 35-1 is a per se violation of CUTPA.

A violation of Chapter 736 is a per se violation of § 42-110b, without applying the Cigarette Rule.

Leonard v. State, Dept. of Consumer Prot., No. Cv-94-540747 (Sep. 29, 1995) · filed 1995-09-29

When the legislature has determined that particular conduct is unfair and makes such conduct unlawful, then that conduct is a per se violation of CUPTA and resort to the Cigarette Rule is inappropriate.

A Home Improvement Act violation is an unfair or deceptive trade practice under subsection (a) and can support a CUTPA claim.

Klein v. Hathaway, No. Cv95 0142988 S (Mar. 15, 1995) · filed 1995-03-15(a)

The defendant next argues that paragraphs 13-16 in the count alleging Connecticut Unfair Trade Practices Act, General Statutes § 42-110b should be stricken. Paragraphs 13-16 reallege the paragraphs in count two, violations of the HIA. General Statutes § 20-427 (c) provides, in pertinent part, "[a] violation of any of the provisions of this chapter shall be deemed an unfair or deceptive trade practice under subsection (a) of section CT Page 3220-c 42-110b ." ... Accordingly, the motion to strike is denied as to the fourth count, but granted as to the second, although paragraphs five through eight remain as part of the fourth count.

A violation of the Home Improvement Act is an unfair trade practice under § 42-110b(a).

Cimino v. Ciaramella, No. Cv91-0312359 (Jun. 5, 1995) · filed 1995-06-05(a)

General Statutes § 20-427 (c) provides that a violation of the Home Improvement Act "shall be deemed an unfair or deceptive practice under subsection (a) of section 42-110b ." While proof of a violation of the Home Improvement Act thus establishes proof of an unfair trade practice, a party is eligible for remedies under that statute only if he proves that he has suffered a loss as a result of the unfair practice.

Alleged violations of the Hill-Burton Act and Connecticut’s hospital bed funds statute can support a claim under § 42-110b.

Yale-New Haven Hospital, Inc. v. Mitchell · filed 1995-06-22(a)

In view of the court’s conclusion that private causes of action do exist under both the Hill-Burton Act and the hospital bed funds statute, it is apparent that allegations of violations of those statutes can be the basis of a CUTPA claim.

Section 42-110b permits a properly stated Sherman Act claim to support a CUTPA claim.

Raybestos Products Co. v. Coni-Seal, Inc. · filed 1997-06-27(b)

In light of these precedents and the express language of CUTPA, the Court concludes that because defendant has stated a claim under § 2 of the Sherman Act, it likewise has stated a claim under CUTPA. Accordingly, plaintiffs’ Motion to Dismiss Count Two of defendant’s counterclaims is denied.

A CUTPA claim may survive when the alleged conduct includes aggravating circumstances beyond a simple breach of contract.

Petro v. K-Mart Corporation, No. Cv 94 0123768 (Oct. 6, 1997) · filed 1997-10-06

In the present case the allegations of fact, viewed in the light most favorable to the plaintiff, constitute more than just a simple breach of contract claim. ... In construing the fourth count in the light most favorable to the third-party plaintiff, as the court must, the allegations adequately show sufficient aggravating circumstances, beyond a mere breach of contract that, if proven, fall with the ambit of CUTPA. Accordingly, Developers' motion to strike the fourth count of the second amended third-party complaint is denied.

Section 42-110b treats failure to file a trade name certificate as a per se CUTPA violation subject to a civil penalty.

State v. Cardwell, No. Cv 95 0556135-S (Jul. 31, 1997) · filed 1997-07-31

The statute provides that failure to file said certificate shall be a violation of CUTPA, General Statutes § 42-110b . ... This is, nonetheless, a per se violation of CUTPA. Consequently the court assesses a penalty of $1,000.00 for violation of the trade name statute. Sec. 35-1 .

A violation of the Home Solicitation Sales Act is a per se violation of CUTPA.

Faragasso v. Degeorge Home Alliance, No. Cv97 0162664 (Dec. 7, 1998) · filed 1998-12-07(a)

Therefore, since the HSSA is applicable, violation of it is a per se violation of CUTPA. As such, the plaintiffs have sufficiently plead allegations of an HSSA violation and a CUTPA violation, and the defendants motion to strike the second count is denied.

