19. LDR operates various web sites through which it offers to pay for people’s used electronic products (the “LDR Web Sites”).  20. The LDR Web Sites (each of which begins with “www” and is followed by “.com”) include cashforapples, cashforberrys, cashforipads, cashforiphones, cashforlaptops, and ecyclebest.  22. By sending a Product to LDR, a Potential Seller agrees to be bound by LDR’s Terms and Conditions; and, therefore, a contract, in the form of LDR’s Terms and Conditions, is formed between LDR and the Potential Seller.  23. Before LDR receives a Product, LDR sends at least two e-mails to the Potential Seller.  25. With respect to thousands of Potential Sellers, LDR, more than three days after sending the Confirmation-of-Receipt E-Mail, sends an e-mail to a Potential Seller that states, “Your check has been printed and will be on its way to you in no time!” or contains materially similar language (the “Check E-Mail”).  26. The Check E-Mail does not inform the Potential Seller of the amount of the check.  27. A Potential Seller learns that the check is for the payment of a Lower Amount (the “Lower-Amount Payment Check”) upon the earlier of the following events: logging on to the Potential Seller’s account on the LDR Web Site or receiving the Lower-Amount Payment Check.  28. When a Potential Seller informs LDR that he had never received a Lower-Amount E-Mail Offer, LDR sends him an e-mail that purports to contain a copy of the Lower-Amount E-Mail Offer (the “Purported Copy”).  29. The Purported Copy is not in the form of a forwarded e-mail but merely purports to contain the information that was in a Lower-Amount E-Mail Offer.  30. LDR claims that the Purported Copy had been sent more than three days before the Potential Seller attempted to reject the purported Lower-Amount E-Mail Offer, as a result of which that attempt is too late under LDR’s Terms and Conditions.  31. No Lower-Amount E-Mail Offer had been sent to the Potential Seller.  32. The Lower Amount is a fraction of the Initial Quote.  34. With respect to thousands of Potential Sellers to whom LDR has sent a Lower- Amount E-Mail Offer and who have, in accordance with LDR’s Terms and Conditions, e-mailed a rejection of that offer, LDR, in breach of LDR’s Terms and Conditions, instructs such potential sellers to call LDR.  35. When a Potential Seller calls LDR in response to the instruction described in the preceding paragraph, LRS’s telephone lines are either busy or the hold times are exorbitant.  36. When an LDR employee is connected to a Potential Seller who makes the telephone call to LDR as described in paragraph “34,” the employee tells the Potential Seller that the Potential Seller must to speak to “purchasing,” upon which LDR transfers the call and either ultimately disconnects the call or has an employee tell the Potential Seller, without regard to the truth, that the Product is no longer in LDR’s possession and therefore cannot be returned.  37. Regardless of whether LDR inspects a Product, and regardless of the results of any such inspection, LDR, at all relevant times, intends not to pay more than a fraction of the Initial Quote for the Product.  38. LDR knowingly, and with the intent to defraud and deceive Potential Sellers, carries out the above-described practices for the purpose of forcefully acquiring Products for a fraction of the amount of the Initial Quote.  39. Prior to the creation of a contract between LDR and a Potential Seller, LDR has the intention of breaching that contract by engaging in the above-described practices.  40. LDR breaches its contracts with Potential Sellers by engaging in the above-described practices.  42. On October 5, 2014, Bank entered, on cashforiphones, the Product Information with respect to three Products (“Bank’s Products”).  43. Instantly following the entry of the information as described in the preceding paragraph, two of Bank’s Products were given an Initial Quote of $307, and the other Product was given an Initial Quote of $230.  44. On October 5, 2014, Bank received an e-mail from LDR whose subject line was “Here is your Pre-Paid Label, Ship your Apple today!,” and whose body stated, in relevant part, that “You can follow [a] link [provided in this e-mail] and re-print your prepaid shipping label.”  