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California Consumers Agree to Settle State-Wide Class Action Lawsuit Against Advanced Medical Optics Concerning Recalled Contact Lens Solution

Orange County, California, November 30, 2011 – Attorneys for California consumers who purchased the recalled Complete® MoisturePlusTM contact lens solution announced today that they have agreed to settle a Court-certified class action consumer fraud lawsuit against Advanced Medical Optics (now known as Abbott Medical Optics, “AMO”) concerning its sale of the solution. The settlement is subject to court approval. The lawsuit is styled Lazar vs. Advanced Medical Optics, Orange County Superior Court Case No. 07CC01296.

In May 2007, AMO recalled Complete® MoisturePlusTM after a report issued by the United States Centers for Disease Control and Prevention noted an increased statistical risk of developing a parasitic eye infection called Acanthamoeba keratitis in contact lens wearers who used the product.

Plaintiffs Nicole Lazar and Cameron Smith filed the lawsuit on behalf of all California consumers who purchased the product. Plaintiffs allege that AMO misled consumers into falsely believing that the product would effectively “disinfect” their contact lenses when in fact the solution did not disinfect against Acanthamoeba and other harmful organisms that are known to contaminate contact lenses. The plaintiffs sought a refund of the money that California consumers paid to purchase the product. AMO denies Plaintiffs’ allegations and claims that Complete® MoisturePlusTM met all FDA requirements.

Plaintiffs and AMO reached the settlement after four years of litigation, several mediation sessions, and just days before trial was scheduled to start. The settlement imposes the following obligations on AMO:

  • AMO will give a 100% cash refund for every bottle of Complete® MoisturePlusTM that a California consumer bought if the consumer can document the purchase through a receipt or a bottle;
  • If a consumer cannot document his purchase of the product through a receipt or a bottle but attests to the purchase, AMO will give the consumer a coupon that is “as good as cash” toward the purchase of certain other AMO products;
  • AMO will pay the difference between the total of the cash refunds paid and $650,000 to Guide Dogs of America and Children’s Vision First;
  • AMO shall not sell Complete® MoisturePlusTM in California;
  • If AMO applies to the FDA during the next three years for clearance to market a multi-purpose disinfecting solution that employs a “no-rub” and “no-rinse” regimen, AMO shall request the FDA’s permission to include on the product label specific cautionary language concerning the disinfecting ability of the solution.

Eligible consumers can obtain the 100% cash refund or the “good as cash” coupon by making a claim through the Court-supervised claim process.

Complete information about the claim process, a claim form, and the complete terms of the settlement are available online at

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