19.  Ring holds itself out to the public as a leader in home security which  manufactures home security products that incorporate indoor and outdoor motion-detecting  cameras, including Ring video doorbells and security cameras.   20.  The Ring video doorbell is the company’s flagship product. The first version of  the Ring video doorbell (hereinafter, the “Ring Video Doorbell 1”) was introduced in 2013.  The Ring video doorbell products are marketed as a smart doorbell that contains a high- definition video camera, a motion sensor, and a microphone and speaker for two-way  communication.   21.  The Ring video doorbell integrates with an associated smartphone “app,” which  allows users to view real-time and recorded video from the camera, receive notifications when  the doorbell is rung, communicate with visitors at the door, and share the recorded video and  snapshots with friends and family.    22.  In 2015, Ring came out with its first video security camera, called the “Ring  Indoor Cam Plug-In Security Camera,” which is a camera with “live-feed” viewability and  video recording and playback features. The Ring Indoor Cam Plug-In Security Camera was  updated in 2018 with motion detection and two-way audio.   88.  Plaintiff brings this action as a class action on behalf of a class defined as:   All United States citizens who, during the applicable  limitations period, (a) purchased a Ring video doorbell or  security camera at a brick and mortar store in the United  States where the outside box did not contain any language  indicating that the video recording, playback or snapshot  features of the product could only be accessed if the consumer  also purchased a Protect Plan subscription for an additional  monthly or annual fee, and (b) signed up for the Protect Plan.    89.  Plaintiff also brings this action as a class action on behalf of a subclass defined  as:  All United States citizens who, during the applicable  limitations period, purchased a “Ring Video Doorbell 2” at a  brick and mortar store in the United States and signed up for  the Ring Protect Plan.    90.  Specifically excluded from the class and subclass are Defendant, any entity in  which a Defendant has a controlling interest or which has a controlling interest in Defendant,  Defendant’s agents and employees and attorneys, the bench officers to whom this civil action is  assigned, and the members of each bench officer’s staff and immediate family.   91.  Numerosity. Plaintiff does not know the exact number of class members, but is  informed and believe that the classes easily comprise tens of thousands of individuals. As such,  class members are so numerous that joinder of all members is impracticable.   92.  No violations alleged in this complaint are a result of any oral communications  or individualized interaction of any kind between class members and Defendant, or of any  subject belief of Plaintiff or an individual class member.  