Section 42-110b does not make a violation of RISFA or UCC Article Nine a per se unfair trade practice.

Moye v. Credit Acceptance Corp., No. X01-99-0157073 (Nov. 3, 2000) · filed 2000-11-03

A violation of RISFA or of a provision of Article Nine of the UCC does not constitute a per se violation of CUTPA.

A sufficiently alleged Home Improvement Act violation states a per se unfair trade practices claim under § 42-110b(a).

Character v. Hodge, No. 121657 (Feb. 22, 2002) · filed 2002-02-22(a)

By operation of § 20-427 (c), these allegations are sufficient to state a per se violation of CUTPA. The motion to strike is therefore denied.

A violation of the new home construction contractor registration and disclosure requirements is a per se unfair trade practice, without separate proof of unfairness or deception.

D'Angelo Development & Construction Corp. v. Cordovano · filed 2010-05-18(a)

It is noteworthy that because D’Angelo Development committed a per se violation of CUTPA, the Cordovanos were not required to prove the existence of any unfair or deceptive acts.

Section 42-110b treats a car dealer’s sale of a vehicle for more than its advertised price as a per se unfair trade practice.

Cartagena-Cordero v. Five Star Cars, LLC · filed 2020-10-06(a)

First, it is a per se violation of CUTPA for car dealers to sell vehicles for more than their advertised price.

Section 42-110b permits a CUTPA claim based on another statute’s regulatory principles even when that statute supplies no private right of action.

Eder Bros. v. Wine Merchants of Connecticut, Inc. · filed 2005-09-06(a)

Thus, the fact that the Liquor Control Act does not convey a private right of action to the plaintiffs is irrelevant to whether they have standing to bring a CUTPA claim.

Section 42-110b does not impose liability on an organization for another person's alleged unfair practices when no agency relationship is shown.

Mullen v. Horton, No. Cv94 0533347 (Oct. 18, 1995) · filed 1995-10-18(a)

In the absence of an agency relationship, the plaintiff's CUTPA claim as against the Oblate Institutional Defendants fails as a matter of law.

A landlord is not liable for an unfair or deceptive practice merely because apparent agency makes her responsible for an agent’s reimbursement agreement.

Chorches v. Dimeo, No. Cvh 5985 (May 3, 1999) · filed 1999-05-03(a)

Again, the agreement to reimburse was made with Seymour Chorches, and although I have found Ellen Chorches obligated by the terms of that agreement under the doctrine of CT Page 6570 apparent agency, I do not find that she, who is the party to this action, engaged in behavior which can be considered oppressive, unethical or unscrupulous, or that she should be found to have engaged in an unfair and deceptive practice — vicariously.

Section 42-110b(a) prohibits unfair or deceptive acts in trade or commerce, subject to CUTPA's municipal exemption.

Town of Guilford v. D.P.L. Refuse Service, No. Cv95-0250575s (May 8, 1996) · filed 1996-05-08(a)

The Connecticut Unfair Trade Practices Act, General Statutes § 42-110b (a), provides in relevant part: "No person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." ... The mere fact that the transfer station ... involves commerce does not in and of itself prevent the application of the exemption provided to municipalities by the statute. ... The plaintiff municipality is exempt from liability under § 42-110. ... Based on the plaintiff's status as a municipality, however, its motion to strike the defendant's fourth special defense is granted.

Section 42-110b does not categorically exempt municipalities from CUTPA; courts apply the Connelly factors to determine whether an exemption applies.

Frillici v. Westport Shellfish C., No. X05 Cv 00-0176696 S (Oct. 12, 2001) · filed 2001-10-12

After a careful review of Connelly, Dana and the trial court decisions, this court holds that there is no blanket immunity for municipalities from CUTPA and the factors of Connelly must be applied to find that a municipality is exempt.

Section 42-110b(a) covers deceptive trade practices involving misrepresentation beyond unauthorized use of copyrighted material, so a claim based on that deception is not preempted by the Copyright Act.

Titan Sports, Inc. v. Turner Broadcasting Systems, Inc. · filed 1997-10-14(a)

CUT-PA protects against deceptive acts that fall outside the scope of copyright protection and satisfies the “extra element” test. The Copyright Act does not preempt Plaintiff’s CUTPA claim.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of trade or commerce.

