25.  UC is one of the nation’s most prestigious public university systems.    26.  UC charges students for both tuition and fees on a per-term basis, with  some UC schools maintaining academic calendars based on quarters and others  based on trimesters.   27.  UC San Diego primarily operates on a quarterly academic calendar with  Fall, Winter, Spring and Summer terms.    46.  Pursuant to Fed. R. Civ. P. 23(a), (b)(2), (b)(3), and/or (c)(4), Plaintiff  brings this action on behalf of himself and the following Class:  All persons who paid tuition, fees, and/or other costs to the University  of California for 1) in-person classes for the Spring 2020 term or a  subsequent term and 2) who did not receive the benefits for which they  paid.   53.  Plaintiff repeats and re-alleges the allegations in the preceding  paragraphs as if fully alleged herein.    54.  Plaintiff brings this claim individually and on behalf of the other  members of the Class.    55.  Plaintiff and the other members of the Class entered into binding  contracts with the Defendant which provided that Plaintiff and the other members of  the Class would pay tuition and fees in exchange for on-campus, in-person  educational, social, athletic, and other experiences.   56.  As part of its contracts with Plaintiff and members of the proposed  Class and in exchange for adequate consideration that Plaintiff and members of the  proposed Class provided, Defendant promised on-campus, in-person educational,  social, athletic, and other experiences.   57.  Defendant failed to provide the services that it was obligated to provide  under its contracts with Plaintiff and the proposed Class. Defendant has retained  tuition, fees and other payments paid by Plaintiff and the other Class members  without providing them the promised benefits, instead providing those benefits for  only a portion of the academic term.   58.  By contrast, Plaintiff and the other members of the Class fulfilled their  end of the bargain when they paid the monies due and owing for their full tuition  and fees.    62.  Plaintiff repeats and re-alleges the allegations in the preceding  paragraphs as if fully alleged herein.    63.  Plaintiff brings this claim individually and on behalf of the other  members of the Class in the alternative to the breach of contract claim brought in  Count I.    64.  Plaintiff and other members of the proposed Class conferred a benefit  or enrichment on UC by paying tuition and required fees to UC which were  beneficial to UC, at the expense of Plaintiff and the other members of the Class.    65.  Plaintiff and the other members of the Class paid tuition and required  fees and did not receive the full benefit of their bargain from UC, thus resulting in  their impoverishment.   69.  Plaintiff repeats and re-alleges the allegations in the preceding  paragraphs as if fully alleged herein.    70.  Plaintiff brings this claim individually and on behalf of the Class.    71.  Plaintiff and the other members of the Class have a right to the in- person educational and extra-curricular services that they were supposed to be  provided in exchange for their payments to UC.   72.  Defendant intentionally interfered with the rights of Plaintiff and the  other members of the proposed Class when it retained fees intended to pay for on- campus classes, facilities, and activities, while moving all classes to an online,  remote learning format and discontinuing services and access to facilities for which  Plaintiff and the members of the proposed Class had paid.    73.  Defendant deprived the Plaintiff and the other members of the Class of  their fees or of the right to the services for which their fees were intended to be used.   74.  Class members demanded the return of the prorated, unused fees for the  remainder of the Spring 2020 term and subsequent terms.   77.  Plaintiff re-alleges each of the allegations in the preceding paragraphs  as if fully alleged herein.    78.  UC’s conduct is unfair in violation of the UCL because it violates  California’s legislatively declared public policy, as set out in the California  Education Code, including in the Donahoe Higher Education Act, against retention  by educational facilities of excess sums from students, and maintaining college  affordability. It also breaches UC’s agreements with its students.    79.  UC’s conduct also is unfair, in violation of the UCL, because UC acted  in an unethical, unscrupulous, tortious, oppressive, and substantially injurious  manner, including by:  a.  Assessing fees for services students could not safely use or  were barred from using;   b.  Refusing to refund fees to students who could not reasonably or  responsibly avail themselves of the services the fees were paid for;  and  c.  Failing to abide by its promises to students with respect to the  education the students would receive.   A.  The UC System   Breach of Contract   Conversion   Restitution Based On Quasi-Contract   Unfair Conduct in Violation of the Unfair Competition Law   (Cal. Bus. & Prof. Code § 17200, et seq.)   V.  CLASS ACTION ALLEGATIONS ............................................................. 9  COUNT I  Breach of Contract ......................................................................................... 12 