(against all Defendants) Unjust Enrichment  (against all Defendants) ,  Injunctive Relief  (against all Defendants) Money Had and Received  22. Plaintiff brings this action as a class action pursuant to Florida Rule of Civil Procedure I .220(bX I ) and I .220(b)(2) on behalf of herself and all others similarly situated as members of the following class: All persons in the United States who purchased an appliance made from Samsung adve¡'tised as "stainless steel" (the "Class").  23. Subject to additional information obtained through further investigation and discovery, the foregoing definition of the Class may be expanded or narrowed by amendment or amended complaint. Specifically excluded from the proposed Class are the Defendants, its officers, directors, agents, trustees, parents, children, corporations, trusts, representatives, employees, principals, servants, partners, joint venturers, or entities controlled by the Defendants, and its heirs, successors, assigns, or other persons or entities related to or affiliated with the Defendants and/or its officers and/or directors, or any of them; the Judge assigned to this action, and any member of the Judge's immediate family.  24. Numerosily. The members of the Class are so numerous that their individual joinder is impracticable. Plaintiff is informed and believes, and on that basis allege, that the proposed Class contains many thousands of members. The precis. nutb.r of Class members is unknown to Plaintiff. The true number of Class members are known by the Samsung, however, and thus, may be notified of the pendency of this action by first class mail, electronic mail, and by published notice, electronic and otherwise.  26. Typícality. Plaintiff s claims are typical of the claims of the members of the Class in that the Defendants sold a product(s) to Plaintiff advertising that they were composed of a specific metal, when it fact it was a baser metal with a laminate/painted surface. All the Class members' claims would therefore be typical. 27 .  Adequacy of Representation. Plaintiff will fairly and adequately protect the interests of the members of the Class. Plaintiff has retained counsel highly experienced in complex consumer class action litigation, and Plaintiff intends to prosecute this action vigorously. Plaintiffhas no adverse or antagonistic interests to those of the Class.  29. In the alternative, the Class may be also certified because: (Ð  the prosecution of separate actions by individual Class members would create a fisk of inconsistent or varying adjudication with respect to individual Class members that would establish incompatible standards of conduct for the Defendants; (g)  the prosecution of separate actions by individual Class members would create a risk of adjudications with respect to them that would, as a practical matter, be dispositive of the interests of other Class members not parties to the adjudications, or substantially impair or impede their ability to protect their interests; and/or E  For example, Plaintiff would be hard pressed to find a law firm willing to engage in a multi-year scorched-earth litigation with Samsung, a well-capitalized foreign corporation with revenues of $305 billion (æ of 2014), to litigate her claim on an individual basis, no matter how meritorious. .Seø https://en.wikipedia.org/wiki/Samsung (læt accessed April 13, 2018). Pursuing a lawsuit pro se would similæly get Plaintiff nowhere. ,Sea https://www.nytimes.coml20l7l09ll l/us/politics/judge-richæd- posner-retirement.html (where noted jurist Judge Richæd A. Posner, formerly of the 7th Circuit Court of Appeals, said that "most judges regæd [pro se litigants] æ kind of trash not worth the time of a federal judge"). I 33. Plaintiff hereby incorporates by reference the allegations in the preceding paragraphs I through 32, as though fully set forth herein. 34, During the class period, Plaintiff and Class members conferred a benefit upon Defendants without knowledge of the substandard products, benefits that were non-gratuitous.  35. Defendants acceþted or retained the non-gratuitous benefits conferred by Plaintiff and the Class members despite Defendants' knowledge of the substandard products.  38. Accordingly, Plaintiffand members of the Class seek full restitution of Defendants' enrichment, benefits and ill-gotten gains acquired because of the unlawful and/or wrongful conduct alleged herein.  39. Plaintiff and the Class have no adequate remedy at law.  40. Plaintiffseeks to obtain a pecuniary benefit for the Class in the form of all reimbursement, restitution and disgorgement from Defendants. Plaintiff s counsel are entitled to recover their reasonable attorneys' fees and expenses as a result of the conference of a pecuniary benefit on behalf of the Class and will seek an award of such fees and expenses at the appropriate time. WHEREFORE, Plaintiff, on behalf of herself and allothers similarly situated, pray for relief and judgment against Defendants as follows: A.  For an order certifying the Class under the appropriate provisions of Florida Rule of Civil Procedure L220, as well as any appropriate subclasses, and appointing Plaintiff and her legal counsel to represent the Class; B.  Awarding reimbursement, restitution and disgorgement from Defendants of the benefits conferred by Plaintiff and the Class; C.  For pre- and post-judgment interest to the Class, as allowed by law; D.  For reasonable attorneys' fees and costs to counsel for the Class if and when pecuniary benefits are obtained on behalf of the Class; and 10 41. Plaintiff hereby incorporates by reference the allegations in the preceding paragraphs I through 32, as though fully set forth herein.  42. This cause of action is pled in the alternative of all contract-based causes of action.  43. As a result of the conduct alleged herein, Defendants have improperly received monies from Plaintiff and the Class it was not legally entitled to receive.  44. Plaintiff and members of the Class have a claim for improperly paid monies to Defendants resulting from Defendants' improper marketing and selling of the Products.  45. Equity and good conscience require that Defendants pay over such additional monies, described above, to Plaintiff and the Class.  46. As a direct and proximate result of Defendants' misconduct, Plaintiff and members of the Class have suffered injury and are entitled to reimbursement, rest¡tut¡on and disgorgement in the âmount necessary to restore them to the position they would have been in if Defendants have not sold them the fraudulent Products.  47. Plaintiff seeks to obtain a pecuniary benefit for the Class in the form of reimbursement, restitution and disgorgement from Defendants. Plaintiff s counselare entitled to recover their reasonable attorneys' fees and expenses as a result of the conferment of a pecuniary benefit on behalf of the Class, and will seek an award of such fees and expenses at the appropriate time. 11 48. Plaintiff hereby incorporates by reference the allegations in the preceding paragraphs I through 32 as though fully set forth herein.  49. Plaintiff has no adequate remedy at law for future unlawfulconduct by Defendants in connection with their manufacture, marketing and sale of appliances fraudulently being sold as "stainless steel" kitchen appliances.  50. Defendants continue to manufacture, market and sell kitchen appliances as "stainless steel" appliances when they are not "stainless steel."  51. The continuing nature of Defendants' acts would necessitate a separate action by Plaintiffand each Class member for damages for each act and would subject Plaintiff, each Class 72 CIVIL DIVISION CASE NO. CLASS REPRESENTATION vs. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) .ú \I\\tfft \\ Defendants. Case No.:_ Judge: RQBYN FERRIS Plaintiff VS, SAMST.JNG ELECTRONTCS CO.. LTp.. SAMSUNC FLECTRONICS AMEzuCA. INC. Defendant II.  ROBYN FERRIS, AN INDIVIDUAL, ON BEHALF OF HERSELF AND ALL OTHERS SIMILARLY SITUATED,