Frontier Group, Inc. v. Northwest Drafting & Design, Inc. · filed 2007-06-29(a)

The court notes that the Plaintiff does not allege that it had a confidential or fiduciary relationship with the Defendant, nor does the Plaintiff allege that the Defendant violated a trade secret. The wrongful (or, as the Plaintiff states, “unfair and deceptive”) conduct alleged here is the same conduct that served as a basis for the Plaintiffs conversion claim — the unauthorized copying and use of the Plans. Allegations of such conduct, without more, are governed by federal copyright law exclusively, regardless of the a plaintiffs attempts to sound a claim in state unfair trade practices law. The Plaintiffs CUTPA claim contains no element to qualitatively differentiate it from those areas protected by copyright. Consequently, the Plaintiffs CUTPA claim fails to meet the “extra element” test, and is thus preempted by the Copyright Act.

The No Surprises Act does not preempt a Section 42-110b(a) claim seeking state law penalties for late payment of IDR awards.

Guardian Flight LLC v. AETNA Life Insurance Company Inc · filed 2025-05-14(a)

Imposing state law penalties for Defendants’ failure to timely pay IDR awards would not create any obstacles to the NSA’s purposes and objectives, as untimely payments are already proscribed by the NSA. And state penalties could help to ensure that parties comply with the NSA’s payment obligations and refrain from engaging in unfair practices to circumvent these provisions. In sum, the NSA does not preempt Plaintiffs’ CUTPA claim.

Section 42-110b(a) covers an attorney’s entrepreneurial activities rather than professional representation.

Suffield Development Associates Ltd. Partnership v. National Loan Investors, L.P. · filed 2002-07-09(a)

Although that may be actionable professional misconduct, we conclude that these allegations do not support a CUTPA claim because obtaining an execution on a judgment relates to the representation by the defendant attorney and law firm of their client and not to the entrepreneurial aspect of practicing law.

Section 42-110b excludes a lawyer's professional negligence and client representation from CUTPA, while covering entrepreneurial or commercial aspects of legal practice.

Bowling v. Mead, No. Cv01 0066544s (Jul. 15, 2002) · filed 2002-07-15

Accordingly, as in the health care context, `we conclude that professional negligence — CT Page 9047 that is, malpractice — does not fall under CUTPA.' Id. ... In conclusion, there are no facts alleged that indicate Mead's allegedly malpractice and immoral, oppressive and unscrupulous behavior are based on entrepreneurial or commercial dealings performed in the course of his representation of Raymond and Rhonda Bowling, Jr. Accordingly, the defendant's motion to strike count four is granted.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of trade or commerce.

Tatum v. Oberg · filed 2009-09-03(a)

CUTPA, which regulates unfair competition and unfair or deceptive acts or practices taking place in Connecticut, provides that, “[n]o person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce.” Conn. Gen.Stat. § 42-110b(a). ... Although the conduct Tatum alleges may be actionable as professional malpractice, the court concludes that such conduct relates to the defendants’ representation of Tatum and is not part of the entrepreneurial aspect of legal practice. To begin, some of the alleged conduct underlying Tatum’s CUTPA claim must plainly be considered outside of the entrepreneurial aspects of practicing law. Informing a client of his rights in a proposed settlement, providing him with legal advice, and filing discovery motions are some of the core tasks of a lawyer hired to represent a client in a dissolution action. These actions, even if performed in an intentionally deceptive manner, do not fall within the ambit of CUTPA.

Section 42-110b(a) does not cover an attorney’s representations to a prospective client about the attorney’s expertise or competence.

Dressler v. Riccio · filed 2021-07-06(a)

We construe the three aforementioned cases3 to instruct that representations made by an attorney to a prospective client regarding the attorney’s expertise and/or competence do not relate to the entrepreneurial aspects of the practice of law. Thus, such representa- tions are outside of the ambit of CUTPA.

Section 42-110b(a) covers the entrepreneurial aspects of practicing law, but conduct arising from an attorney’s professional representation does not support a CUTPA claim.

Minerva USA, LLC v. McCabe · filed 2020-07-24(a)

In short, because Minerva’s allegations of Defendants’ improper conduct all relate to their professional representation of Minerva, these allegations are insufficient to state a claim under CUTPA.

Section 42-110b(a) covers the entrepreneurial aspects of legal practice but does not cover professional negligence or malpractice.

