Professional Documents
Culture Documents
Coinbase Class Action
Coinbase Class Action
23 Defendants.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 2 of 26
1 amount of business throughout the State, and (2) having its principal executive
2 office in the City of San Francisco in the State of California. (California Secretary
3 of State, Corporation – Statement of Information, Entity (File) Number
4 C3548456.)
5 20. Venue is proper in this Court under 28 U.S.C. § 1391(b). Defendants’
6 principal executive office is located in, and Defendant does business in, the
7 Northern District of California.
8 FACTUAL ALLEGATIONS
9 21. Defendant is a publicly-traded corporation involved in the business of
10 cryptocurrency exchange. Defendant provides an online platform where consumers
11 can store their currencies on a digital “wallet,” as well as to buy, sell, spend, and
12 trade cryptocurrency (“platform”).
13 22. Defendant advertises that “[a]pproximately 56 million verified users,
14 8,000 institutions, and 134,000 ecosystem partners in over 100 countries trust
15 Coinbase to easily and securely invest, spend, save, earn, and use crypto.” “About
16 Coinbase, Coinbase powers the cryptoeconomy,” available at
17 https://www.coinbase.com/about (emphasis added).
18 23. Defendant holds itself out as a regulated and fully compliant entity,
19 registered with the United States Department of the Treasury’s Financial Crimes
20 Enforcement Network (“FinCEN”) as a Money Services Business, as that term is
21 defined by FinCEN. “Legal, Is Coinbase regulated?,” available at
22 https://www.coinbase.com/legal/faq.
23 24. Defendant further proclaims that it is “building the cryptoeconomy – a
24 more fair, accessible, efficient, and transparent financial system enabled by
25 crypto.” “About Coinbase,” available at https://www.coinbase.com/about
26 (emphasis added). Defendant further touts,
27 The company started in 2012 with the radical idea that anyone,
28 anywhere, should be able to easily and securely send and receive
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 6 of 26
1 access his funds, or engage in any authorized transactions including but not limited
2 to, investing, spending, saving, earning, using, selling or withdrawing his
3 cryptocurrencies.
4 29. Plaintiff JOSEPH TRESEDER (“Plaintiff TRESEDER”) deposited
5 approximately thirty thousand dollars ($30,000.00) in funds into his Coinbase
6 account in or around December 2020 to purchase Ripple cryptocurrency, which
7 trades under the symbol “XRP.” In or around mid to late January 2021, when
8 attempting to log into his Coinbase account, Plaintiff TRESEDER received an
9 error message that his username and password were invalid. Plaintiff TRESEDER
10 requested an email to reset his password, which never arrived. Plaintiff
11 TRESEDER immediately called a number provided as Defendant’s “Customer
12 Support” phone number and was informed that Defendant could only lock his
13 account, not unlock it. Plaintiff TRESEDER filed an official complaint with
14 Defendant to regain access to his account and funds. Despite sending multiple
15 emails requesting an update from Defendant, Plaintiff TRESEDER received only
16 two automatic responses in which Defendant informed him that the issue was
17 “under review.” Defendant eventually reached out to Plaintiff TRESEDER and
18 stated that he needed to verify his identity before being able to access his account,
19 by logging into the very account from which he was locked out to verify his email
20 address, phone number, and password. Plaintiff TRESEDER completed
21 Defendant’s requested identity verification steps, but remained locked out of his
22 account. Plaintiff TRESEDER was locked out of his Coinbase account for several
23 months, unable to access his funds, or engage in any authorized transactions,
24 including but not limited to, investing, spending, saving, earning, using, selling or
25 withdrawing his cryptocurrencies.
