(Unjust Enrichment)   (Violation of Massachusetts Unfair Trade Practices Act, Mass. Gen. Laws ch. 93A)   19.  Plaintiff repeats and re-allege the allegations contained in the paragraphs above as  if fully set forth herein.   20.      Mass. Gen. Laws Ch. 93 § 105(a) provides that:  No person, firm, partnership, corporation or other business entity that accepts a  credit card for a business transaction shall write, cause to be written or require that  a credit card holder write personal identification information, not required by the  credit card issuer, on the credit card transaction form. Personal identification  information shall include, but shall not be limited to, a credit card holder's address  or telephone number.  The provisions of this section shall apply to all credit card  transactions.   21.       Williams-Sonoma is a corporation that accepts credit cards for retail transactions.   22.      When a consumer used a credit card at Williams-Sonoma’s retail stores in  Massachusetts, a Williams-Sonoma employee requested that consumer’s ZIP code. The Williams- Sonoma employee then wrote 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 belief that providing a ZIP code is necessary  to complete the transaction.   23.   The ZIP code is part of a credit card holder’s  address, and is therefore personal  identification information under Mass. Gen. Laws Ch. 93 § 105(a).  Williams-Sonoma  and other  retailers are also able to use a customer’s name and ZIP code to determine their address or  telephone number by using commercially available databases.   25.         Mass. Gen. Laws ch. 93A § 9 provides that:  Any person .  .  .  who has been injured by another person’s  use or  employment of any method, act or practice declared to be unlawful by  section two . . . may bring an action in the superior court . . . for damages  and such equitable relief, including an injunction, as the court deems to be  necessary and proper . . . Any persons  entitled  to  bring  such  action  may,   if the use or  employment  of  the unfair or deceptive act or practice has  caused similar injury to numerous other persons similarly situated and if the  court finds in a preliminary hearing that he adequately and fairly represents  such other persons, bring the action on behalf of himself and such other  similarly injured and situated persons.   26.   Plaintiff and the Class have been injured by Williams-Sonoma's collection of  ZIP codes and Defendant’s subsequent use of their 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, Plaintiff and the Class were injured by Williams-Sonoma appropriation and  use of their economically valuable PII without consideration, and the profit derived from  Defendant’s use of Plaintiff and the Class’s  ZIP codes is a measure of their damages.  Plaintiff  and the Class were also injured by the receipt of unwanted junk mail from Williams-Sonoma.   28.   Plaintiff repeats and re-allege the allegations contained in the paragraphs above  as fully set forth herein.              29.   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.   30.   Under the circumstances described herein, it is inequitable for Defendant to  retain the full monetary benefit of that information at the expense of Plaintiff and the Class.   31.   By engaging in the conduct described above, Defendant has unjustly enriched  itself at the expense of Plaintiff and the Class and is required, in equity and good conscience, to  compensate Plaintiff and the Class for the appropriation of their PII, the amount of such  compensation to be determined at trial.  WHEREFORE, Plaintiff respectfully requests that the Court enter judgment against  Defendant as follows: 