CJI-Civ. 29:1

For plaintiff, (name), to recover from defendant, (name), on the claim that defendant

violated the Colorado Consumer Protection Act, you must find that all of the following

have been proved by a preponderance of the evidence:

1. The defendant (engaged in) (or) (caused another to engage in) a deceptive trade

practice;

2. The deceptive trade practice occurred in the course of defendant’s (business)

(vocation) (occupation);

3. The deceptive trade practice significantly impacted the public as actual or

potential consumers of the defendant’s (goods) (services) (or) (property);

4. The plaintiff (was an actual or potential consumer of the defendant’s [goods]

[services] or [property)] (or) (was injured in the course of [insert applicable pronoun]

business or occupation as a result of the deceptive trade practice); and

5. The deceptive trade practice caused actual damages or losses to the plaintiff.

If you find that any one of these statements has not been proved, then your verdict

on this claim must be for the defendant.

On the other hand, if you find that all of these (number) statements have been

proved, (then your verdict must be for the plaintiff) (then you must consider defendant’s

affirmative defense of [insert any affirmative defense that would be a complete defense to

plaintiff’s claim]).

If you find that defendant’s affirmative defense has been proved by a

preponderance of the evidence, then your verdict must be for the defendant.

However, if you find that the affirmative defense has not been proved, then your

verdict must be for the plaintiff.