17.  Plaintiffs incorporate by reference all allegations contained in the preceding  paragraphs 1-16.    18.  Samsung manufactured televisions for the purposes of their eventual sale to  retail buyers. Samsung also appended to the goods express warranties.   19.  On or about March 2011, Samsung manufactured a television that Plaintiff  would eventually purchase. On or about April 2011, at San Rafael California, a retailer, Best  Buy, sold the Samsung television to Plaintiff at retail for roughly two thousand, four hundred  ($2,400.00) dollars.   20.  In connection with the sale, Plaintiff received Samsung's express warranty,  which accompanied the television. Plaintiff examined the sample of the television model used  as a demonstrator at the seller's premises. Plaintiff paid for an additional four year warranty at  the time of the sale.   21.  On or about March 2016, Plaintiff discovered that the television exhibited a  failure in utility or performance and failed to conform to the sample in that it began to cycle on  and off frequently.    26.  Plaintiff incorporates the allegations contained in the preceding paragraphs 1-25.   27.  Samsung has violated Cal. Bus. and Prof. Code §17200 et seq. by engaging in  unlawful business acts and practices that constitute acts of “unfair competition” as defined in  Cal. Bus. Prof. Code §17200 with respect to the services provided to the California Class.   28.  Samsung engaged in unlawful acts and practices in violation of the Song- Beverly Act as alleged above and the Consumers Legal Remedies Act as alleged below.   29.  As a direct and proximate result of Samsung’s unlawful acts, Plaintiff and the   class members were injured and lost money or property, including but not limited to the  purchase price they paid to Samsung for their televisions.    31.  Plaintiff incorporates the allegations contained in the preceding paragraphs 1-30.   32.  Samsung engaged in unfair acts and practices by the acts alleged above. These  unfair acts and practices were immoral, unethical, oppressive, unscrupulous, unconscionable,  and/or substantially injurious to Plaintiff and class members. They were likely to deceive the  public. The harm these practices caused to Plaintiff and the class members outweighed their  utility, if any.   33.  As a direct and proximate result of Samsung’s unfair practices and acts, Plaintiff  and the  class members were injured and lost money or property, including but not limited to  the purchase price they paid to Samsung for their televisions.   34.  Defendant has engaged in, and continues to engage in, business practices that  violate the UCL by continuing to make false and misleading representations on their labeling of  the Product.  35.  Plaintiff incorporates the allegations contained in the preceding paragraphs 1-34.   36.  Samsung’s conduct alleged above was fraudulent and deceptive. Samsung’s  omission to disclose that it would not provide repair parts for seven years was likely to deceive  Members of the public, including Plaintiff and the class members. Plaintiff and the class  members relied on this omission in purchasing their Samsung televisions.    37.  As a direct and proximate result of Samsung’s deceptive practices and acts,  Plaintiff and the class members were injured and lost money or property, including but not  limited to the price received by Samsung for their televisions.    39.  Plaintiff incorporates the allegations contained in the preceding paragraphs 1-38.   40.  Plaintiff and Members of the proposed Class were consumers within the  meaning of Civil Code § 1761(d).   41.  Samsung's conduct violates Civil Code § 1770(a)(5), which prohibits:  "[r]epresenting that goods or services have sponsorship, approval, characteristics, ingredients,  uses, benefits, or quantities which they do not have..."   42.  Samsung's conduct violates Civil Code § 1770(a)(7), which prohibits  "[r]epresenting that goods or services are of a particular standard, quality, or grade, or that  goods are of a particular style or model, if they are of another."   43.  Samsung's conduct violates Civil Code § 1770(a)(9), which prohibits  "[a]dvertising goods or services with intent not to sell them as advertised."   44.  Defendant is a “Person” as defined by Cal. Civ. Code § 1761(c).   45.  The transaction(s) involved here are “Transaction(s)” as defined by Cal. Civ.  Code § 1761(e).   46.  Plaintiff and the Members of the Class have standing to pursue this cause of  action because they have suffered injury-in-fact and have lost money or property as a result of  Defendant’s actions as set forth here.   47.  Plaintiff and the Members of the Class purchased their Samsung televisions in  reliance on Defendant’s labeling and marketing and omission to disclose that it would not  provide repair parts for seven years as required by law.   48.  Defendant has used deceptive representations with respect to the Product in  violation of Cal. Civ. Code §1770(a)(4).   Violation of California’s Unfair Competition Law  Cal. Bus. & Prof. Code §17200 – Unlawful Business Practices   Violation of Consumers Legal Remedies Act (Civ. Code § 1750 et seq.)   Violation of Song-Beverly Consumer Warranty Act   CAL. CIV. CODE §§ 1792 et seq.   Violation of California’s Unfair Competition Law  Cal. Bus. & Prof. Code §17200 – Unfair Business Practices   Violation of California’s Unfair Competition Law  Cal. Bus. & Prof. Code §17200 – Fraudulent/Deceptive Business Practices  