Anderson v. Schoenhorn · filed 2005-06-21(a)

In general, CUTPA applies to attorney conduct, but only as to the entrepreneurial aspects of legal practice.

Section 42-110b does not apply to disputes arising from an employee/employer relationship because that relationship is outside trade or commerce.

Backert v. Bic Corporation, No. Cv 00 0376394 (Aug. 9, 2002) · filed 2002-08-09(a)

The court finds that the plaintiff cannot state a cause of action pursuant to CUTPA, because the claim is based upon an employee/employer relationship and is, therefore, outside the purview of CUTPA.

Section 42-110b does not apply to claims based on conduct within an employer-employee relationship.

Fortunato v. Office of Stephen M. Silston, D.D.S · filed 2004-06-23(a)

The defendant seems correctly to argue that the pertinent facts in the present case implicate the employer-employee relationship, a relationship to which CUTPA does not apply. ... This court must conclude that the plaintiff would not frankly have been able to assert a valid CUTPA based claim because, to follow Quimby, the relationship on center stage was that of employee-employer, as is the nature of the harm suffered, termination. ... Thus, while the termination’s motivating event occurred outside of the employment relationship, the termination itself lies at the action’s heart. The plaintiff, therefore, must be deemed unable to assert the public policy underlying CUTPA as a basis for recourse in wrongful termination.

Section 42-110b does not confer standing for an indirect injury.

North American Energy Systems, LLC v. New England Energy Management, Inc. · filed 2002-09-13

Any possible injury suffered by plaintiffs is an indirect injury and therefore cannot confer standing pursuant to CUTPA.

Section 42-110b applies to residential landlord-tenant transactions, and a landlord’s failure to return a tenant’s security deposit in violation of § 47a-21 (d) (2) can violate CUTPA.

Fitzpatrick v. Scalzi · filed 2002-10-08(a)

The referee found that because the defendants had violated § 47a-21 (d) (2) by not delivering the plaintiffs’ security deposit to them, the defendants had committed a CUTPA violation. The legislature and courts mandate a liberal reading of CUTPA. The referee’s finding is not clearly erroneous and will not be disturbed.

A landlord’s failure to hold one tenant’s security deposit in an escrow account, without more, does not establish an unfair or deceptive practice under CUTPA.

Freidburg v. Kurtz · filed 2022-02-01(a)

In the absence of any findings that the plaintiff violated § 47a-21, beyond failing to hold one tenant’s security deposit in an escrow account, we cannot conclude that the plaintiff’s alleged conduct, even if found by the court, was sufficiently unfair or deceptive to constitute a CUTPA violation.

A tenant’s alleged use of a lease and restrictive covenant to suppress competition, causing injury to the landlord and consumers, can state a claim under § 42-110b.

Putnam Downtown v. Stop Shop Supermkt., No. Cv 02 0067845 (Oct. 16, 2002) · filed 2002-10-16

Thus, the allegations in the complaint amount to a violation of public policy that falls within the rubric of CUTPA's cigarette rule.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in trade or commerce, requiring aggravating circumstances beyond a simple breach of contract.

AZTEC. ENERGY PARTNERS, INC. v. Sensor Switch, Inc. · filed 2007-10-02(a)

Section 42-110b(a) of the Connecticut General Statutes provides that “[n]o person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce.” ... Aztec must allege “sufficient aggravating circumstances” beyond a mere breach of contract to adequately state a claim for a violation of CUTPA. ... Here, the only deceptive practice that Aztec alleges is that Sensor Switch refused to provide credit to Aztec for the returned products because Aztec did not plan to purchase more products from it. With this sole allegation, Aztec cannot satisfy the cigarette rule test to establish a CUT-PA violation. ... In fact, Aztec cannot satisfy any of the three prongs of the CUTPA criteria. Accordingly, Aztec’s claim for a CUTPA violation is dismissed as legally deficient.

Section 42-110b applies standards that largely mirror federal and Connecticut antitrust standards to unfair competition claims.

Saint Francis Hospital and Medical Center v. Hartford HealthCare Corporation · filed 2023-02-13(a)–(b)

In sum, the standards governing an antitrust plaintiff’s CUTPA claim alleging unfair competition largely mirror the standards governing federal claims arising under the Sherman and Clayton Acts and state claims arising under the Connecticut Antitrust Act.

