10. As reflected on the “Avis-Prouder” website page attached as Exhibit B, AVIS  continues to make such discounts available to gay and lesbian renters, albeit with the AWD code  15. Plaintiff brings this action as a class action pursuant to Rule 23(b)(3) and/or  23(b)(2) of the Federal Rules of Civil Procedure.         16. The Class is defined as follows:  All persons who rented cars from AVIS at locations in the State of  California during the period from September 15, 2010 through the  date of class certification and who were charged a rate that  exceeded the rate available for a comparable rental by using the  IGLTA or NGLCC AWD Codes.  17. Excluded from the Class are Defendant’s employees and affiliates as well as any  judicial officers who may be assigned to this matter.    18. The members of the Plaintiff Class are so numerous that joinder of all members  would be impracticable.  Plaintiff believes that there are many thousands of members in the  proposed Class, who can be readily identified from AVIS’ computer records.   20. Plaintiff's claims are typical of the claims of the members of the Class as all  members of the Class were similarly affected by Defendant’s wrongful conduct.   21. Plaintiff will fairly and adequately protect the interests of the members of the  Class and has retained counsel competent and experienced in consumer class action litigation.    22. Defendant has acted or refused to act on grounds that apply generally to the Class  so that final injunctive relief or corresponding declaratory relief is appropriate respecting the  Class as a whole.   23. A class action is superior to all other available methods for the fair and efficient  adjudication of this controversy since joinder of all members would be impracticable.   Furthermore, as the injuries suffered by individual Plaintiff Class members may be relatively  small, the expense and burden of individual litigation make it impracticable for members of the  Class to individually redress the wrongs done to them. There will be no difficulty in the  management of this action as a class action. VI. 24. Plaintiff hereby incorporates by reference each of the preceding allegations as  though fully set forth herein.   26.   Civil Code Section 51.5 further provides that:  No business establishment of any kind whatsoever shall discriminate against . . . or trade with any person in this state on account of any characteristic listed or defined  in subdivision (b) or (e) of Section 51, or of the person’s partners, members,  stockholders, directors, officers, managers, superintendents, agents, employees,   business associates, suppliers, or customers, because the person is perceived to have  one of more of those characteristics, or because the person is associated with a person  who has, or is perceived to have any of those characteristics. [Emphasis added]   27. The Act’s remedial provisions are set forth in Civil Code Section 52(a), which  provides: Whoever denies, aids or incites a denial, or makes any discrimination or distinction  contrary to Section 51, 51.5, or 51.6, is liable for each and every offense for the actual  damages and any amount that may be determined by a jury, or a court sitting without  a jury, up to a maximum of three times the amount of actual damage but in no case  less than four thousand dollars ($4,000), and any attorney’s fees that may be  determined by the court in addition thereto, suffered by  any person denied the rights  provided in Section 51, 51.5, or 51.6.  28. Plaintiff and the Class members were injured by AVIS’ violations of Civil Code  Section 51 et seq. and bring this action to recover statutory damages and attorney’s fees.    29. Plaintiff hereby incorporates by reference each of the preceding allegations as  though fully set forth herein.   31. By its actions described above, Defendant violated and continues to violate the  UCL in that it has engaged and continues to engage in unlawful business practices within the  meaning of the UCL, specifically violations of the Unruh Act.   32. Defendant has engaged in an “unfair” business practice by charging numerous car  renters rates greater than those it makes available to persons who rent cars using the IGLTA and  NGLCC AWD Codes.  33. As a direct and proximate result of these acts, Plaintiff and the Plaintiff Class  have suffered injury in fact and have lost money and property through excessive charges to their  credit and debit cards.  34. Defendant received and continues to hold funds that rightfully should be restored  to Plaintiff and members of the Class. Pursuant to Section 17203 of the Business and Professions  Code, Plaintiff seeks an order and/or judgment from the Court (1) enjoining defendant from  engaging in practices which constitute illegal and unfair competition and (2) restoring to Plaintiff  and the Class all monies wrongfully acquired by Defendant by means of such practices, plus  interest.   8. AVIS is one of the world’s leading car rental brands.  It has extensive operations  throughout the State of California, including at least 12 locations in San Diego County.  9.   In or about September 2010, AVIS “signed a three year partnership with the International Gay and Lesbian Travel Association (IGLTA) that provides gay renters with  discounted car rentals.” September 15, 2010 SDGLN.com article, attached as Exhibit A. The  article further states that “[t]he Avis Worldwide Discount (AWD) number B450300 provides  savings of up to 25 percent on global rates.”  Cite the U.S. Civil Statute under which you are filing  (Do not cite jurisdictional statutes unless diversity): Brief description of cause: VII.  REQUESTED IN Violations of Cal. Bus. & Prof. Code §17200   Violations of the Unruh Civil Rights Act California Civil Code, Section 51 et seq. 