21.  Tidal was originally launched in 2014 as a high fidelity music-streaming platform  by a company named Aspiro.    22.  Soon thereafter, Project Panther BidCo Ltd., a holding company created by  Defendant SCE (which is controlled by Jay Z) acquired Aspiro.6   50.  Plaintiff Baker-Rhett is a fan of Defendant Kanye West’s music.   64.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   65.  Defendants engaged in advertising and marketing to consumers throughout the  United States, including in California, that encouraged them to subscribe to Tidal by promising  them that The Life of Pablo album would be exclusive to its music-streaming service.   66.  Specifically, Mr. West—via his Twitter account—represented to his fans and the  public at large that the album would only be available through the Tidal platform. Mr. West  made this representation knowing that various media outlets would ensure it was broadcast to  consumers the world over—in particular, consumers of his music. Moreover, SCE and Mr. West  also represented to consumers that Tidal would be the exclusive method of listening to the album  via Tidal’s Twitter feed and other representations made by Tidal. SCE then failed to correct any  statements made by Mr. West, or otherwise indicate that the album would not be a permanent  exclusive on Tidal.   67.  Defendants did so with the intent to induce Plaintiff and the California Subclass  members to subscribe to Tidal’s streaming platform.    68.  Despite their public advertising and marketing statements that The Life of Pablo  would only be available via the Tidal music-streaming platform, The Life of Pablo was not a  Tidal only exclusive (nor did Defendants intend it to be).   75.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   76.  California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200,  et seq., protects both consumers and competitors by promoting fair competition in commercial  markets for goods and services.   77.  The UCL prohibits any unfair, unlawful, or fraudulent business acts or practices.  A business practice need only meet one of these three criteria to be considered unfair  competition.    87.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   88.  To induce Plaintiff and the Class into subscribing to Tidal’s music streaming  service, Mr. West and SCE affirmatively and intentionally misrepresented, made false statements  about, and/or omitted facts about the different mediums through which The Life of Pablo would  be available.    96.  Plaintiff incorporates the foregoing allegations as if fully set forth herein,  excluding paragraphs 60-91.    97.  Defendants have knowingly received and retained benefits from Plaintiff Baker- Rhett and the Class through a fraudulent scheme that would render it unjust to allow them to  retain such benefits. Specifically, Defendants have received and retained Plaintiff Baker-Rhett  and the Class members’ money, personal information, credit card information, and social media  account details, which Plaintiff Baker-Rhett and the Class members submitted under false  pretenses because of the misrepresentation that The Life of Pablo would be available exclusively  through Tidal.    Fraudulent Inducement  (On Behalf of Plaintiff and the Class)   The Tidal Music Service    Unjust Enrichment   In the Alternative to Counts 1-3   (On Behalf of Plaintiff and the Class)   Violation of California’s False Advertising Law  Cal. Bus. & Prof. Code § 17500  (On Behalf of Plaintiff and the California Subclass)   Violation of California’s Unfair Competition Law  Cal. Bus. & Prof. Code §§ 17200, et seq.  (On Behalf of Plaintiff and the California Subclass)  