Idaho Code § 39-8705

Pleading requirements.
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(1) In any action exempted pursuant to section 39-8703 (1), Idaho Code, the complaint initiating such action shall state with particularity the following:
(a) The statute, rule, regulation or other law of Idaho or the United States that was allegedly violated;
(b) The facts that are alleged to constitute a material violation of such law; and
(c) The facts that are alleged to demonstrate that such violation proximately caused actual injury to the plaintiff.
(2) In any action exempted pursuant to section 39-8703 (2), Idaho Code, the complaint initiating such action shall state with particularity facts sufficient to support a reasonable inference that the violation was done with the intent to deceive or injure consumers or with actual knowledge that such violation was injurious to consumers.

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