45. On October 5, 2014, Bank received, several minutes after having received the e-mail described in the preceding paragraph, three identical e-mails from LDR whose subject line was “Reset Password Request,” and whose body stated, in relevant part, “You requested a link to reset your password. Please set a new password by clicking the link provided below.”  46. On October 7, 2014, Bank received, with respect to each of Bank’s Products, an e- mail from LDR whose subject line was “Order [xxxxx6,or xxxxx7, or xxxxx8] Status: Thank You For Shipping Your Apple iPhone 5 16GB Verizon,” and whose body stated, in relevant part, “Your package should arrive at our processing center within the next 5-7 business days. The USPS tracking number for your device is . . . . You will also receive a notification email once we have received your package.”  47. On or about October 8, 2014, Bank, using the prepaid shipping label to which paragraph “44” refers, sent Bank’s Products to LDR.  49. On October 19, 2014, Bank received an e-mail from LDR whose subject line was “Order [xxxxx8] Status: Your Device Has Been Received,” and whose body, in relevant part, was the same as that described in the preceding paragraph.  51. On October 24, 2014, Bank received, several minutes after having received the e-mail described in the preceding paragraph, two identical e-mails from LDR whose subject line was “Reset Password Request” and whose body stated, in relevant part: “You requested a link to reset your password. Please set a new password by clicking the link provided below.”  52. On October 24, 2014, Bank logged onto his LDR account and learned that the LDR Checks were in the amounts of $23, 45, and $47.  53. On October 24, 2014, Bank, after learning the amounts of the LDR Checks, called LDR’s customer-service telephone number and was told by LDR’s customer-service personnel that LDR had sent him three Lower-Amount E-Mail Offers, that is, one for each of Bank’s Products, and that LDR deemed Bank to have accepted each offer by not responding to it within three days.  54. No Lower-Amount E-Mail Offer had been sent to Bank.  55. On October 24, 2014, Bank, after his conversation with LDR’s customer-service personnel, received three identical e-mails from LDR whose subject line was “Copy of payment email.”   59. On October 31, 2014, LDR, in response to a complaint that Bank filed with the Better Business Bureau, called Bank and told him that LDR would send him an additional check so that the total amount of payment to Bank would be equal to the total amount of the Initial Quotes that had been given to him.  60. On or about November 5, 2014, Bank received a Lower-Amount Payment Check for $115, and on or about November 12, 2014, Bank received the check to which the preceding paragraph refers. 62.  LDR has engaged in fraud upon Bank and the other Members of the Class, thereby wrongfully depriving them of their property.  63. As a result of LDR’s fraud, Bank and the other Members of the Class are entitled to compensatory damages, punitive damages, and other appropriate relief under the laws of each of the fifty States and the District of Columbia. 64. Bank incorporates herein each and every allegation contained in paragraphs “1” through “60.”  65.  LDR has breached its contracts with Bank and the other Members of the Class, thereby wrongfully depriving them of their property.  66. As a result of LDR’s breaches, Bank and the other Members of the Class are entitled to compensatory damages and other appropriate relief under the laws of each of the fifty States and the District of Columbia. 67. Bank incorporates herein each and every allegation contained in paragraphs “1” through “60.”  68.  LDR has breached the implied covenant of good faith and fair dealing in engaging in a contractual relationship with Bank and the other Members of the Class, thereby wrongfully depriving them of their property.  70. Bank incorporates herein each and every allegation contained in paragraphs “1” through “60.”  71.  