13.  Defendant Sempris is a marketing company that offers numerous subscription- based, negative-option “Membership Programs” which purport to offer discounts and services,  such as coupons and rebates, to “subscribing” consumers.   37.  In or around December 2012, Georgia Noonan viewed a television infomercial for  one of Defendant Hampton Direct’s products—the Wraptastic.   49.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23(a),  (b)(2), and (b)(3) on behalf of herself and a Class and Subclass defined as follows:  Sempris Class: All individuals who were enrolled in any Sempris Membership  Programs following an over-the-phone purchase of a Hampton Direct  product.  Washington Subclass: All Sempris Class members who reside in the State of  Washington.  The following persons are excluded from the Class and Subclass: (1) any Judge or Magistrate  presiding over this action and members of their families; (2) Defendants, Defendants’  subsidiaries, parents, successors, predecessors, and any entity in which Defendants or their  parents have a controlling interest and their current or former employees, officers, and directors;  (3) persons who properly execute and file a timely request for exclusion from the class; and  (4) the legal representatives, successors or assigns of any such excluded persons.   50.  Numerosity: The exact numbers of the members of the Class and Subclass  (together, the “Classes”) is unknown and not available to Plaintiff at this time, but it is clear that  individual joinder is impracticable. Defendants have wrongfully obtained money from thousands  of consumers who fall into the definition set forth above. Members of the Classes can be  identified through Defendants’ records.   55.  Plaintiff incorporates by reference the foregoing allegations.   56.  The Washington Consumer Protect Act [“CPA”] provides that “[u]nfair methods  of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce  are . . . unlawful.” RCW § 19.86.020.   57.  As the purpose of the CPA is “to protect the public and foster fair and honest  competition,” the act should be “liberally construed” to serve its beneficial purposes. RCW  § 19.86.920.   58.  The CPA prohibits (a) an unfair or deceptive act or practice, (b) occurring in trade  or commerce, (c) with a public interest impact, (d) that causes injury.   59.  In the context of the CPA, pleading and proof of an unfair or deceptive act or  practice bears little resemblance to pleading and proof of fraud.  The term “deceptive” in RCW  § 19.86.020 means having a capacity to deceive a substantial portion of the public.   60.  Defendants’ conduct, representations, and omissions regarding the terms of the  Membership Programs, including the negative-option price and term, the account to be charged,  and the actions necessary to prevent those charges, has or had the capacity to deceive a  substantial portion of the public.   61.  The price of a product is likely to affect the choice of, or conduct regarding,  whether to purchase a product. Defendants’ confusing conduct, representations, and omissions  related to the price of their products has or had the capacity to deceive a substantial portion of the  public.   73.  Plaintiff incorporates by reference the foregoing allegations.   74.  RCW ch. 19.56 regulates the provision of unsolicited goods or services. It states  that “if unsolicited goods or services are provided to a person, the person has a right to accept the  goods or services as a gift only” and “may use them or dispose of them in any manner without  any obligation to the provider.” RCW § 19.56.020.   75.  Goods or services are unsolicited “unless the recipient specifically requested, in  an affirmative manner, to receive the goods or services according to the terms under which they  are being offered.” RCW § 19.56.020.   84.  Plaintiff incorporates by reference the foregoing allegations.   91.  Plaintiff incorporates by reference the foregoing allegations, excluding paragraphs  84 through 90.   97.  Plaintiff incorporates by reference the foregoing allegations, excluding paragraphs  84 through 90.   98.  Sempris, knowingly and without authorization, charged Membership Program  fees to the credit and debit accounts of Plaintiff and the members of the Class.   Breach of Contract  (against Hampton Direct)  (Individually and on behalf of the Class)   Unjust Enrichment in the alternative to breach of contract  (against Hampton Direct)  (Individually and on behalf of the Class)   Unjust Enrichment  (against Sempris)  (Individually and on behalf of the Class)   Violation of the Washington Consumer Protection Act, RCW ch. 19.86  (against both Defendants)  (Individually and on behalf the Washington Subclass)   Violation of RCW ch. 19.56  (against Sempris)  (Individually and on behalf of the Washington Subclass)  