A CUTPA claim pleaded in skeletal form and based on the same allegations as dismissed trademark claims cannot survive.

Lops v. Youtube · filed 2023-03-03(a)

In other words, because the CUTPA claim is “alleged in skeletal form and largely based on the same factual allegations that support the Lanham Act claims, … the CUTPA claims cannot survive for the same reasons I have explained that the Lanham Act claims must be dismissed.” Bruce Kirby, Inc. v. Laserperformance (Eur.) Ltd., 2018 WL 3614117, at *3–5 (D. Conn. 2018). I will therefore dismiss Count Seven of Lops’s complaint.

A CUTPA claim based entirely on an alleged RESPA violation fails when the RESPA claim fails.

Speer v. Select Portfolio Servicing, Inc. · filed 2023-07-28(a)

Speer’s CUTPA claim depends on her allegation that MERS violated RESPA, but because her RESPA claim fails, so too must her derivative CUTPA claim.

Surviving Lanham Act allegations can provide a sufficient basis for a CUTPA claim under § 42-110b(a).

Concannon v. LEGO Systems, Inc. and LEGO System A/S · filed 2023-03-15(a)

As addressed above, Plaintiff’s Lanham Act allegations survive the motion to dismiss, and thus serve as a sufficient basis for his CUTPA claim as well.

Section 42-110b(a) covers a corporate insider’s efforts to divert a medical practice’s business and clientele to a competing practice.

Fink v. Golenbock · filed 1996-07-23(a)

In this case, the defendant took certain actions designed to usurp the business and clientele of one corporation in favor of another. As such, Golenbock’s acts fit squarely within the provenance of CUTPA.

Section 42-110b(a) prohibits unfair competition and unfair or deceptive acts in trade or commerce, including only entrepreneurial or business aspects of health care services.

Klimas v. Connecticut Health Assoc., No. Cv99-0152955s (Nov. 20, 2002) · filed 2002-11-20(a)

Section 42-110b (a) provides that "[n]o person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." ... In the present case, the facts set forth in the complaint fail to allege that an entrepreneurial or business aspect of the provision of services is implicated, as required to support a CUTPA claim against the defendant.

Section 42-110b(a) reaches an assisted living provider’s alleged scheme to induce residents to buy a higher priced service that the provider knows is not higher quality.

Schachter v. Sunrise Senior Living Management Inc · filed 2020-03-16(a)

A valid CUTPA claim against a health care provider requires “an allegation that an entrepreneurial or business aspect of the provision of services is implicated, aside from medical competence or aside from medical malpractice based on the adequacy of staffing, training, equipment or support personnel.” ... Specifically, plaintiffs allege that the Sunrise defendants and Robbins pressured plaintiffs to have Mrs. Schachter moved to the Dementia Floor for improper business purposes and as part of a fraudulent scheme to induce residents into contracting for a higher-priced service that the Sunrise defendants and Robbins knew was not higher quality—in particular, that they knew that the staff were not capable of dealing with residents suffering from dementia. ... At least for initial pleading purposes, the complaint alleges enough—even if barely and inartfully—to state a CUTPA claim against the remaining Sunrise defendants—SSLMI and AL—and Robbins.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce.

Cocchiola Paving v. Peterbilt of So. Ct, No. Cv01-0168579s (Mar. 3, 2003) · filed 2003-03-03(a)

As to the claim for unfair trade practices in violation of CUTPA (count five), General Statutes § 42-110b (a) provides: "No person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." ... Thus, the claim for unfair trade practices in violation of CUTPA is not barred by the economic loss doctrine, and accordingly, the defendant's motion to strike count five is denied.

Section 42-110b does not sustain a CUTPA claim for commercial losses when the claim rests on the same facts as a postacceptance breach of warranty claim.

Flagg Energy Development Corp. v. General Motors Corp. · filed 1998-03-17(a)

These authorities are particularly persuasive in the circumstances of this case, in which the misrepresentation and CUTPA claims depend upon allegations of fact that are identical to those asserted in their claims. ... In this case, the plaintiffs’ claims for fraud and for unfair trade practices cannot be squeezed into the narrow presumption of consistency contained in § 42a-2-721.

Section 42-110b provides the basis for Connecticut unfair trade practices claims, subject to choice of law.

