(CONVERSION AND MISAPPROPRIATION)  111.  The allegations contained in the previous paragraphs are incorporated by  reference.  112.  Plaintiff brings this claim on behalf of the Nationwide Class under the laws of all  states.  113.  Defendants have no authority to charge and collect “Taxes & Fees” amounts in  excess of the taxes and fees owed to the appropriate governmental authorities for each  reservation transaction; they are certainly not entitled to retain the overcharges as extra revenue.  114.  Defendants’ collection of overcharged “Taxes & Fees” constitutes a conversion  and misappropriation of funds belonging to Plaintiff and the Class members.  115.  On information and belief, the conversion and misappropriation of these funds is  illegal, unjustified, intentional, and deliberate.  Defendants’ conduct is, at a minimum, indicative  of wanton and reckless neglect.  116.  Accordingly, Plaintiff and the Nationwide Class members are entitled to actual  damages as determined by a jury at trial.  1.  The Tax Fraud Enterprise   1.  The Tax Fraud Enterprise ........................................................................ 16   2.  Mail and Wire Fraud ................................................................................ 20  21.  Reservations.com claims to offer bookings at 250,000 hotels around the world  through its website and call centers.  The Reservations.com website came online in April of  2014, and the website now boasts that Reservations.com has booked “4 million room nights” for  its customers.   22.  All the hotel rooms listed on Reservations.com are provided by Expedia  subsidiaries (including EAN, Travelscape, and Hotels.com) and other third-party suppliers.   23.  Reservations.com does not contract with hotels directly.  Instead, EAN and other  third-party suppliers coordinate Reservations.com customers’ bookings with the hotels, collect  the room rate and the “Taxes & Fees,” and remit some of these monies to the hotels and,  sometimes, directly to governmental taxing authorities.  Reservations.com is not involved in the  “Taxes & Fees” collection and remission process.   24.  Sunil Bhatt, one of the co-founders of Reservations.com, was the Vice-President  and General Manager of EAN from 2009 until June of 2011.   Mr. Bhatt served as CEO of  Reservations.com from June 2014 until July of 2015.   25.  Reservations.com indicates on its website that it has a “partnership” with Expedia.   On information and belief, Expedia has provided Reservations.com with a significant portion of  the 4 million room nights sold on the Reservations.com website.   26.  So close is the relationship between Reservations.com and Expedia that Expedia  operated a call center for Reservations.com from April 2014 until April of 2017.   27.  Expedia sells hotel reservations through many different channels, including its  own websites (most notably, expedia.com., hotels.com, orbitz.com, travelocity.com, and  hotwire.com), and through EAN, which Expedia describes as its “purely partner-focused arm.”   EAN provides room inventory to online retailers, including Reservations.com.    74.  Plaintiff incorporates by reference each preceding paragraph as though fully set  forth herein.   75.  Plaintiff brings this Count on behalf of the Nationwide Class against Defendants  Expedia, EAN, Travelscape, and Hotels.com.   76.  The Defendants are “persons” under 18 U.S.C. § 1961(3) because they are  capable of holding, and do hold, a “legal or beneficial interest in property.”   77.  Expedia, EAN, Travelscape, and Hotels.com, along with other entities and  individuals, including Reservations.com, were associated with, and conducted or participated in  the affairs of, a RICO enterprise (the “Tax Fraud Enterprise”), whose purpose was to deceive  consumers into believing they were paying a legitimate “Taxes & Fees” charge.   A.  Nationwide Class ................................................................................................. 13  B.  Washington Subclass ........................................................................................... 13  A.  Expedia, not Reservations.com, determines the amount of the “Taxes & Fees,” and  collects that amount directly from Reservations.com’s customers.   A.  Expedia, not Reservations.com, determines the amount of the  “Taxes & Fees,” and collects that amount directly from  Reservations.com’s customers. .............................................................................. 5  B.  Plaintiff’s experience ............................................................................................. 9  C.  The Tax Overcharge practice occurs throughout the United States. ................... 10  V.  COUNT III  (UNJUST ENRICHMENT) .................................................................................... 24  COUNT IV  (CONSTRUCTIVE TRUST) .................................................................................. 25  COUNT V  (VIOLATIONS OF THE WASHINGTON CONSUMER  INFLUENCED AND CORRUPT ORGANIZATIONS ACT (“RICO”) ........................ 16   VIOLATION OF 18 U.S.C. § 1962(C)–(D):  THE RACKETEER INFLUENCED AND CORRUPT  ORGANIZATIONS ACT (“RICO”)  