(Unfair and Deceptive Acts and Practices in Violation of  the California Consumers Legal Remedies Act)   (Violation of California’s Unfair Competition Law)   1.  Whether Defendants charged the $3.50 to all rentals originating at  the San Diego Airport as a policy and practice during the Class  Period;   13.  On April 10, 2018, the Board of Port Commissioners of the San Diego  Unified Port District adopted Resolution 2018-065, which purported to re-enact San  Diego Port Ordinance 2030 and imposed a special tax, disguised as a “user fee,” on car  renters. The special tax is a charge of $3.50 that renters are assessed for each rental car  transaction that takes place on San Diego Port tidelands, which includes San Diego  International Airport and the adjacent Rental Car Center.   14.  Ordinance 2030 was enacted approximately twenty years ago to fund a  parking structure near the San Diego Convention Center and Airport. Collection of  fees under Ordinance 2030 was suspended over a decade ago.   41.  Plaintiff brings this action pursuant to Rule 23 of the Federal Rules of  Civil Procedure on behalf of himself and all other similarly situated individuals (the  “Class”), defined as follows:  All United States citizens who rented a vehicle from one of the Defendants  in San Diego, California from the period of April 10, 2018 to the present  and who were assessed a $3.50 fee.  Excluded from the Class are any of  Defendants’ officers, directors, or employees; officers, directors, or  employees of any entity in which Defendants currently have or have had  a controlling interest; and Defendants’ legal representatives, heirs,  successors, and assigns.   42.  At this time, Plaintiff does not know the exact number of Class members;  however, given the nature of the claims and the number of individuals who rented  vehicles in San Diego Airport during the Class period, Plaintiff believes that the Class  members are so numerous that joinder of all members is impracticable.     43.  There is a well-defined community of interest in the questions of law and  fact involved in this case.  The following questions of law and fact are common to the  Class members and predominate over questions that may affect individual Class  members:   51.  Plaintiff incorporates by reference each of the allegations contained in the  preceding paragraphs of this Complaint and further alleges as follows.   52.  This cause of action is brought pursuant to the California Consumers  Legal Remedies Act, Cal. Civ. Code §§ 1750-1785 (the “CLRA”).   53.  Plaintiff and the other Class members are “consumers,” as the term is  defined by California Civil Code § 1761(d), because they purchased and/or leased the  car rentals at issue for personal, family, or household purposes.     54.  Plaintiff and Defendants, and the other Class members and Defendants,  have engaged in “transactions,” as that term is defined by California Civil Code  §1761(e).   55.  The conduct alleged in this complaint constitutes unfair methods of  competition and unfair and deceptive acts and practices for the purpose of the CLRA,  and the conduct was undertaken by Defendants in transactions intended to result in,  and which did result in, the sale or lease of goods to consumers.   62.  Plaintiff incorporates by reference each of the allegations contained in the  preceding paragraphs of this Complaint and further alleges as follows.   63.  By committing the acts and practices alleged herein, Defendants have  violated California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§  17200-17210, as to the Class as a whole, by engaging in unlawful, fraudulent, and  unfair conduct.   A.  The Illegal Tax  