MM Global Services, Inc. v. Dow Chemical Co. · filed 2003-09-12

Further, in counts nine, ten, eleven, and twelve, the amended complaint alleges violations of the Connecticut Unfair Trade Practices Act (“CUTPA”), Conn. Gen.Stat. § 42-110b, and the Connecticut Antitrust Act, Conn. Gen.Stat. §§ 35-26 and 35-28(a). Because these causes of action are based upon elements of unfair competition similar to that which is found in the common law of unfair competition, the same choice of law analysis applies to the CUTPA and Connecticut antitrust claims as applies to the tort claims. ... As the law of India does not authorize an action for unfair trade practices or antitrust, dismissal is required as well for the CUTPA claims and the Connecticut antitrust claim.

Section 42-110b(a) does not apply to violations outside Connecticut unless they are tied to trade or commerce intimately associated with Connecticut or Connecticut choice of law principles require applying Connecticut law.

McCrae Associates, LLC v. Universal Capital Management, Inc. · filed 2010-09-29(a)

CUTPA does not apply to a violation occurring outside Connecticut unless the violation is “tied to a form of trade or commerce intimately associated with Connecticut,” or Connecticut choice of law principles dictate the application of Connecticut law.

Section 42-110b(a) prohibits unfair or deceptive trade practices, and passive conduct violates it only when the defendant had a duty to act.

Berglund v. Cynosure, Inc. · filed 2007-06-22(a)

However, as with Plaintiffs’ fraud claim, Cynosure’s failure to comment on Sona’s protocols can not constitute an unfair or deceptive trade practice unless Cynosure had a duty to comment on those protocols.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of trade or commerce.

Metcoff v. Lebovics · filed 2007-08-16(a)

Stated differently, on the basis of the plaintiffs’ argument, the scope of CUTPA obliterates the corporate shield so that any act of the corporation may be attributed to its directors or officers so that the latter may be held liable under CUTPA. The scope of CUTPA is broad, but not that broad. Certainly, there are circumstances in which the individual acts of a corporate officer or employee may form the basis of a CUTPA violation ... but the actions of an officer, director or employee taken on behalf of the corporation and within the context of his corporate responsibilities are ordinarily outside of CUTPA’s application. ... Thus, it follows in turn that CUTPA does not apply to intracorporate affairs; Ostrowski v. Avery, supra, 243 Conn. 379; or employer-employee relations. Quimby v. Kimberly Clark Corp., 28 Conn. App. 660, 670-71, 613 A.2d 838 (1992).

Section 42-110b(a) allows a claim against individual corporate officers for unfair trade practices without piercing the corporate veil when their conduct is alleged to involve trade or commerce.

Bardon Tool Mfg. v. the Torrington, No. Cv 96-0473455 S (Oct. 31, 1996) · filed 1996-10-31(a)

The defendants cite to no case law supporting the proposition that the corporate veil must be pierced to hold the individual defendants liable for the alleged violations of CUTPA. Indeed, no case law was found supporting the proposition that individual officers of a corporation are shielded from liability under CUTPA. ... Accordingly, the plaintiff has sufficiently alleged a CUTPA violation by the individual defendants in the instant case and the defendants' motion to strike count eight of the complaint is denied.

Section 42-110b(a) prohibits unfair trade practices only when they occur within Connecticut.

Western Dermatology Consultants, P.C. v. VitalWorks, Inc. · filed 2013-10-01(a)

Section 42-110b (a) provides that “No person shall engage in unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce.” ... The meaning of § 42-110b (a) is plain and unambiguous; it proscribes only unfair trade practices occurring within the state of Connecticut.

A CUTPA claim requires a sufficient connection to Connecticut; alleging that the relevant insurance policies were issued there satisfies that requirement at the pleading stage.

Wells Fargo Bank, National Association v. Transamerica Life Insurance Company · filed 2020-02-12(a)

Having determined that Wells Fargo has satisfied CUTPA’s nexus requirement, the Court turns to the merits of Wells Fargo’s CUTPA claim.

Section 42-110b(a) does not reach alleged unfair competition when the defendant is not plausibly alleged to have engaged in trade or commerce in Connecticut.

JKB Daira, Inc. v. OPS-Technology, LLC · filed 2022-09-27(a)

Because JKB has failed to adequately allege that NAS (through the actions of Fukasawa or otherwise) engaged in trade or commerce in Connecticut (even assuming a flexible interpretation of CUTPA’s geographic reach applies), the claim is dismissed.

