38. To the extent that the Happy Cows ads imply that California dairy cows are kept in better conditions than anywhere else in the country, for reasons detailed in this complaint, such an implication is false. Higher production levels, higher "cull" rates, diseases and other painful medical conditions, hormones, and dry lots are some of the things California cows endure during their hard lives at dairy operations. In some cases, California dairy cows endure exactly the same intensive conditions the rest of the country’s dairy cows do; in many cases, the conditions are much worse. In almost no case is it a life of ease and luxury. The implication that California dairy cows have it better off than the rest of the country, which is certainly likely to induce a reasonable, but uninformed, conscientious consumer to purchase California dairy products, is simply untrue, and unlawfully deceptive.