26 30. Plaintiff TRAVIS REECE (“Plaintiff REECE”) opened a Coinbase
27 account in or around February 2021, in which he deposited previously-owned
28 cryptocurrency into Defendant’s platform. After making the deposit, Plaintiff
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 8 of 26
1 REECE logged into his Coinbase account and noticed that the cryptocurrency he
2 had deposited was missing from his account on Defendant’s platform. Plaintiff
3 REECE contacted Defendant regarding his missing cryptocurrency. In response,
4 Defendant informed him that he needed to verify his identity before he can be
5 given access to his funds. Specifically, Defendant required Plaintiff REECE to
6 transfer one thousand four hundred (1,400) Stellar Lumens cryptocurrency, which
7 trades under the symbol “XLM,” worth approximately eight hundred thirty dollars
8 ($830.00) to his Coinbase account in order to verify his identity. Between February
9 2021 and May 2021, Plaintiff REECE reached out to Coinbase’s customer service
10 email address multiple times regarding other methods of proving his identity, and
11 filed an official complaint regarding this issue and the issue of regaining access to
12 his account. Plaintiff REECE had no access to the funds he deposited to his
13 Coinbase account for several months, unable to engage in any authorized
14 transactions, including but not limited to, investing, spending, saving, earning,
15 using, selling or withdrawing his cryptocurrencies.
16 31. Plaintiff DAVID BEAVERS (“Plaintiff BEAVERS”) opened a
17 Coinbase account in or around 2020 and purchased cryptocurrency for several
18 thousand dollars. On January 23, 2021, Plaintiff BEAVERS contacted Defendant
19 regarding what appeared to be mistaken one hundred dollar ($100.00) charges
20 from Defendant. Defendant responded by stating that Plaintiff BEAVERS would
21 be locked out of his account, which in fact occurred. Plaintiff BEAVERS
22 immediately made an inquiry to Defendant’s “help desk,” wherein he was
23 informed that he would receive a response within 4-5 days. After approximately
24 ten (10) days with no response, Plaintiff BEAVERS submitted “tickets” to
25 Defendant’s “help desk” approximately three (3) additional times, with no
26 response to any of his inquiries. On or around February 23, 2021, Plaintiff
27 BEAVERS filed an official complaint with Defendant. Plaintiff BEAVERS was
28 locked out of his Coinbase account for over a month, unable to access his funds, or
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 9 of 26
1 engage in any authorized transactions including but not limited to, investing,
2 spending, saving, earning, using, selling or withdrawing his cryptocurrencies.
3 32. Plaintiff FAZAL US SABOOR ALI (“Plaintiff ALI”) opened a
4 Coinbase account in or around 2018, purchased cryptocurrency from Coinbase,
5 and kept the currency in his Coinbase account. In or around early January 2021,
6 after logging into his Coinbase account, Plaintiff ALI found that he was unable to
7 engage in any authorized transactions, including but not limited to, spending,
8 selling or withdrawing his cryptocurrencies. Plaintiff ALI received an automated
9 message indicating that his account was locked and under manual review, which
10 would take approximately 2 to 3 days. On January 19, 2021, given the lack of any
11 response from Defendant, Plaintiff ALI filed a complaint with Defendant.
12 Defendant responded that it would provide a response to Plaintiff ALI’s complaint
13 in two (2) business days. In an effort to get a response, Plaintiff ALI submitted
14 additional complaints on January 29, 2021, February 7, 2021, and February 20,
15 2021, but did not receive a substantive response to any of his inquiries from
16 Defendant. On February 20, 2021, Defendant responded by stating that it had
17 consolidated the four (4) complaints filed by Plaintiff ALI. Plaintiff ALI was
18 locked out of his Coinbase account for over three (3) months, unable to access his
19 funds, or engage in any authorized transactions including but not limited to,
20 investing, spending, saving, earning, using, selling or withdrawing his
21 cryptocurrencies.
