Plaintiffs pled a viable claim for false advertising under the UCL by the defendant manufacturers of pet food labeled “prescription” pet food. Under the reasonable consumer test, use of the word “prescription” was misleading in suggesting that the pet food contrained medicine or drugs. The fact that defendants sold their products, at least initially, only through vets did not make the ads, which were directed at the general public, not just vets, less misleading. Vets may not have been misled, but the reasonable consumer was likely to be. Plaintiffs satisfied Rule 9(b) requirements by alleging the “prescription” representation and the fact that the so-call prescription pet food has substantially similar ingredients as non-prescription pet food. They also sufficiently alleged actual reliance by stating that they would not have paid the higher price of prescription pet food but for the misleading labeling. Moreover, actual reliance may be inferred at the motion to dismiss stage from the misrepresentation itself–beyond which it is plausible that plaintiffs would not have paid a higher price for similar pet food for any reason other than its prescription label. See also Vansant v. Hill’s Pet Nutrition, Inc. (7th Cir 2019) 934 F.3d 730 (upholding a claim that the same “prescription” label was misleading under Illinois’ consumer protection statute).)