46.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth  at length herein.   47.  Plaintiff and Defendant are parties to a contract regarding the use of the Uber  platform, including terms regarding eligible vehicles stating that Acura MDX, Audi Q7, Chevrolet  LTZ, Chevrolet Tahoe, Ford Expedition (non-Platinum series), Infinity QX60, Mercedes GL  Class, Nissan Armada, Toyota Sequoia and/or other vehicles of an appropriate model year could  be used be in connection with the Uber BlackSUV service level.   49.  The conduct of Defendant was a direct and proximate cause, as well as a substantial  factor, in bringing about the serious injuries, actual damages and harm to the Plaintiff and the Class  that are outlined more fully above and, as a result, Defendant is liable to the Plaintiff and the Class  for the full amount of actual damages, as well as such further relief, as may be permitted by law.  50.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth  at length herein.   51.  In its business dealings with Plaintiff and other drivers in the State of New Jersey,  Uber repeatedly made binding representations or promises stating that Acura MDX, Audi Q7,  Chevrolet LTZ, Chevrolet Tahoe, Ford Expedition (non-Platinum series), Infinity QX60,  Mercedes GL Class, Nissan Armada, Toyota Sequoia and/or other vehicles of an appropriate  model year were eligible to be used in connection with Uber’s Uber BlackSUV service level.   52.  Uber made these representations or promises with the intent that Plaintiff and other  New Jersey-based drivers would rely on them in selecting vehicles to use on the Uber platform.   53.  Plaintiff and other New Jersey-based drivers reasonably relied upon Uber’s  representations and promises regarding vehicle eligibility in selecting vehicles.   55.  The conduct of Defendant was a direct and proximate cause, as well as a substantial  factor, in bringing about the serious injuries, actual damages and harm to the Plaintiff and the Class  that are outlined more fully above and, as a result, Defendant is liable to the Plaintiff and the Class  for the full amount of actual damages, as well as such further relief, as may be permitted by law.  56.  Plaintiff incorporates the foregoing paragraphs as though the same were set forth  at length herein.   57.  The agreement between Plaintiff and Defendant regarding access to the Uber  platform contained an implied covenant of good faith and fair dealing.   58.  By, contrary to its prior representations, terminating the ability of Plaintiff and other  drivers of otherwise eligible Acura MDX, Audi Q7, Chevrolet LTZ, Chevrolet Tahoe, Ford  Expedition (non-Platinum series), Infinity QX60, Mercedes GL Class, Nissan Armada, Toyota  Sequoia and/or vehicles from accessing the Uber BlackSUV service level, Defendant breached the  covenant of good faith and fair dealing.   59.  Defendant acted in bad faith and/or with a malicious motive to deny Plaintiff and  other drivers of some of the benefit of the bargain originally intended by the parties, thereby  causing Plaintiff and other drivers damages as outlined above.  Breach of Contract   Breach of the Covenant of Good Faith and Fair Dealing   Promissory Estoppel  