22 33. Plaintiff KEISHA PINKNEY (“Plaintiff PINKNEY”) purchased
23 approximately six thousand dollars ($6,000.00) in multiple types of
24 cryptocurrencies using Coinbase in or around 2020. On February 4, 2021, when
25 attempting to log into her Coinbase account, Plaintiff PINKNEY discovered that
26 her account had been locked, and that she could not access her funds. Plaintiff
27 PINKNEY immediately submitted an official complaint to Defendant, who
28 responded that her account was “cleared” and she should have access to it.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 10 of 26
1 37. Plaintiffs and Putative Class Members that Defendant locked out of
2 their accounts and/or denied access to their funds were often unable to access their
3 accounts for a month or more. As a result, Plaintiffs and Putative Class Members
4 who were locked out and were eventually permitted access to their accounts find
5 that the value of their cryptocurrency had dropped significantly in the interim
6 and/or they had no ability to sell or in any way use the cryptocurrency held in their
7 Coinbase accounts.
8 38. As further result of Defendant locking Plaintiffs and Putative Class
9 Members out of their accounts and/or denying access to their funds, Plaintiffs and
10 Putative Class Members were victims of Defendant’s actions were deprived use of
11 their funds for long periods of time, and could not engage in any authorized
12 transactions including but not limited to, investing, spending, saving, earning,
13 using, selling or withdrawing their cryptocurrencies.
14 39. Despite claiming to implement safety measures to ensure that
15 cryptocurrency is kept as safe as possible, in some cases, Plaintiffs and Putative
16 Class Members who eventually regained access to their accounts and/or funds
17 found that cryptocurrency had disappeared from their accounts. In some
18 circumstances, Plaintiffs and Putative Class Members’ accounts are erased in their
19 entirety without explanation from Defendant.
20 40. As part of the “User Agreement” entered into by Defendant, Plaintiffs
21 and Putative Class Members, Coinbase combines the balance of their customers’
22 “wallets” and hold such funds in a U.S. FDIC-insured bank, or invest those funds
23 in liquid investments, the interest and earnings from which are solely kept and
24 owned by Coinbase. “Legal: Coinbase User Agreement, Part 1: General Use, 2.
25 Wallet and Custodial Services, 2.7 USD Wallet,” available at
26 https://www.coinbase.com/legal/user_agreement/united_states. As a result of
27 locking out Plaintiffs and the Putative Class Members from their accounts unable
28 to withdraw or use their funds in any way, Defendant was unjustly enriched by
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 12 of 26
1 retaining the use of these funds, including the accrual of interest on Plaintiffs’ and
2 the Putative Class’ deposited funds and assets.
3 41. Defendant’s actions have resulted in irreparable harm to Plaintiffs and
4 the Putative Class.
5 CLASS ALLEGATIONS
6 42. This action is brought and may properly proceed as a class action,
7 pursuant to the provisions of Rule 3.765 of the California Rules of Court.
8 43. Plaintiff seeks certification of a Class pursuant to Federal Rules of
9 Civil Procedure Rule 23 and California Civil Code section 1781(a), which is
10 composed of and defined as follows:
11 CLASS: All current and former Coinbase account users and/or consumers
12 in the United States who registered for a Coinbase account at any time on or
after the day four years prior to the date on which this Complaint is filed,
13 who maintained funds and/or cryptocurrency in their Coinbase accounts, and
14 were subsequently prevented from accessing their Coinbase account and/or
deprived of access to their funds or cryptocurrency for any measure of time
15 by Defendant, and were damaged by Defendant’s conduct.
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44. The members of the Putative Class for whose benefit this action is
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brought are so numerous that joinder of all members is impracticable.
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45. There are questions of law and fact common to the members of the
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Putative Class that predominate over questions affecting only individuals. These
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common questions include, but are not limited to:
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A. Whether Defendant owed duties to Plaintiffs and the Putative
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Class, the scope of those duties, and whether Defendant breached
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those duties;
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B. Whether Defendant’s conduct was unfair or unlawful;
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C. Whether Defendant engaged in deceptive conduct;
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D. Whether Defendant has converted the funds belonging to Plaintiffs
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and the Putative Class;
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 13 of 26
1 securely invest, spend, save, earn, and use crypto,” Defendant had a duty to
2 develop, design, test, and monitor their consumers’ access to their Coinbase
3 accounts and/or funds, as well as to create and maintain procedures that would
4 limit disruption to account holders’ ability to access their Coinbase accounts and/or
5 funds. Defendant had a duty to meet its promises and obligations to its millions of
6 consumers.
