(Declaratory Judgment)   (Negligence)   (Violation of Unfair Competition Law  California Business and Professional Code Section 17200, et seq.)   11.  Seagate has represented that on or about March 1, 2016, it discovered that it was  the victim of a “phishing” scam (the “Data Breach”).  According to Seagate, the Data Breach  resulted in the release of PII for approximately 10,000 of its and its affiliates’ current and  former employees.  In the Data Breach, Seagate provided to unknown cybercriminals the 2015  Forms W-2 data for all Employees.  The Form W-2 data disclosed the Employees’ names,  addresses, compensation and, most importantly, Social Security numbers.   41.  Plaintiffs reallege and incorporate by reference all prior allegations as if fully set  forth herein.   42.  This cause of action is brought on behalf of all of the sub-classes.   51.  Plaintiffs reallege and incorporate by reference all prior allegations as if fully set  forth herein.   52.  This cause of action is brought on behalf of all the classes.    53.  Seagate engaged in unfair, unlawful and fraudulent business practices in  violation of the Unfair Competition Law, Cal. Bus. & Prof. Code § 17200, et seq. (“UCL”).   Seagate’s acts, omissions and conduct constitute unfair, unlawful and fraudulent business  practices under the UCL.     54.  Seagate’s practices were unlawful and in violation of Civil Code section  1798.81.5(b) because Seagate failed to take reasonable measures in protecting Plaintiffs’ and  the class members’ PII.   55.  Seagate’s practices were also unlawful and in violation of Civil Code section  1798.82 because Seagate unreasonably delayed informing Plaintiffs and the class members  about the breach of security after Seagate knew the breach occurred.   63.  Plaintiffs reallege and incorporate by reference all prior allegations as if fully set  forth herein.   64.  This cause of action is brought on behalf of all the classes.   65.  As set forth above, Plaintiffs and the class members have valid claims against  Seagate for negligence and violations of the UCL.  An actual controversy has arisen in the wake  of Seagate’s Data Breach regarding Seagate’s current obligations to provide reasonable data  security measures to protect the PII of Plaintiffs and the class members.   