Page:International Code Council v. UpCodes (2021).pdf/5

 outdated code.” (Complaint ¶ 50.) Likewise, Defendants have claimed on Twitter that their codes are “kept up-to-date with all the amendments integrated natively into the code.” ( Id. ¶ 51.) And according to ICC, UpCodes falsely asserts that it provides the building industry with “‘a complete understanding of relevant material’ for their projects” ( id. ¶ 52), and helps customers “surface the most critical code sections” ( id. ¶ 56).

ICC provides screenshots of the UpCodes website in which the following additional claims are made: ( Id. ¶ 52.) ICC further alleges that customers rely on these representations and cites a customer review in which the customer stated that he is “much more comfortable knowing that my team is working off the most up-to-date codes.” ( Id. ¶ 59.)
 * “Your code library in one place, always up to date”;
 * “… never work from outdated code”;
 * “Codes are organized by state and jurisdiction to provide a full understanding of the applicable codes for your project”;
 * “Understand all the requirements for your jurisdiction in one place.”
 * 2. Representations of Amendment Integration

ICC alleges that Defendants “falsely advertise and promote that UpCodes offers ‘Integrated Amendments,’” as