7 60. Given the nature of Defendant’s business, Defendant also owed
8 Plaintiffs and the Putative Class a duty to provide access to their Coinbase
9 accounts and/or funds.
10 61. Defendant breached its duties to Plaintiffs and the Putative Class by
11 denying them access to their accounts and/ or funds for long periods of time in a
12 market that it knows to be volatile thereby denying Plaintiffs and Putative Class
13 Members from their own funds and assets.
14 62. Defendant further breached its duties by intentionally and/or
15 negligently failing to provide an adequate and timely resolution to Plaintiffs’ and
16 the Putative Class’ inability to access their accounts and/or funds and intentionally
17 and/or negligently failing to respond in a timely fashion to the complaints of
18 Plaintiffs and the Putative Class filed with Defendant’s Customer Support.
19 63. Defendant further breached its duties by failing to promptly enable
20 access to Plaintiffs and the Putative Class accounts and/or funds, especially upon
21 their compliance with Defendant’s identity verification requirements.
22 64. To the extent that Plaintiffs and the Putative Class were locked out of
23 their Coinbase accounts and/or denied access to their funds due to a security
24 breach, Defendant breached its duty to provide a safe and secure platform for
25 Plaintiffs and the Putative Class and/or to inform Plaintiffs and Putative Class
26 Members of such breach.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 16 of 26
1 76. Plaintiff and the Putative Class entered into written agreements with
2 Defendant, specifically a “User Agreement” upon their registration for a Coinbase
3 account. Attached herein as “Exhibit A” is a true and correct copy of the
4 “Coinbase User Agreement,” last updated April 9, 2021, available at
5 https://www.coinbase.com/legal/user_agreement/united_states. Plaintiff and
6 Putative Class Members were presented this agreement on a take-it-or-leave it
7 basis, or slightly modified versions thereof, when opening their Coinbase accounts.
8 77. Defendant breached its User Agreements by, among other things,
9 failing to discharge its obligations and provide services it promised such as (1)
10 consumers’ access to their Coinbase accounts and/or funds; (2) safety and security
11 of consumers’ accounts and funds; (3) creating and implementing an adequate plan
12 and/or procedure that would limit disruption to account holders’ ability to access
13 their Coinbase accounts and/or funds, and engage in their authorized use; and (4)
14 reinstating consumers’ access to their accounts and/or funds, upon the prompt
15 verification of their identities.
16 78. Plaintiffs and the Putative Class, as part of their agreement to open an
17 account with Defendant, complied with Defendant’s “Identify Verification”
18 procedures.
19 79. Plaintiffs and the Putative Class also completed additional “Identity
20 Verification” procedures as requested by Defendant in order to regain access to
21 their accounts and/or funds, once they had been locked out.
22 80. Defendant nevertheless failed to provide Plaintiffs and the Putative
23 Class access to their accounts and/or funds, despite their compliance with the
24 “Identity Verification” requirements of the User Agreement and failed to respond
25 to Plaintiffs and the Putative Class complaints in a timely fashion to address
26 ongoing account lock outs.
27 81. As a result of Defendant’s breach of its duties, obligations and/or
28 promises, Plaintiffs and the Putative Class were harmed, including but not limited
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 19 of 26
1 to the loss of use of their Coinbase accounts and/or funds, for long periods of time,
2 inability to access their funds, inability to withdraw their funds, and diminution of
3 the value of their funds. Plaintiffs and the Putative Class also suffered additional
4 damages such as nominal damages, and damages in reliance to the agreement.
5 82. As a direct and proximate cause of Defendant’s breach of its fiduciary
6 duties, Plaintiffs and the Putative Class sustained damages as alleged herein,
7 including attorney’s fees and costs as provided by contract (Exhibit A). Plaintiffs
8 and Putative Class Members are entitled to damages, pre-judgment interest,
9 attorney’s fees and costs pursuant to California Civil Code section 1021.5, or as
10 otherwise provided by statute or contract.
