11. Samsung holds the largest share of the United States cellular phone  market.  Samsung’s flagship line of cell phones is the Galaxy S7 series.  Phones in  this series include the Galaxy S7, Galaxy S7 Edge, and Galaxy S7 Active  (collectively, the “S7 Phone”).    12. Samsung’s material misrepresentations of the S7 Phone in a widely  seen advertising campaign give rise to this action.  Samsung’s Representations That Its Galaxy S7 Phones Are Water Resistant   13. Samsung markets the S7 Phone through nationally-televised  advertisements, print advertisements, and online advertisements.     14. Samsung represents in advertisements for the S7 Phone that the phone  is water resistant.    15. Samsung’s claims of water resistance are objective in nature.  As part of  its advertising campaign, Samsung consistently represents that the S7 Phone is  “water resistant up to 5 feet of water for up to 30 minutes.”   26. Plaintiff brings this action pursuant to Federal Rule of Civil Procedure  23 on behalf of the following proposed Class and Subclass:  The Nationwide Class  All individuals in the United States who purchased a new  Galaxy S7, Galaxy S7 Edge or Galaxy S7 Active cellular  phone.  The California Subclass  All individuals in California who purchased a new Galaxy  S7, Galaxy S7 Edge or Galaxy S7 Active cellular phone.   27. Excluded from the proposed Class and Subclass are Samsung’s officers,  directors, legal representatives, successors, and assigns, any entity in which  Samsung has a controlling interest, and any Judges to whom this case is assigned  and their immediate family members.   28. The requirements of Federal Rule of Civil Procedure 23(a), (b)(1),  (b)(2), and (b)(3) are met in this case.   29. Numerosity.  The proposed Class consists of millions of consumers  who purchased S7 phones, making joinder of each Class member impracticable.      37. Plaintiff incorporates the above allegations by reference.    38. Plaintiff brings this cause of action on behalf of the Nationwide Class.   39. Samsung commits fraud by intentionally misrepresenting that the S7  Phone possesses characteristics that it does not possess—namely, that it is water  resistant.  Samsung’s fraud induced Plaintiff and Class members to purchase the S7  Phone.   40. Samsung’s intentional and material misrepresentations include its  advertising, marketing materials and messages, and other standardized statements  claiming the S7 Phone is water resistant.    50. Plaintiff incorporates the above allegations by reference.    51. Plaintiff brings this cause of action on behalf of the California Subclass.   52. Samsung violates the FAL by using false and misleading statements,  and material omissions, to promote the sale of the S7 Phone.  The S7 Phone does  not possess the level of quality or value that Samsung promised.  Samsung  represents in a widespread advertising campaign that the S7 Phone is water resistant  when it is not.   57. Plaintiff incorporates the above allegations by reference.   58. Plaintiff brings this cause of action on behalf of the California Subclass.   Fraud   Violations of the False Advertising Law (“FAL”),  Cal. Bus. & Prof. Code § 17500, et seq.   Violations of the Unfair Competition Law (“UCL”),  Cal. Bus. & Prof. Code § 17200, et seq.  