14. Founded in 1997 and launched in 1998, AutoTrader operates a digital automotive marketplace and is a leading provider of marketing and software solutions to automotive dealers in the United States.  15. AutoTrader has over 20,000 automobile dealer clients and boasts of having 18.5 million unique visitors monthly with average daily vehicle listings of  16. “Autotrader has the most unique visitors monthly and drives more buyers to dealerships than any other third-party automotive website. Our comprehensive view of the marketplace provides proprietary market insights to help dealers improve their operational efficiency and inform their decisions,” according to AutoTrader’s website.  4.4 million, according to its company website.  96. Plaintiff brings this lawsuit as a class action pursuant to Federal Rules of Civil Procedure 23(a), and 23(b)(2) and 23(b)(3), on behalf of itself and all others similarly situated as members of the following nationwide class ("Nationwide Class”), on their claims as purchasers of subscription advertisement listings from AutoTrader.  97. The proposed Nationwide Class is defined as follows: Nationwide Class: All dealer customers located in the United States who purchased subscription advertisement listings from AutoTrader between June 1, 2010 and June 30, 2015 inclusive.  AutoTrader Touts Itself As Being The Most Visited Car Shopping Website 