Section 42-110b(a) can apply to conduct outside Connecticut when the trade or commerce is intimately associated with Connecticut or applicable choice of law principles call for Connecticut law.

Stanley Works Israel Ltd. v. 500 Group, Inc. · filed 2024-08-01(a)

Absent unfair conduct intimately associated with Connecticut and/or application of Connecticut choice of law principles, dictating application of Connecticut law, Plaintiff SWI’s CUTPA claim fails as a matter of law.

When the challenged conduct occurs outside Connecticut and Connecticut choice of law does not apply, a CUTPA claim requires trade or commerce intimately associated with Connecticut.

Norwich Commercial Group, Inc. v. Quintalino · filed 2024-02-26(a)

Thus, Norcom’s CUTPA claim can survive only if “the violation is tied to a form of trade or commerce intimately associated with Connecticut.” ... The core of Norcom’s CUTPA claim relates to allegedly unfair trade practices that occurred in New Jersey, perpetrated by New Jersey residents, regarding allegedly fraudulent invoices for marketing services performed in New Jersey.

Section 42-110b(a) requires the alleged unfair or deceptive practice to involve trade or commerce in Connecticut; an allegation that business decisions originated there does not suffice when the service was offered in Missouri.

Harris v. LAZ Parking LTD, LLC · filed 2025-02-12(a)

The Court concludes that Plaintiff fails to allege that Defendants have engaged in “unfair or deceptive acts or practices in the conduct of any trade or commerce” in the state of Connecticut, as would be required to pursue a claim under CUTPA.

Section 42-110b prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of trade or commerce.

Beckworth ex rel. Discount Trophy & Co. v. Bizier · filed 2014-09-30

The plaintiffs’ individual CUTPA claim arising from the merger of DTC and Plastic Plus and the defendants’ subsequent actions are also outside the scope of CUT-PA. The alleged conduct in violation of the various merger-related agreements, including increasing Marcel Bizier’s salary, reducing Glenn Beckworth’s salary, cancel-ling the Commercial Leases, withholding access to corporate records, and acquiring Barhill, are all disputes that are internal to DTC. Therefore, the CUTPA claims are being dismissed.

Section 42-110b(a) prohibits unfair methods of competition and unfair or deceptive acts or practices in the conduct of trade or commerce.

System Pros, Inc. v. Kasica · filed 2016-07-12(a)

The present case involves an intracorporate dispute between officers and equal shareholders of a corporation. ... Accordingly, the court improperly determined that the exception to the general rule that CUTPA does not apply to intracorporate conflicts was implicated in this case.

A violation of § 42-110b cannot be asserted as a special defense in a foreclosure action.

Bank of America, N.A. v. Aubut · filed 2016-08-02

Against this backdrop, we readily conclude that a CUTPA violation may not be asserted as a special defense.

Section 42-110b provides a cause of action for aiding and abetting liability under CUTPA.

In re Trilegiant Corp. · filed 2014-03-28

Given CUTPA’s legislative history, its remedial purpose that the Connecticut Supreme Court has consistently interpreted broadly, the general consensus of the lower courts in this district, the status of federal law referenced in CUTPA at the time the statute was adopted, and the interpretations of the nearly identical Massachusetts statute, the Court holds that CUTPA provides an independent cause of action for aiding and abetting liability.

Section 42-110b(a) can apply to the sale and marketing of firearms.

Soto v. Bushmaster Firearms International, LLC · filed 2019-03-19(a)

CUTPA prohibits ‘‘unfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce.’’ (Emphasis added.) General Statutes § 42-110b (a). Accordingly, the statute clearly is capable of being applied to the sale and marketing of firearms.

Section 42-110b(a) cannot support a CUTPA claim for abuse of bankruptcy proceedings because the Bankruptcy Code preempts such claims.

Metcalf v. Fitzgerald · filed 2019-09-03(a)

Accordingly, the plaintiff’s state law CUTPA and vexatious litigation claims are in conflict with the Bankruptcy Code provisions regarding sanctions for abuse of process and, thus, are preempted.

A CUTPA claim based on an independent Connecticut law duty that mirrors FDCA requirements is not preempted by the FDCA.

Hope Medical Enterprises, Inc. v. Fagron Compounding Services, LLC · filed 2020-07-07(a)

Accordingly, the Court rejects defendants’ argument that the FDCA preempts Hope’s CUTPA claim.

