(CAL. BUS. & PROF. CODE § 17200, ET SEQ.) ............................................................... 16  COUNT III  VIOLATION OF THE CALIFORNIA FALSE ADVERTISING LAW   (CAL. BUS. & PROF. CODE § 17500, ET SEQ.) ............................................................... 18  10.  Among its broad assortment of internet-related services and products, Google offers a  mobile phone and data service. Google calls the service “Project Fi.” Google has partnered with  several mobile data carriers to provide Project Fi users with access to mobile data on a pay-as-you-go  basis.   11.  Users of the mobile data service choose a monthly data allocation as an estimate of  their monthly charge, but Google bills per gigabyte of data used. That is, Google generally charges  $10 per gigabyte of data actually used, whether as part of the pre-purchased data allocation or  additional data used by the customer.   12.  Google’s Terms of Service falsely assure customers that Google will bill them only  for their use of Google’s products and services (“Services”).   13.  Under the Terms of Service, Google requires users only “to pay all applicable charges  for the Services you use.”   14.  The Terms of Service authorize Google only “to automatically collect payments of all  charges associated with the use of the Services from your designated payment method.”   15.  And through the Terms of Service, Google promises that it will use information  collected from customers’ devices to “[b]ill you and collect payment for the Services and devices  that you [customers] purchased.”   59.  Plaintiff Gordon Beecher brings this action under Federal Rule of Civil Procedure  23(b)(2) and (b)(3) on his own behalf and on behalf of the following class of plaintiffs:  All past and present subscribers of Google mobile data services  who have been charged by Google for the use of data services  independently provided by third parties.    60.  The persons in the class are so numerous that individual joinder of all members is  impracticable under the circumstances of this case. Although the precise number of such persons is  unknown, the exact size of the class is easily ascertainable as each class member can by identified by  using Defendant’s records. Plaintiff is informed and believes that there are many thousands of class  members.    69.  Plaintiff incorporates the allegations set forth above as if fully set forth herein.   88.  Plaintiff realleges and incorporates by reference all paragraphs alleged herein.   89.  Plaintiff asserts this claim on behalf of himself and members of the Class on behalf of  all persons or entities that purchased the Project Fi mobile data service.   97.  Plaintiff realleges and incorporates by reference all paragraphs alleged herein.   98.  Plaintiff asserts this claim on behalf of themselves and members of the Class on  behalf of any person or entity that purchased Project Fi services.   A.  The Project Fi Mobile Data Plan   A.  The Project Fi Mobile Data Plan ................................................................................. 3  B.  Google Bills Its Customers for Data Service It Did Not Provide ................................ 7  V.  VI.  CLAIMS FOR RELIEF ......................................................................................................... 13  COUNT I  VIOLATIONS OF THE CONSUMER LEGAL REMEDIES ACT   VIOLATIONS OF THE CONSUMER LEGAL REMEDIES ACT   (CAL. CIV. CODE § 1750, ET SEQ.)   VIOLATION OF THE CALIFORNIA UNFAIR COMPETITION LAW   (CAL. BUS. & PROF. CODE § 17200, ET SEQ.)   VIOLATION OF THE CALIFORNIA FALSE ADVERTISING LAW   (CAL. BUS. & PROF. CODE § 17500, ET SEQ.)  