In Q1, U.S. District Judge Lindsay Jenkins dismissed a proposed class action lawsuit alleging that Estée Lauder's virtual "try-on" tool violated Illinois' biometric privacy law. The lawsuit claimed that Estée Lauder and its brands, including Bobbi Brown, Smashbox, and Too Faced, collected facial scans without proper consent. Staying in the US, a class action lawsuit was filed in a New York federal court, alleging that Neutrogena's T/Sal Therapeutic Shampoo was falsely marketed as "preservative free." Lastly, L'Oréal settled a case brought by the University of Massachusetts and Carmel Laboratories over patents related to the use of adenosine in its Revitalift moisturizer. In Q2, a U.S. District Judge rejected a motion by law firm Zimmerman Reed to force L'Occitane into arbitration with some 3,000 customers.