20.  In late 2019, an outbreak of respiratory illness resulting from a novel coronavirus was  first identified in Wuhan City, Hubei Province, China.  That illness, now known as COVID-19, has  spread across the world.  COVID-19 has been designated a pandemic by the World Health  Organization, the first pandemic resulting from a coronavirus.  As of the date of this Complaint,  more than 2.43 million confirmed cases of COVID-19 have been reported across the globe, and more  than 169,859 persons have died from their illness.6     21.  California was one of the first states affected by the pandemic and one of the first to  see COVID-19 cases.  On January 17, 2020, travel to California was affected when the CDC began  health screenings of passengers on direct or connecting flights from Wuhan to the “three U.S.  airports that receive most of the travelers from Wuhan, China: San Francisco (SFO), New York  (JFK), and Los Angeles (LAX) airports.”7  The third confirmed COVID-19 case in the United States  was an Orange County man diagnosed on January 26, 2020.  Shortly thereafter, the State Department  evacuated 195 U.S. citizens and from Hubei Province, placing them in isolation at the March Air  Reserve Base in Riverside, California.  Around the same time, new COVID-19 cases emerged in  Santa Clara County in and around “Silicon Valley.”  On January 31, the CDC confirmed that a Santa  Clara man had tested positive for the virus, and an unrelated Santa Clara women tested positive two  days later.  Around the same time, two additional cases were confirmed just south in San Benito  County.  By February 12, 2020, eight of the nation’s fourteen confirmed COVID-19 patients were in  California, indicating that the virus was clustering in the state.8     77.  Plaintiffs bring this proposed action on behalf of themselves and, pursuant to Rules  23(a), 23(b)(2) & 23(b)(3) of the Federal Rules of Civil Procedure, on behalf of the following class  (collectively, the “Class”):    All persons who purchased in California any Protected Product on  Amazon.com on or after February 4, 2020 at a price 10 percent greater  than the price charged on Amazon.com for the same Protected Product  (a) on February 2, 2020, or (b) immediately prior to any declaration of  a State of Emergency relating to the COVID-19 crisis.     86.  Plaintiffs repeat and re-make every allegation above as if set forth herein in full.   87.  California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200, et  seq., proscribes acts of unfair competition, including “any unlawful, unfair or fraudulent business act  or practice.”   88.  Any violation of California Penal Code § 396 “constitute[s] an unlawful business  practice and an act of unfair competition within the meaning of Section 17200 of the Business and  Professions Code.”  Cal. Penal Code § 396(i).     93.  Plaintiffs repeat and re-make every allegation above as if set forth herein in full.   COMPETITION LAW (CAL. BUS. & PROF. CODE § 17200) ......................................... 42  SECOND CAUSE OF ACTION NEGLIGENCE AND NEGLIGENCE PER SE .......................... 43  THIRD CAUSE OF ACTION UNJUST ENRICHMENT ............................................................... 45  NEGLIGENCE AND NEGLIGENCE PER SE   Outbreak of Covid-19 and the Early Impact on California’s Population   V.  CLASS ACTON ALLEGATIONS ....................................................................................... 38  VI.  VIOLATION OF CALIFORNIA’S UNFAIR COMPETITION LAW  (CAL. BUS. & PROF. CODE § 17200)  