34. Plaintiff alleges as follows, on information and belief, formed after a  reasonable inquiry under the circumstances.   35. Due to the side effects of her battle with cancer, Mrs. Solorio found that her  hair was lacking the volume and health that it once had.    36. Within the last few years, while watching television, Mrs. Solorio saw an  infomercial about a product that was advertised to help treat hair loss and  increased circulation in her scalp, which product was made by a company  called Keranique.   37. As a result of the infomercial, Mrs. Solorio learned that she could receive hair  care products through the mail for a set monthly payment.    38. In or around March of 2017, Mrs. Solorio called “1-800” telephone number  advertised on the infomerical.   39. Upon information and belief, Keranique hired two telemarketing firms in  both Colorado and Maine to field calls that come in through its advertised  number.    40. Upon information and belief, Sempris has contracted with these  telemarketing calling centers to “upsell” the Keranique product.   41. By calling the phone number, Mrs. Solorio was connected with one of these  two calling centers.   42. During the call, Mrs. Solorio notified the salesman on the line (“Salesman”)  that she was interested in purchasing one of Keranique’s haircare products.    43. After describing the product that she wished to purchase, Salesman offered  Mrs. Solorio the chance to also purchase a membership in Taste for Savings.  Mrs. Solorio declined the offer and stated that she was only interested in the  hair products.   69. Plaintiff brings this action on behalf of herself and on behalf of all others  similarly situated (“the Class and Subclass”).    70. Plaintiff represents and is a member of the Class, consisting of:  All persons within the United States who were charged  by Defendant/s and/or their employees and/or agents on a  monthly basis for any membership, without consent, in  the four years prior to the filing of the Complaint.   CONVERSION  193.  Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.  194.  Plaintiff and Class and Subclass members held lawful rights in the  personal property that Defendants’ withdrew from their accounts through its  autorenewal program.  195.  Defendant engaged in an unlawful act when it exercised dominion  over Plaintiff and Class members’ and Subclass members’ property when  they charged Plaintiff’s and Class Members’ credit and debit cards without  their consent or knowledge.  196.  Defendant acted with malice, oppression or fraud in obtaining these  funds it was not entitled to.   197.  As a result of the control over Plaintiff and Class members’ and  Subclass members’ personal property, Plaintiff and Class members and  Subclass members suffered monetary damages.   VIOLATIONS OF CALIFORNIA’S UNFAIR COMPETITION LAW (“UCL”)  CAL. BUS. & PROF. CODE §§ 17200, ET SEQ.  • An award of actual damages, in an amount to be determined at trial,  pursuant to Cal. Bus. & Prof. Code § 17206(b), for Plaintiff;  • An order requiring Defendants to pay restitution to Plaintiff and class  members due to Defendants’ UCL violations, pursuant to Cal. Bus. &  Prof. Code §§ 17200-17205, in the amount of their subscription  agreement payments;  • That Defendants be enjoined from continuing the wrongful conduct  alleged herein and required to comply with all applicable laws;  • An award of costs of litigation and reasonable attorney’s fees, pursuant to  Cal. Civ. Code § 1021.5 for Plaintiff; and  • Any and all other relief as this Court may deem necessary or appropriate.  VIOLATIONS OF RICO AND CONSPIRACY TO VIOLATE RICO  18 U.S.C. §§ 1962, ET SEQ.   • compensatory damages, for a sum trebled, plus interest to the Class  pursuant to 18 U.S.C. § 1964(c);   • an award of attorneys’ fees, together with all costs and expenses,  pursuant to 18 U.S.C. § 1964(c); and   • any and all other relief that this Court deems just and proper. 