14.  On or about October 5, 2019, Mrs. Corrigan enrolled her daughter Samantha  Corrigan (“Samantha”), an 8th grader at the Doherty Middle School in Andover, MA, in an  educational tour of Spain, scheduled for April 17 through April 25, 2020, and offered to the  Doherty students by EF Education Tours, Inc., EF Travel, Inc., EF Educational Exchange, Inc.,  EF Education First, Inc., EF Explore America, Inc., EF Institute for Cultural Exchange, Inc.  and/or EF Education First International Ltd. (collectively “EF”).   15.  The EF website, under “Help Center” and “Payments & Policies,” contains a  document entitled “Booking Conditions,” which contains a section entitled “Release and  Agreement.”  According to EF, the Booking Conditions and Release and Agreement constitute  the entire agreement between EF and Mrs. Corrigan.   16.  EF did not disclose to Mrs. Corrigan the legal name(s), complete street business  address(es), telephone number(s), and/or owner(s) of the seller of travel services or the  provider(s) of the travel package.  EF also did not disclose the complete terms of its cancellation  policy.   17.  The EF Booking Conditions make reference to EF Education First International,  Ltd., a Swiss entity that is not registered to do business in Massachusetts.   19.  On October 6, 2019, EF charged $4,180.00 to Mrs. Corrigan’s credit card, thereby  paying in full for the EF travel services.   20.  Soon after enrolling Samantha, Mrs. Corrigan began receiving email and  telephone travel insurance-related marketing solicitations from EF.   21.  On November 21, 2019, Mrs. Corrigan received a telephone call from an EF  Travelers Support Agent, who touted the benefits and strongly recommended the purchase of the  Global Travel Protection Plan for Samantha’s tour at a one-time premium of $165.00.   22.  EF described its Global Travel Protection Plan as follows: “Travelers can choose  to enroll in the Global Travel Protection Plan, which we offer because many insurance  companies do not provide adequate coverage for people traveling abroad. Designed specifically  with EF travelers in mind, this affordable plan provides protection for travelers should something  unexpected happen before, en route or during the tour.”   23.  Mrs. Corrigan informed the EF Travelers Support Agent that she wanted to  review the policy terms before authorizing payment.   25.  Mrs. Corrigan agreed to purchase the Policy and paid the $165.00 premium online  through her EF account.   26.  The Policy provides, among other things, for full reimbursement of “Trip Cost”  upon cancellation of a “Trip” for a covered loss, to wit:  3. Without limitation, EF and/or Me to We Trips, Ltd. in collaboration  with Free The Children and its affiliated companies, partners, any  companies acting on its behalf, each of their directors, officers, employees,  volunteers, sponsors, independent contractors, agents, and authorized  representatives (together referred to as “MTW”) are not responsible for  any injury, loss or damage to person or property, death, delay, or  inconvenience in connection with the provision of any goods or services  occasioned by or resulting from, but not limited to, acts of God; force  majeure; acts of government; acts of war or civil unrest; insurrection or  revolt; strikes or other labor activities; criminal, terrorist, or threatened  terrorist activities of any kind; overbooking or downgrading of  accommodations; structural or other defective conditions in houses,  apartments, or other lodging facilities (or in any heating, plumbing,  electrical, or structural problem therein); mechanical or other failure of  airplanes or other means of transportation or for any failure of any  transportation mechanism to arrive or depart timely or safely; dangers  associated with or bites from animals, insects, or pests; sanitation  problems; food poisoning; epidemics or the threat thereof; disease; lack of  access to or quality of medical care; difficulty in evacuation in case of a  medical or other emergency; or any negligent or willful act or failure to  act of any third party or for any other cause beyond the direct control of  EF or MTW.   52.  Plaintiff reserves the right to modify, expand, or amend the definitions of the  proposed Classes.   53.  This action is properly maintainable as a class action.   54.  Plaintiff does not know the exact number of members of the proposed Classes  since that information is in the control of Defendants, but the members of the Classes are so  numerous that joinder of all members is impractical.   55.  There are questions of law or fact common to the Classes that predominate over  any questions affecting only individual members.    56.  Plaintiff’s claims are typical of the claims of the Classes, because all members of  the Classes will be similarly affected by the judgment sought in this action.   57.  Plaintiff will fairly and adequately protect the interest of the members of the  Classes and have retained counsel competent and experienced in class litigation.   58.  A class action is superior to other available methods for the fair and efficient  adjudication of this controversy because joinder of all Class members is impracticable. There  will be no difficulty in the management of this action as a class action.   6.   I further agree to release the Released Parties from any and all  decisions to cancel, modify, or delay the tour as a result of unforeseeable  events that are beyond the reasonable control of EF or MTW or which  become necessary or advisable so as to increase the quality of the tour.   60.  Plaintiff repeats and incorporates by reference each and every allegation above.   61.  Defendants made an offer to Plaintiff/Class Members concerning travel services  containing illegal provisions and illusory promises.   62.  Defendants made an offer to Plaintiff/Class Members concerning travel insurance.   63.  Plaintiff/Class Members made payments to Defendants.   64.  Plaintiff/Class Members and Defendants formed/may have formed valid, binding  contracts.    65.  If so, Defendants breached the contracts by failing and refusing to offer full cash  refunds and travel insurance benefits for undelivered, purchased travel services as a result of  68.  Defendants were obligated to act in good faith and to deal fairly with  Plaintiff/Class Members.   69.  Defendants breached the covenant of good faith and fair dealing by failing and  refusing to offer full cash refunds and travel insurance benefits.   7.   I agree that this Release applies to and binds myself and my minor  child enrolling on tour (if applicable) along with my personal  representatives, executors, heirs, and family.   70.  Plaintiff/Class Members suffered damage as a result of Defendants’ breach of the  covenant of good faith and fair dealing.  71.  Plaintiff repeats and incorporates by reference each and every allegation above.   72.  Defendants received payments from Plaintiff/Class Members.   73.  Defendants have been unjustly enriched to the detriment of Plaintiff/Class  Members.  74.  Plaintiff repeats and incorporates by reference each and every allegation above.   75.  Plaintiff/Class Members have property rights to refunds of amounts paid for  undelivered travel services purchased from Defendants.   76.  Defendants intentionally exercised control over and/or interfered with such rights.   77.  Plaintiff/Class Members have suffered damage as a result.  Breach of Duty of Good Faith & Fair Dealing  (On Behalf of Plaintiff and the Class)   Breach of Contract  (On Behalf of Plaintiff and the Class)   Conversion  (On Behalf of Plaintiff and Class)   INC., EF INSTITUTE FOR CULTURAL  EXCHANGE, INC., EF EDUCATION  FIRST INTERNATIONAL, LTD., UNITED  Unjust Enrichment   (On Behalf of Plaintiff and the Class)  