29.  Just For Men® is a cosmetic hair care and dye product line intended to improve and  alter hair and facial hair color.   86.  Plaintiff brings this action on behalf of himself and as a representative of all others  who are similarly situated.  Pursuant to Rules 23(a), (b)(2), and/or (b)(3) of the Federal Rules of  Civil Procedure, Plaintiff seeks certification of a Nationwide Class and a California Class.   87.  The Nationwide Class is initially defined as follows:  All African American males residing in the United States who have  purchased, used and incurred injury as a result of using the Just For  Men® Jet Black color shade within the applicable statute of  limitations, subject to appropriate tolling and estoppel (the  “Nationwide Class”).   88.  The California Class is initially defined as follows:  All African American males residing in California who have  purchased, used and incurred injury as a result of using the Jet Black  color shade within the applicable statute of limitations, subject to  appropriate tolling and estoppel (the “California Class”).   96.  Plaintiff incorporates by reference each and every paragraph of this Complaint as if  fully set forth herein.   97.  Plaintiff brings this claim individually and on behalf of the members of the  Nationwide Class against Defendants.   98.  The Civil Rights Act of 1866, as amended 42 U.S.C. § 1981, guarantees that “[a]ll  persons within the jurisdiction of the United States shall have the same rights…to make and  enforce contracts…as is enjoyed by white citizens, includ(ing) the making, performance,  modification, and termination of contracts, and the enjoyment of all benefits, privileges, terms,  and conditions of the contractual relationship.”     Violation of 42 U.S.C. § 1981   (By Plaintiff and the Nationwide Class Against Defendants)  