(all Class Members)   10. When Plaintiff clicked on the “Cancel Air Reservation” section of Southwest.com,  the website showed his itinerary, explained Southwest’s cancellation rules and procedures,  and prompted him to “Please select what you would like to do with the balance of these  funds”: “Nonrefundable” – “These funds will be held for future use.”  Believing  Southwest’s representation that his entire payment was “nonrefundable,” Plaintiff accepted  a “"Travel Funds"” credit for the entire amount of his prepayment ($536.98).     11. Plaintiff is unable to use the full “"Travel Funds"” credit and part of his “"Travel  Funds"” will expire on May 8, 2021.   12. Contrary to Southwest’s statement, the TSA fee is indeed refundable, and Southwest  has itself promised to refund that fee as required by law.  The subsequent sections explain  these obligations.  Southwest’s Contract of Carriage promise to refund a TSA fee   to a passenger when required by governing regulation   14. This provision is no great victory for passengers—it obliges Southwest only to  refund those fees for which governing regulations already require a refund.  But that is  exactly the situation for the TSA fees that Plaintiff prepaid.  Governing regulation requires Southwest to refund a TSA fee   to a passenger when the passenger cancels travel   15. Indeed, governing law requires refunds.  See 49 CFR § 1510.9(b) (emphasis added):   Any changes by the passenger to the itinerary are subject to  additional collection or refund of the security service fee ... as  appropriate.  Plaintiff canceled his itinerary by cancelling it in full.  This entirely obviates the basis for  the security fee, per the calculation in 49 CFR § 1510.5(a).  As a result, 1510.9(b) obliged  Southwest to refund the fee – not to convert it into a “"Travel Funds"” credit for  Plaintiff’s possible future use, but to return it to the Plaintiff     16. Secondary authorities confirm the plain meaning of 1510.9(b).  The DHS Office of  Audits in 2006 prepared a Review of the Transportation Security Administration Collection  of Aviation Security Service Fees (DHS OIG-06-35).  At page 9 (PDF page 13), the DHS  report summarizes: “air carriers have no grounds to keep fees of any kind that are owed to  the ticket purchaser or TSA.”   19. Plaintiff re-alleges the foregoing paragraphs of this Complaint as though fully set  forth herein.   20. In ordinary circumstances, a large number of passengers buy tickets for travel on  Southwest, but then do not travel.  In such circumstances, Southwest systematically fails to  refund their TSA fee to them as required by law.   21. The COVID-19 pandemic has expanded the set of passengers who do not use their  pre-purchased travel.     23. This action is properly maintained as a class action.  The Class satisfies all of the  requirements of Rule 23 for maintaining a class action.   24. Ascertainability.  The members of the Class (collectively “class members”) are  known to Southwest.  Their identities are recorded in Southwest’s business records.   Moreover, the Class Definition enables every putative class member to identify himself or  herself as a member of the Class.   25. Numerosity.  The Class is so numerous that joinder of all members is impracticable  and the disposition of their claims in a class action will provide substantial benefits to the  parties and the Court.  Plaintiff believes there are tens of thousands of members of the  Class, who are geographically dispersed throughout the United States.   26. Existence and predominance of common questions of law or fact.  There are  questions of law or fact that are common to the Class, which predominate over questions  affecting any individual class member.       28. Typicality.  The claims of Plaintiff are typical of those of the class members, and  Defendant has no defenses that are unique to Plaintiff.    29. Adequacy of representation.  Plaintiff will fairly and adequately protect the  interests of the class and has no interests adverse or antagonistic to the interests of the other  members of the class.  Plaintiff has retained competent counsel who are experienced in the  prosecution of consumer class action litigation.   30. Superiority.  A class action is superior to other methods for the fair and efficient  adjudication of the claims asserted herein.  A class action will permit a large number of  similarly situated persons to prosecute their common claims in a single forum  simultaneously, efficiently, and without the duplication of time and expense that the  prosecution of numerous individual actions would entail.  Class treatment will also permit  the adjudication of relatively small claims by many class members who could not otherwise  afford to seek legal redress for the wrongs complained of in this action.  Plaintiff does not  anticipate any unusual difficulties in the management of this class action.  31. Plaintiff re-alleges the foregoing paragraphs of this Complaint as though fully set  forth herein.   33. Southwest nonetheless refused and failed to refund the TSA fee.  In breach of its  contracts with class members, Southwest represented that the TSA Fee was nonrefundable  and issued a Southwest "Travel Funds" credit instead of refunding the TSA Fee.    34. As a direct result of Southwest’s breach of the Contract, Plaintiff and all other  members of the Class suffered actual damages in the form of being denied their refundable  TSA Fees and incurred reasonable and foreseeable economic harm.  9. On February 7, 2020, Plaintiff Jason Steele purchased a ticket to fly on Southwest  Airlines.  He paid $536.98, an amount that included airfare, all taxes, and a TSA fee.  Due  to the COVID-19 pandemic and other circumstances, Mr. Steele was unable to travel as  booked and he cancelled the ticket.  