11 FOURTH COUNT
12 (Unjust Enrichment)
13 83. Plaintiffs reallege and incorporate by reference the preceding
14 paragraphs of this complaint as if fully set forth herein.
15 84. Plaintiffs and the Putative Class conferred a benefit upon Defendant
16 by depositing currency and cryptocurrency into Defendant’s platform.
17 85. As part of the “User Agreement” entered into by Defendant, Plaintiffs
18 and Putative Class Members, Coinbase combines the balance of their customers’
19 “wallets” and hold such funds in a U.S. FDIC-insured bank, or invest those funds
20 in liquid investments, the interest and earnings from which are solely kept and
21 owned by Coinbase. “Legal: Coinbase User Agreement, Part 1: General Use, 2.
22 Wallet and Custodial Services, 2.7 USD Wallet,” available at
23 https://www.coinbase.com/legal/user_agreement/united_states.
24 86. During the time in which Plaintiffs and the Putative Class were
25 prevented from accessing their funds, Defendant was unjustly enriched by
26 retaining the use of these funds, including the accrual of interest on Plaintiffs’ and
27 the Putative Class’ deposited funds and assets, such as the funds deposited by
28 Plaintiffs and the Putative Class’ Coinbase USD Wallets.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 20 of 26
1 SIXTH COUNT
2 (Violation of the Unfair Competition Law)
3 93. Plaintiffs reallege and incorporate by reference the preceding
4 paragraphs of this complaint as if fully set forth herein.
5 94. Business and Professions Code section 17200, et seq., also known as
6 the Unfair Competition Law (“UCL”), prohibits unfair competition in the form of
7 any unlawful, unfair, or fraudulent business acts or practices.
8 95. Business and Professions Code section 17204 allows “any person who
9 has suffered injury in fact and has lost money or property as a result of such unfair
10 competition” to prosecute a civil action for violation of the UCL.
11 96. Defendant’s acts and omissions as alleged herein, including its breach
12 of its fiduciary duties to its consumers, serve as unlawful predicate acts and
13 practices for purposes of Business and Professions Code sections 17200, et seq.,
14 and are not outweighed by any countervailing benefits to consumers.
15 97. As a result of these actions, including locking out Plaintiffs and the
16 Putative Class from accessing their account and preventing them from having any
17 authorized use of their funds, Defendant is able to unfairly compete with other
18 comparable companies in violation of Business and Professions Code sections
19 17000, et seq. and 17200, et seq. Due to these unlawful, unfair, and/or fraudulent
20 business practices, Defendant has gained a competitive advantage over other
21 comparable companies.
22 98. The victims of these unlawful, unfair, and/or fraudulent business
23 practices include, but are not limited to, Plaintiffs and the Putative Class,
24 competing cryptocurrency exchange platforms providing similar services as
25 Defendant, and the general public. Plaintiffs are informed and believe, and based
26 thereon alleges, that Defendant performed the alleged acts with the intent of
27 gaining an unfair competitive advantage and thereby injuring Plaintiffs and the
28 Putative Class, other competitors, and the general public.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 22 of 26
1 99. Plaintiff’s success in this action will enforce important rights affecting
2 the public interest and public policy. In this regard, Plaintiffs sue on behalf of
3 themselves and the public.
4 100. Business and Professions Code section 17203 provides that a court
5 may make such orders or judgments as may be necessary to prevent the use or
6 employment by any person of any practice which constitutes unfair competition.
7 Injunctive relief is necessary and appropriate to prevent Defendant from repeating
8 their unlawful, unfair, and fraudulent business acts and business practices alleged
9 above.
