A new lawsuit claims that Facebook Inc. overstates the potential reach of its advertisements to boost ad sales and the prices it can charge.

The class action complaint filed Wednesday by a plaintiffs team led by Cohen Milstein Sellers & Toll in the Northern District of California claims that based on publicly available research and the plaintiffs' analysis, Facebook's estimated reach among the key 18- to 34-year-old demographic exceeds the actual population of 18- to 34-year-olds in every state in the U.S.

Facebook representatives didn't respond to a request for comment Thursday morning.

Plaintiffs allege that Facebook's inflation of the demographic, coveted by advertisers since they have disposable income but little brand loyalty, is even higher in some locales. They estimate that Facebook's asserted “potential reach” among 18- to 34-year-olds in Chicago is about four times higher than the number of actual Facebook users in that bracket. The suit claims that the inflation was “apparent” in other age categories as well.

Photo: Video Advertising Bureau

“Because Facebook has inflated its potential reach, plaintiffs and putative class members purchased more advertisements from Facebook and paid a higher price for advertisements than they otherwise would have,” wrote the lawyers at Cohen Milstein, joined in the complaint by Charles Reichmann of Kensington, California, and Michael Rapp of Stecklein & Rapp in Kansas City.

The suit is seeking compensation and injunctive relief barring Facebook from touting the allegedly inflated numbers and forcing the company to audit the estimates under California's Unfair Competition Law.

The named plaintiff in the lawsuit, Kansas resident Danielle Singer, claims that she spent $14,000 on a national Facebook ad campaign promoting her aromatherapy fashionwear company that specifically targeted Chicago, Kansas City and other cities. The complaint says that claims were based in part off of surveys commissioned by the plaintiff of the percentage of Chicago and Kansas City residents who use Facebook. The complaint also cites three confidential witnesses alleged to have worked for Facebook, including a former employee of the company's infrastructure/mapping team who said the company “did not give a sh–” about the actual number of people its ads reached.

Neither Cohen Milstein's Andrew Friedman, who has served as the co-lead plaintiffs counsel in multidistrict litigation targeting health insurance company Anthem with claims related to its massive data breach, nor his co-counsel Reichmann responded to phone messages Thursday morning.

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