from a cosmetics company to bring a § 349 claim against the cosmetics company for deceptive recruiting practices. Id. at 165 (“Although plaintiffs may not necessarily be end-users of the product they are indeed end-users of the distributorships, which they bought and paid for.”). In doing so, the court rejected the argument “that plaintiffs — as middlepersons in a marketing chain retailing defendant’s products to the end-user consumers — cannot be deemed ‘consumers.’ ” Id. Subsequent appellate authority, however, excludes businesses from the definition of “consumer,” stating unequivocally that a consumer is an individual who “purchases goods and services for personal, family or household use.” Sheth v. New York Life Ins. Co., 273 A.D.2d 72, 709 N.Y.S.2d 74, 75 (1st Dep’t 2000) (<HOLDING>); see also Cruz v. NYNEX Info. Res., 263 A.D.2d
holding that parents who brought suit challenging certain religiouslyrelated practices in public schools were without standing to challenge religious practices at baccalaureate programs because their children who were enrolled in elementary schools were not adversely affected by the challenged practice holding that insurance investigators were not agents of the government for fourth amendment purposes because they had an independent reason to investigate the scene holding that plaintiffs had standing because they were directly affected by the laws and practices against which their complaints were directed holding that the challenged practices were not consumeroriented under  349 because they were directed only at prospective insurance agents holding that insurance agents purchase of drinks for prospective insureds did not violate antirebate statute