17.  Plaintiff incorporates by reference and realleges all paragraphs previously  alleged herein.   18.  At all times relevant, Defendant made and continues to make automatic  renewal offers and continuous service offers, as those terms are defined by  Cal. Bus. & Prof. Code § 17600, et seq. (“California’s Automatic Purchase  Renewal Statute”) to Plaintiff and other consumers similarly situated.    19.  On or about August 13, 2012, in a good faith effort to protect his financial  credit and financial information, Plaintiff purchased a subscription from  LifeLock, a company that represents to consumers that it assists in the  protection of consumer financial identity.   20.  With this goal in mind, Plaintiff purchased an annual subscription to the  service Defendant offered.   22.  At the time Plaintiff purchased this subscription Defendant charged, and  continues to charge, Plaintiff for this automatic renewal offer without first  obtaining the affirmative consent to the agreement containing the automatic  renewal offer terms or continuous service offer terms.   23. At the time Plaintiff subscribed to Defendant’s services, Plaintiff was  subjected to Defendant’s unlawful policies and/or practices as set forth herein,  in violation of California’s Automatic Purchase Renewal Statute.   24. The material circumstances surrounding this experience by Plaintiff were the  same, or nearly the same, as the other class members Plaintiff proposes to  represent, and Plaintiff and all class members were required to pay, and did  pay, money for this service by Defendant.  25. Plaintiff brings this action, on behalf of himself and all others similarly  situated (“the Class”).   26. Plaintiff represents, and is a member of, the Class, consisting of:   All persons within California who purchased products  and/or services from Defendant via Defendant’s website  as part of an automatic renewal plan or continuous service  offer, within four years prior to the filing of the Complaint  in this action.   29. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   30. At a date presently unknown to Plaintiff, but at least four years prior to the  filing of this action, and as set forth above, Defendant has engaged in the  practice of making automatic renewal offers and continuous service offers, as  those terms are defined by Cal. Bus. & Prof. Code § 17600, et seq.  (“California’s Automatic Purchase Renewal Statute”), to California  consumers and the general public.   32. As a direct and proximate result of Defendant’s aforementioned conduct and  representations, Defendant received and continues to hold monies rightfully  belonging to Plaintiff and other similarly situated consumers   33. As a direct and proximate result of Defendant’s violations of Cal. Bus. &  Prof. Code § 17600, et seq., Plaintiff and members of the Class are entitled to  a declaration that Defendant violated the California Automatic Purchase  Renewal Statute.    35. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   36. Plaintiff and Defendant are each “person[s]” as defined by California  Business & Professions Code § 17201.  California Bus. & Prof. Code              § 17204 authorizes a private right of action on both an individual and  representative basis.   37. “Unfair competition” is defined by Business and Professions Code Section §  17200 as encompassing several types of business “wrongs,” two of which are  at issue here: (1) an “unlawful” business act or practice, (2) an “unfair”  business act or practice, (3) a “fraudulent” business act or practice, and (4)  “unfair, deceptive, untrue or misleading advertising.”  The definitions in         § 17200 are drafted in the disjunctive, meaning that each of these “wrongs”  operates independently from the others.    38. By and through Defendant’s conduct alleged in further detail above and  herein, Defendant engaged in conduct which constitutes (a) unlawful and (b)  unfair business practices prohibited by Bus. & Prof. Code § 17200 et seq.    (a) Unlawful” Prong   40. Defendant had other reasonably available alternatives to further its legitimate  business interest, other than the conduct described herein, such as adequately  disclosing the terms of Defendant’s automatic renewal offers and continuous  service offers, as set forth by Cal. Bus. & Prof. Code § 17600, et seq.   41. Plaintiff and the putative class members reserve the right to allege other  violations of law, which constitute other unlawful business practices or acts,  as such conduct is ongoing and continues to this date.  (b) “Unfair” Prong   42. Defendant’s actions and representations constitute an “unfair” business act or  practice under § 17200 in that Defendant’s conduct is substantially injurious  to consumers, offends public policy, and is immoral, unethical, oppressive,  and unscrupulous as the gravity of the conduct outweighs any alleged benefits  attributable to such conduct.  Without limitation, it is an unfair business act or  practice for Defendant to knowingly or negligently fail to adequately disclose  the terms of Defendant’s automatic renewal offers and continuous service  offers, as set forth by Cal. Bus. & Prof. Code §§ 17600, et seq.   43. At a date presently unknown to Plaintiff, but at least four years prior to the  filing of this action, and as set forth above, Defendant has committed acts of  unfair competition as defined by Cal. Bus. & Prof. Code §§ 17200 et seq., as  alleged further detail above and herein.   45. Plaintiff incorporates by reference all of the above paragraphs of this  Complaint as though fully stated herein.   46. Cal. Bus. & Prof. Code § 17535, et seq. (the “UCL”) allows “any person who  has suffered injury in fact and has lost money or property” to prosecute a civil  action for violation of the UCL. Such a person may bring such an action on  behalf of himself and others similarly situated who are affected by the  unlawful, unfair, or fraudulent business practice.    47. Beginning at an exact date unknown to Plaintiff, but prior to January 16,  2013, and continuing to the present, Defendant has committed unlawful,  unfair, and/or fraudulent business acts and practices as defined by the UCL,  by violating Cal. Bus. & Prof. Code § 17602.    48. As a direct and proximate result of Defendant’s unlawful, unfair, and/or  fraudulent acts and practices described herein, Defendant has received and  continues to hold unlawfully obtained property and money belonging to  Plaintiff and class members in the form of payments made for subscription  agreements by Plaintiff and class members. Defendant has profited from its  unlawful, unfair, and/or fraudulent acts and practices in the amount of those  business expenses and interest accrued thereon.   50. In prosecuting this action for the enforcement of important rights affecting the  public interest, Plaintiff seeks the recovery of attorneys’ fees, which is  available to a prevailing plaintiff in class action cases such as this matter.   51. Plaintiff, on behalf of himself and similarly situated class members, request  relief as described below.  VIOLATION OF CAL. BUS. & PROF. CODE §§ 17200, ET SEQ.  [CALIFORNIA’S UNFAIR COMPETITION LAW]   VIOLATION OF CAL. BUS. & PROF. CODE §§ 17535, ET SEQ.   VIOLATION OF CAL. BUS. & PROF. CODE §§ 17600, ET SEQ.  [CALIFORNIA’S AUTOMATIC PURCHASE RENEWAL STATUTE]  