Draft a complaint for the below scenario:

Bobbi always wanted to own her own pet store so 8 years ago she

opened Bald and Beautiful Pet Store. The store is located in Topeka,

Kansas and specializes in the breeding and sale of hairless cats.

Over the last 3 years, business has been booming as she expanded

to internet sales. In addition to selling her hairless friends, she also

sells hypo-allergenic products to care for them. Obviously, her

primary customers are individuals who are allergic to pet dander

and hair.

In August 2017 Bobbi created a product to reduce pet dander which

she markets via her retail business. The product, Cair (instead of

Nair) is selling like hotcakes as it is all natural and guaranteed to

remove your pet's nasty dander.

SCENARIO

Chris, a hair model for Head and Shoulders shampoo ironically has

an allergy to pet hair and dander so he purchased his hairless cat,

Mike, from Bobbi last year. In January 2018 he began sneezing and

coughing around the cat so he ordered a bottle of Cair. He began

using Cair on or about January 21st and immediately noticed a

reduction in his sneezing and coughing, however, about 2 weeks

later he began to notice his hair thinning. This of course is not good

for a hair model and he's only 35.

Chris immediately looked at the Cair packaging and did not see any

warning signs about its use, nor did he see any ingredients that

might cause hair loss. He then went to his doctor who told him it

appeared to be an allergic reaction, but by this time a week had

passed and he had multiple bald spots on his scalp. As a result of

the hair loss Chris lost his contract with Head and Shoulders and

fell into a pit of despair.

SCENARIO

Not knowing what to do next and fearful he would lose not only his

job, but his home and of course be unable to care for Mike, he

contacted an attorney. The attorney advised him to file a lawsuit

against Bobbi after having Cair analyzed by a chemist.

The chemist, Ike, determined that the ingredients include garlic,

aloe, turmeric, mint, lavender, orange peel, argon oil and trace

elements of calcium hydroxide and sodium hydroxide, neither of

which are listed ingredients on the bottle. The last two ingredients

are known to cause hair loss and in fact are the main ingredients in

the product Nair. The testing was done specifically on the bottle of

Cair Chris purchased.

TNT Manufacturing, Inc., the company Bobbi uses to manufacture

her product is located in Lawton, Oklahoma. TNT not only blends

the ingredients for Bobbi's product, but for many other companies

as well, including Nair.