(Unjust Enrichment)  (Violation of Massachusetts Unfair Trade Practices Act, Mass. Gen. Laws ch. 93A)  18. Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as iffully set forth herein.  20. Restoration Hardware is a corporation that accepts credit cards for retail transactions.  21. When a consumer uses credit cards at Restoration Hardware's retail stores in Massachusetts, a Restoration Hardware employee requests that consumer's ZIP code. The Restoration Hardware employee then writes that ZIP code into the credit card transaction form, which is on the computerized check-out register used to process the point-of-sale transaction. Consumers typically provide this information in the mistaken beliefthat providing a ZIP code is necessary to complete the transaction.  22. The ZIP code is part ofa credit card holder's address, and is therefore personal identification information under Mass. Gen. Laws Ch. 93 § IOS(a). Restoration Hardware and other retailers are also able to use a customer's name and ZIP code to determine their address or telephone number using commercially available databases.  23. Mass. Gen. Laws ch. 93 § lOS(c) provides that the collection ofpersonal identification information is a per se violation of Mass. Gen. Laws ch. 93A § 2: "Any violation ofthe provisions ofthis chapter shall be deemed to be an unfair and deceptive trade practice, as defined in section 2 of chapter 93A."  25. Plaintiff and the Class have been injured by Restoration Hardware's collection of ZIP codes and Defendant's subsequent use oftheir personal identification information. Mass. Gen. Laws. Ch. 93 § 105 creates a protected privacy interest held by consumers in not having to divulge personal identification information, including their ZIP codes, merely to use a credit card. In addition, Plaintiffand the Class were injured by Restoration Hardware appropriation and use oftheir economically valuable personal identification information without consideration, and the profit derived from Defendant's use of Plaintiffs and the Class's ZIP codes is a measure oftheir damages. Plaintiffand the Class were also injured by the receipt ofunwanted junk mail from Restoration Hardware.  26. In compliance with Mass. Gen. Laws. Ch. 93A § 9(3), on March 15,2013, Plaintiffs counsel sent Defendant a written demand for relief by Federal Express, identifying Ms. Monteferrante as a claimant and reasonably describing the unfair or deceptive act alleged herein and the injury she and other Class members suffered. 27. Plaintiffrepeats and re-alleges the allegations contained in the paragraphs above as if fully set forth herein.  28. Defendant knowingly and willingly accepted benefits from Plaintiff and the Class, to wit, their economically valuable personal identification information which Defendant used for its own profit, while providing Plaintiff and the Class nothing in return. 