A private CUTPA claim under § 42-110b(a) requires a causal link between the deceptive practice and the plaintiff’s injury.

Lemoult v. Benedetto, No. Cv99 0173711 S (Jun. 6, 2000) Ct Page 7020 · filed 2000-06-06(a)

The deceptive practice of the defendant described in § 42-110b (a) requires a showing of proximate cause because the language in § 42-110g (a) requires "[a]n actual cause that is a substantial factor in the resulting harm. . . ." Abrahams v. Young Rubicam, Inc. , supra, 240 Conn. 306 .

A CUTPA plaintiff need not prove reliance, but must prove that the challenged practice proximately caused an injury.

In Re: 100% Grated Parmesan Cheese Marketing and Sales Practices Litigation · filed 2019-07-16

As under ICFA, a CUTPA plaintiff need not show reliance, but must prove proximate cause.

A claim under § 42-110b(a) requires harm proximately caused by the challenged unfair or deceptive practices.

Navin v. Wells Fargo Bank, N.A. · filed 2016-08-08(a)

Again, O’Reilly was neither a borrower nor an insured, and paid no mortgage payments or insurance premiums. To the extent the Defendants engaged in these acts, they did not proximately cause O’Reilly any harm.

Section 42-110b(a) is not violated by using different wholesalers to sell different wines when the sales comply with liquor distribution law.

Pere Et Fils v. Matias, No. Cv 99-0585559 (Oct. 3, 2001) · filed 2001-10-03(a)

Related to this issue, of course, is the CUTPA claim, General Statutes § 42-110b (a). Inasmuch as this court finds no violation of § 30-17 , it does not find a violation of CUTPA. While the plaintiff may have sold wines to Worldwide, it did not do so in violation of the liquor distribution statutes. Indeed, there is no prohibition of utilizing different wholesalers to sell different products.

Section 42-110b may prohibit unfair or deceptive conduct even when the same allegations do not establish another statutory or common law tort.

Indiaweekly. Com, LLC v. Nehaflix. Com, Inc. · filed 2009-01-27

Even if the allegations of the CUTPA claim do not rise to the level of statutory or common law torts, they may still violate CUTPA.

Section 42-110b(a) may cover an accountant’s entrepreneurial billing practices.

Freiberg v. Stuart · filed 2019-09-30(a)

At the time the underlying suit was brought, the scope of CUTPA’s application to accountants had not been established by the Connecticut Supreme Court. See Stuart II, 69 A.3d at 334. Under the law as it then existed, an accountant’s entrepreneurial practices for purposes of CUTPA could include “solicitation of business and billing practices.” Haynes v. Yale-New Haven Hosp., 699 A.2d 964, 973 (Conn. 1997). The complaint against Freiberg alleged that he improperly billed the estate for work performed on behalf of Kenneth. Freiberg has not shown that this allegation lacked the factual basis required for probable cause.

Section 42-110b permits a deceptive-labeling claim when an ambiguous front label could mislead a significant portion of reasonable consumers, even if the ingredient list is accurate.

Bell v. Albertson Companies, Inc. · filed 2020-12-07

We therefore join our colleagues in at least three other circuits in holding that an accurate fine-print list of ingredients does not fore- close as a matter of law a claim that an ambiguous front label deceives reasonable consumers.

Section 42-110b(a) permits a deceptive trade practices claim based on a plausibly false product label without requiring the heightened pleading standard of Rule 9(b).

Quinn v. Walgreen Co. · filed 2013-08-07(a)

Therefore, plaintiffs have plausibly alleged that defendant’s claim that the Glucosamine Supplements “help rebuild cartilage” is false or deceptive — particularly given that plaintiffs need not meet Rule 9(b)’s heightened pleading standards. ... In sum, the Court finds plaintiffs have stated plausible claims under Section 349 and CUTPA, and the motion to dismiss those claims is denied.

Section 42-110b(a) permits a deceptive practices claim when sunscreen labeling plausibly leads reasonable consumers to believe the entire product is natural.

Langan v. Johnson & Johnson Consumer Companies · filed 2015-03-31(a)

In sum, plaintiff has alleged a plausible claim that defendant’s statements on the sunscreen products are deceptive in violation of CUT-PA.