10.  Plaintiff expected that her telephone call would be private (i.e., neither recorded  nor monitored) due to the sensitive and confidential nature of the conversation.   12.  Plaintiff brings this class action for damages and other monetary relief on behalf  of the following class:  “All persons who placed calls to Defendant from California whose  telephone conversations with Defendant were intentionally  recorded without disclosure by Defendant at any time during the  statute of limitations period through the date of final judgment in  this action.”  (the “Class”).   13.  Excluded from the Class are governmental entities, Defendant, any entity in which  Defendant has a controlling interest, and Defendant’s officers, directors, affiliates, legal  representatives, employees, co-conspirators, successors, subsidiaries, and assigns, and individuals  bound by any prior settlement.  Also excluded from the Class is any judge, justice, or judicial  officer presiding over this matter and the members of their immediate families and judicial staff.   14.  The proposed Class is so numerous that individual joinder of all its members is  impracticable.  Due to the nature of the trade and commerce involved, Plaintiff believes that the  total number of Class members is at least in the tens of thousands and members of the Class are  numerous and geographically dispersed across California.  While the exact number and identities  of the Class members are unknown at this time, such information can be ascertained through  appropriate investigation and discovery.  The disposition of the claims of the Class members in a  single class action will provide substantial benefits to all parties and to the Court.   7.  In June, 2013, while located in California, Plaintiff called Abbott at (800) 986- 8800 from a wireless telephone in California.  Plaintiff spoke to a customer service representative  of Defendant to inquire about Defendant’s Similac infant formula products.     8.  Plaintiff was not aware that the call was being recorded.  Defendant did not, at any  point during the telephone conversation with Defendant’s customer service representative, advise  Plaintiff that the call was being recorded.  Plaintiff did not give either express or implied consent  to the recording.    9.  After completing her call, Plaintiff learned that Defendant records all incoming  telephone calls but does not disclose this to callers.     Penal Code § 632.7  