18.  Best Buy is an international retailer of consumer electronics. With over 1,000  stores located within the United States, and 30 stores in Georgia alone, Best Buy is one of the  largest and most prominent retailers in the nation.     20.  By deceiving consumers about the Products’ mAh, Best Buy is able to sell more  of, and charge more for, the Products than it could if they were labeled accurately. Further, Best  Buy is incentivized to mislead consumers to take away market share from competing products,  thereby increasing its own sales and profits.   21.  All of the Products are marketed, sold, and advertised in a substantially similar  manner, and there is no non-trivial difference amongst the models other than the differences in  purported mAh.    23.  Best Buy draws attention to its Products’ mAh by prominently displaying the  mAh rating on advertising materials and the product package.   B ) The Products Cannot Deliver The Full mAh Amount To PEDs As Advertised   24.  Best Buy knew at the time it sold the Products that they were incapable of  delivering the mAh it promised.   25.  In very basic terms, the Products consist of an internal battery cell (or series of  batteries’ cells) and a circuit board that controls the technology. The Products’ circuit boards  convert the internal batteries’ charge to a voltage that PEDs, like cell phones, can accept.   27.  This conversion and distribution process necessarily reduces the amount of mAh  delivered into a PED.   28.  Reasonable consumers such as the Ms. Robinson read the advertised mAh and  would expect and understand that the Products can actually deliver that mAh amount, not that  they are incapable of doing so.   29.  Because of the process described above, Best Buy knows the Products are  technologically incapable of delivering the amount of mAh Best Buy represents.   30.  Ms. Robinson hired an experienced and reputable outside laboratory to perform  tests on the same model of INSIGNIA battery she purchased (INSIGNIA 8000), as well as on the  2600 mAh Product models. These tests were done in accordance with recognized engineering  standards.   32.  On November 7, 2018, while in Georgia, Ms. Robinson saw and relied on Best  Buy’s mAh representations about the INSIGNIA 8000.    33.  On INSIGNIA’s package, Best Buy said that the INSIGNIA 8000 had “8000  mAh.”    34.  Ms. Robinson purchased the INSIGNIA 8000.   35.  After purchasing the INSIGNIA 8000, Ms. Robinson was disappointed to find she  was forced to recharge the INSIGNIA 8000 more often than she expected.   36.  Ms. Robinson, like any reasonable consumer and member of the putative classes,  would not have purchased the Product, or would have paid less, had she known the truth about  its mAh.   37.  On July 9, 2019, Ms. Robinson’s counsel sent Best Buy a letter informing them of  the harm caused by Best Buy’s deceptive acts.   38.  Best Buy has not remedied the situation for Ms. Robinson or the classes that Ms.  Robinson represents.   40.  Additionally, Ms. Robinson brings this action pursuant to Rule 23 of the Federal  Rules of Civil Procedure on behalf of herself and similarly situated individuals within certain  States (the “Multi-State Class”), defined as follows:  All consumers who purchased the Products  in  California, Florida,  Georgia, Illinois, Massachusetts, Michigan, Minnesota, New Jersey,  New York, North Carolina, Ohio, and Washington.    Excluded from the Multi-State Class are any of Best Buy’s officers,  directors, or employees; officers, directors, or employees of any  entity in which Best Buy currently has or has had a controlling  interest; and Best Buy’s legal representatives, heirs, successors, and  assigns.   41.  The Georgia Class and Multi-State Class are referred to collectively as the  “Classes.”     42.  Ms. Robinson reserves the right to later alter the Classes’ definitions in any  manner allowed by law.   43.  At this time, Ms. Robinson does not know the exact number of members of the  Classes; however, based on Best Buy’s sales, market research, and publicly available  information, Ms. Robinson believes that the number of members of the Classes are so numerous  that joinder of all members is impractical. Best Buy is a major player in the power bank market.   45.  Ms. Robinson’s claims are typical of those of the Classes. Like all members of the  Classes, Ms. Robinson purchased Best Buy’s Products bearing the claim that the Product’s  ability to deliver mAh was greater than it really is. And like all Class Members, Ms. Robinson  sustained damages from Best Buy’s wrongful conduct. There is nothing unusual or distinct about  Ms. Robinson’s claims compared with others who meet the class definitions.   46.  Ms. Robinson will fairly and adequately protect the interests of the Classes, and  has retained counsel experienced in complex consumer products class actions. Ms. Robinson has  no interests which conflict with those of the Classes.   48.  No member of the Classes has a substantial interest in individually prosecuting a  separate action. The damages for each individual member of the Classes likely will be relatively  small compared with the costs of this complex litigation. Thus, absent a class mechanism, it  would be virtually impossible for class members to obtain an effective remedy.   49.  The prerequisites to maintaining a class action for injunctive or equitable relief  are met, as Best Buy has acted or refused to act on grounds generally applicable to the members  of the Classes, thereby making appropriate final injunctive or equitable relief with respect to the  Classes as a whole.   50.  The prosecution of separate actions by members of the Classes would create a risk  of establishing inconsistent rulings and/or incompatible standards of conduct for Best Buy. For  example, one court might enjoin Best Buy from selling any Products, whereas another might  require label changes. Additionally, individual actions could be dispositive of the interests of the  members of the Classes even where certain members of the Classes are not parties to such  actions.   51.  Best Buy’s conduct is generally applicable to the Classes as a whole and Ms.  Robinson seeks, inter alia, equitable remedies with respect to the Classes. As such, Best Buy’s  systematic policies and practices make declaratory relief with respect to the Classes as a whole  appropriate.  A) BEST BUY Markets Its Products By Emphasizing Their mAh.  