Consumer Staples, Consumer Discretionary and Food & Staples Retailing were targeted most in September with a combined total of 166 lawsuits (thats 59.5%). Most lawsuits (63%) were filed in New York with California coming in second at 33%. None of the litigated Websites in September seemed to employ Third-party Overlay tools. MANNING LAW, APC filed the most complaints in September with 84 lawsuits in California.