On February 12, 2015, WLF filed formal comments with the Vermont Attorney General, urging him to substantially revise his proposed regulations designed to implement Act 120, Vermont’s law requiring foods containing genetically modified (GM) ingredients to include GM labeling. WLF argued that, unless the regulations are revised, food manufacturers could face massive—and unwarranted—tort liability. WLF noted that the regulations leave the door open to class-action lawsuits on behalf of consumers who purchase improperly labeled food (with each consumer entitled to recover up to four times the purchase price), even when the manufacturer designated the food for sale in other States and the food was brought into Vermont at the behest of retailers (who are exempted from liability). WLF urged the Attorney General to issue regulations stating that Act 120 does not create a private right of action and that it is up to state officials (not private lawyers) to decide how to enforce the statute.