Perkins Coie was quoted in the Food Processing article, "FDA Letters, Lawsuits Meet the First Generation of CBD Products," regarding the FDA warning letters that were issued to companies selling products containing CBD at the end of November, which explicitly stated that the FDA has not proclaimed CBD as safe yet.

"The Perkins Coie law firm warned, “Manufacturers of CBD products should be aware of the likelihood of increased litigation, especially class actions, resulting from the FDA’s recent actions. Consumer class actions are often intertwined with government enforcement activity and proclamations.” For a number of reasons, those are not likely at the federal level, but “experience from other FDA-regulated industries, particularly food, suggests that state attorneys general and private citizens might use state [consumer protection] laws as a vehicle for class actions against such companies.”