20.  Wells Fargo has built its retail banking business by cross-selling its products and  encouraging its customers to maintain numerous accounts with the bank. Its drive to maximize accounts  per customer has led Wells Fargo to promote and tolerate fraudulent, deceptive, and illegal practices that  harm customers while inflating the bank’s bottom line.  A.  Wells Fargo Requires its Employees to Reach Unreasonable Quotas    21.  A centerpiece of Wells Fargo’s business model is getting each customer to maintain  multiple accounts. In a brochure published by Wells Fargo called “The Vision & Values of Wells  Fargo,” Wells Fargo states: “‘Going for gr-eight.’ Our average retail banking household has about six  products with us. We want to get to eight . . . and beyond. One of every four already has eight or more.  Four of every 10 have six or more.”   22.  In its 2014 Annual Report to the U.S. Securities and Exchange Commission, Wells Fargo  boasts about its “products” per customer and its “cross-sell strategy”: “Our vision is to satisfy all our  customers’ financial needs, help them succeed financially, be recognized as the premier financial  services company in our markets and be one of America’s great companies. Important to our strategy to  achieve this vision is to increase the number of our products our customers use and to offer them all of  the financial products that fulfill their financial needs.” That report further states: “Our cross-sell  strategy is to increase the number of products our customers use by offering them all of the financial  products that satisfy their financial needs.”   71.  This matter is brought by Plaintiff on behalf of herself and those similarly situated, under  Federal Rules of Civil Procedure 23(b)(2) and 23(b)(3).    81.  Plaintiff, a resident of Arizona, incorporates by reference each and every prior and  subsequent allegation of this Complaint as if fully restated here.    82.  The Arizona Consumer Fraud Act (“Act”) prohibits a variety of deceptive and fraudulent  practices in connection with the sale or advertisement of merchandise or products. The Act specifically  provides:  The act, use or employment by any person of any deception, deceptive act or practice, fraud,  false pretense, false promise, misrepresentation, or concealment, suppression or omission of any  material fact with intent that others rely upon such concealment, suppression or omission, in  connection with the sale or advertisement of any merchandise whether or not any person has in  fact been misled, deceived or damaged thereby, is declared to be an unlawful practice.  89.  Plaintiff incorporates by reference each and every prior and subsequent allegation of this  Complaint as if fully restated here.    96.  Plaintiff incorporates by reference each and every prior and subsequent allegation of this  Complaint as if fully restated here.   Asserted on Behalf of Plaintiff and the Class  Violations of Fair Credit Reporting Act § 1681 et seq.   Asserted on Behalf of Plaintiff and the Class  Violations of the Arizona Consumer Fraud Act   Asserted on Behalf of Plaintiff and the Class  Unjust Enrichment  