22. From the time the Safe Rides program launched until approximately June 21, 2014, drivers on the LIberX platform did so under a form contract with Rasier, LLC; that contract—first implemented in 2013 was called the "Transportation Provider Service Agreement." (A true and correct copy of that agreement is attached to this Complaint as E3chibit B and will be referred to as the "2013 Agreement.").  23. From approximately June 21, 2014 until approximately November 10, 2014, drivers on the LIberX platform did so under an identical form contract, which geographically assigned one of two Rasier entities as the other party (Rasier-CA, LLC, for California drivers and Rasier, LLC, for the rest of the United States); that contract was called the "Rasier Software Sublicense & Online Services Agreement." (A true and correct copy of that agreement is attached to this Complaint as Exhibit C and will be referred to as the "June 2014 Agreement.").  24. From approximately November 10, 2014 unril approximately December 11, 20l 5, drivers on the LlberX platform did so under an identical form contract, which geographically assigned one of three Rasier entities as the other party (Rasier-CA, LLC, for California drivers, Racier-PA, LLC, for Pennsylvania drivers, and Racier, LLC, for the rest of the L.Inited States); that agreement was called the "Software License and Online Services Agreement." (A true and correct copy of that agreement is attached to this Complaint as E~ibit D and will be referred to as the "November 2014 Agreement.")  28. The relevant provisions from the November 2014 Agreement are excerpted below: • "Company [i,e., the geographically-assigned Rasier entity], a subsidiary of Llber Technologies, Inc. ("L.Iber"), provides lead generation to independent providers of rideshare or peer-to-peer (collectively, "P2P") passenger transportation services using the Llber Services (as defined below). The L.Iber Services enable an authorized transportation provider to seek, receive and fulfill re9uests for transportation services from an authorized user of Uber's mobile applications, You desire to enter into this Agreement for the purpose of accessing and using the L.Iber Services. • You acknowledge and agree that Company is a technology services provider that does not provide transportation services. • "Territory" means the city or metro areas in the Linited States in which you are enabled by the Driver App to provide Transportation Services. • "Transportation Services" means your provision of P2P passenger transportation services to Users via the L.Iber Services in the Territory using the Vehicle. • "Uber Services" mean Uber's on-demand lead generation and related services licensed by Llber to Company that enable transportation providers to seek, receive and fulfill on-demand requests for transportation services by Users seeking transportation services, which services include LIber's software, websites, payment services as described in Section 4 below, and related support services systems, as mad be updated or modified from time to time. • "User" means an end user authorized by L[ber to use the Llber mobile application for the 76. Plaintiff Chuck Congdon began working as an LIber driver on the LIberX platform in January 2014, before the Safe Rides program began.  77. Plaintiff Congdon undertook approacimately 208 minimum fare trips, and due to its actions, LIber reduced those fares on those trips by the amount of the Safe Rides Fees. Class Representative Ryan Cowden  78. Plaintiff Ryan Cowden began working as an LIber driver on the LIberX platform in August 2015, after the Safe Rides program began.  79. Plaintiff Cowden undertook approximately 5 minimum fare trips, and due to its actions,  j LIber reduced those fares on those trips by the amount of the Safe Rides Fees. Class Representative Anthony Martinez  80. Plaintiff Anthony Martinez began worlang as an Uber driver on the LIberX platform in April 2014, before the Safe Rides program began.  81. Plaintiff Martinez undertook 145 minimum fare trips, and due to its actions, LIber reduced those fares on those trips by the amount of the Safe Rides Fees. Class Representative Jason Rosenberg  82. Plainriff Jason Rosenberg began working as an L.Iber driver on the LIberX platform in October 2013, before the Safe Rides program began.  83. Plaintiff Rosenberg undertook approximately 119 minimum fare trips, and due to  its actions, Llber reduced those fares on those trips by the amount of the Safe Rides Fees. Class Representative Jorge Zuniga  86. All Plaintiffs represent and are members of a proposed Main Class asserting claims under Rule 23(b)(3) for Breach of Contract in Count L  87. The Main Class is defined as: (A) all persons in the United States; (B) who entered the 2013 Agreement, the June 2014 Agreement, the November 2014  ~' Agreement, or a combination of those agreements (regardless of whether the person also later entered the December 2015 Agreement); (C) and provided at least one minimum fare ride on the LlberX platform for which a Safe Rides Fee applied before Uber changed its local fare webpages in November 2015 to state that minimum fares would include Safe Rides fees.  88. Plaintiffs Congdon and Martinez represent, and are also members of, a Declaratory and Injunctive Relief Class asserting claims under Rule 23(b)(2) for final declaratory and injunctive relief in Count II.  89. The Declaratory and Injunctive Relief Class is defined as: (A) all persons in the United States; (B) who entered the 2013 Agreement, the June 2014 Agreement, the November 2014 Agreement, the December 2015 Agreement, or a combination of those agreements if the Court does not find the arbitration provision in the last Uber driver contract the person executed was unenforceable; and (C) did not opt-out of arbitration under the last Uber driver contract the person executed. Class Representative Chuch Congdon  Definitions of the Main Class, the Declaratory and Injunctive Relief Class and the Issue Class  The Arbitration Clauses and Class Action WaiversTo~ether Render Relief Ineffectual and Require that LIber be Enjoined from Arbitrating Driver Claims 137. To the extent the claims alleged in Count I are otherwise subject to arbitration for any class members, Plaintiffs Congdon and Martinez reallege paragraphs 1 to 116 on behalf of a proposed Issue Class. l 38. As with Count II, the relief sought in Count III with respect to individuals who signed the 2013 Agreement, the June 2014 Agreement, and the November 2014 Agreement (in which the arbitration provisions have been previously determined to be unenforceable) but did not enter into the December 2015 Agreement, is conditioned on the contractual arbitration provisions in the 2013 The History of the Uber Driver Contracts in this Case 