10 101. Business and Professions Code section 17203 provides that the Court
11 may restore to any person in interest, any money or property that may have been
12 acquired by means of such unfair competition. Plaintiff and the Putative Class are
13 entitled to restitution pursuant to Business and Professions Code section 17203 for
14 their funds deposited in the Coinbase platform and were unlawfully withheld from
15 them when locked out of long periods of time, the losses incurred as a result of
16 Plaintiffs and the Putative Class being locked out of their accounts and/or funds,
17 and the fair value of other losses alleged herein, during the four-year period prior
18 to the filing of this complaint. All remedies are cumulative pursuant to Business
19 and Professions Code section 17205.
20 102. Business and Professions Code section 17202 provides:
21 “Notwithstanding section 3369 of the Civil Code, specific or preventative relief
22 may be granted to enforce a penalty, forfeiture, or penal law in a case of unfair
23 competition.” Plaintiffs and the Putative Class are entitled to enforce all applicable
24 penalty provisions of the Labor Code pursuant to Business and Professions Code
25 section 17202.
26 103. Plaintiffs and the Putative Class request injunctive relief pursuant to
27 Business and Professions Code section 17203 to enjoin Defendant from continuing
28 the unfair/unlawful business practices alleged herein.
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 23 of 26
1 104. Plaintiffs herein take upon enforcement of these laws and lawful
2 claims. There is a financial burden involved in pursuing this action. The action is
3 seeking to vindicate a public right, and it would be against the interests of justice to
4 penalize Plaintiffs by forcing Plaintiffs to pay attorneys’ fees from the recovery in
5 this action. Attorneys’ fees are appropriate pursuant to Code of Civil Procedure
6 section 1021.5.
7 SEVENTH COUNT
8 (Violations of the Consumers Legal Remedies Act)
9 105. Plaintiffs reallege and incorporate by reference the preceding
10 paragraphs of this complaint as if fully set forth herein.
11 106. Defendant’s acts and omissions as alleged herein were intended to
12 deceive Plaintiffs and the Putative Class, and have resulted in harm to Plaintiffs
13 and the Putative Class.
14 107. Defendant’s actions as alleged herein violated, and continue to
15 violate, California Civil Code section 1750, et seq. also known as the Consumers
16 Legal Remedies Act (“CLRA”) including section 1770(a)(5) for making
17 representations that their services have characteristics, uses, or benefits which they
18 do not, section 1770(a)(7) for making representations that their services are of a
19 particular quality, which they are not, and section 1770(a)(9) for advertising
20 services with intent not to sell them as advertised.
21 108. Pursuant to California Civil Code section 1782, attached herein as
22 “Exhibit B” is a true and correct copy of Plaintiff’s Notice of Violation of the
23 California Consumer Legal Remedies Act (California Civil Code section 1750 et
24 seq.) sent to Defendant on June 4, 2021. Once the time period set forth in
25 California Civil Code section 1782(a) have expired after providing Notice and
26 Demand to Defendant, Plaintiffs will amend this cause of action to seek recovery
27 of damages pursuant to California Civil Code section 1782(d).
28 ///
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 24 of 26
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Kevin Mahoney, Esq.
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Katherine J. Odenbreit, Esq.
20 Kate Nicole G. Blanco, Esq.
Attorneys for Plaintiffs MICHAEL LEONE,
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JOSEPH TRESEDER, TRAVIS REECE, DAVID
22 BEAVERS, FAZAL US FABOOR ALI, and
KEISHA PINKNEY, as individuals and on behalf
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of all others similarly situated
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CLASS ACTION COMPLAINT
Case 3:21-cv-04286 Document 1 Filed 06/04/21 Page 26 of 26
1 JURY DEMAND
2 Plaintiffs demand a trial by jury on all issues subject to trial.
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_________________________________
Kevin Mahoney, Esq.
9 Katherine J. Odenbreit, Esq.
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Kate Nicole G. Blanco, Esq.
Attorneys for Plaintiffs MICHAEL LEONE,
11 JOSEPH TRESEDER, TRAVIS REECE, DAVID
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BEAVERS, FAZAL US FABOOR ALI, and
KEISHA PINKNEY, as individuals and on behalf
13 of all others similarly situated
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CLASS ACTION COMPLAINT