LDR is liable to the Class Members under the following laws of the respectively listed states and the District of Columbia: Alabama Deceptive Trade Practices Act, Ala. Code §§ 8-19-1 - 8-19-15  72. LDR has violated Ala. Code § 8-19-5(27), entitling class members to $100 per violation under Ala. Code § 8-19-10(a)(1). Alaska Alaska Unfair Trade Practices and Consumer Protection Act, Alaska Stat. §§ 45.50.471 - 45.50.561  73. LDR has violated Alaska Stat. §§ 45.50.471(a), (b)(11), and (b)(12), entitling class members to $500 per violation under Alaska Stat. § 45.50.531(a). Arizona Consumer Fraud Act, Ariz. Rev. Stat. §§ 44-1521 - 44-1534  74. LDR has violated Ariz. Rev. Stat. § 44-1522(A), entitling class members to actual damages under Freeway Mobile Homes Sales, Inc., 521 P.2d 1119 (Ariz. 1974). Arkansas Deceptive Trade Practices Act, Ark. Code Ann. §§ 4-88-101 - 4-88-503  76. LDR has violated Calif. Bus. & Prof. Code § 17500, entitling class members to restitution and injunctive relief under Calif. Bus. & Prof. Code § 17203. Colorado Colorado Consumer Protection Act, Colo. Rev. Stat. §§ 6-1-101 - 6-1-115  77. LDR has violated Colo. Rev. Stat. § 6-1-105(1)(e), entitling class members to the greater of actual damages, $500 per violation, or three times the amount of actual damages if it is established by clear and convincing evidence that LDR engaged in bad-faith conduct, under Colo. Rev. Stat. § 6-1-113(2)(a). Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. §§ 42-110a - 42-110q  78. LDR has violated Conn. Gen. Stat. § 42-110b(a), entitling class members to actual damages, punitive damages in the discretion of the Court, and, as the Court deems necessary or proper, equitable relief, under Conn. Gen. Stat. § 42-110g(a). Delaware Consumer Fraud Act, 6 Del. C. §§ 2511-2527  79. LDR has violated 6 Del. C. § 2513(a), entitling class members to actual damages under 6 Del. C. § 2525(a). District of Columbia Consumer Protection Procedures Act, D.C. Code §§ 28-3901 - 28-3913  81. LDR has violated Fla. Stat. § 501.204(1), entitling class members to actual damages under Fla. Stat. § 501.211(2). Georgia Fair Business Practices Act of 1975, Ga. Code Ann. §§ 10-1-390 - 10-1-407  82. LDR has violated Ga. Code Ann. § 10-1-393(a), entitling class members, who comprise natural persons who made their purchases primarily for personal, family, or household purposes as provided by Ga. Code Ann. §§ 10-1-392(a)(6) and (10), to general damages, exemplary damages if the violations were committed intentionally, and equitable injunctive relief under Ga. Code Ann. § 10-1-399(a), and three times actual damages Ga. Code Ann. § 10-1-399(c). Hawaii Haw. Rev. Stat. §§ 480-2  83. LDR has violated Haw. Rev. Stat. § 480-2(a), entitling class members, who comprise natural persons who made their purchases primarily for personal, family, or household purposes as provided by Haw. Rev. Stat. § 480-1, $1,000 per violation under Haw. Rev. Stat. § 480-13(b)(1) and injunctive relief under Haw. Rev. Stat. § 480-13(b)(2). Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 - 815 ILCS 505/12  84. LDR has violated 815 ILCS 505/2, entitling class members to actual economic damages or any other relief that the Court deems proper under 815 ILCS 505/10a(a). Kansas Consumer Protection Act, Kan. Stat. Ann. §§ 50-617 - 50-6,115  86. LDR has violated Ky. Rev. Stat. § 367.170(1), entitling class members, who comprise persons and entities that made their purchases primarily for personal, family, or household purposes as provided by Ky. Rev. Stat. § 367.220(1), to actual damages in the discretion of the Court, and equitable relief as the Court deems necessary or proper, in the discretion of the Court under Ky. Rev. Stat. § 367.220(1). Louisiana Unfair Trade Practices and Consumer Protection Law, La. Rev. Stat. §§ 51:1401 - 51:1418  87. LDR has violated La. Rev. Stat. § 51:1405(A), entitling class members to actual damages under La. Rev. Stat. § 51:1409(A). Maine Maine Unfair Trade Practices Act, 5 Me. Rev. Stat. Ann. §§ 205-A - 214  88. LDR has violated 5 Me. Rev. Stat. Ann. § 207, entitling class members, who comprise persons and entities that made their purchases primarily for personal, family, or household purposes as provided by 5 Me. Rev. Stat. Ann. § 213(1), to actual damages, restitution, and such other equitable relief, including an injunction, as the Court determines to be necessary and proper under 5 Me. Rev. Stat. Ann. § 213(1). Maryland Consumer Protection Act, Md. Code Ann. §§ 13-101 to 13-501  90. LDR has violated Mass. Gen. Laws ch. 93A, § 2(a), entitling class members to $25 per violation, and between $50 and $75 per violation if such violations were committed willfully or knowingly under Mass. Gen. Laws ch. 93A, §§ 9(1) and 9(3), and such equitable relief, including an injunction, as the Court deems to be necessary and proper under Mass. Gen. Laws ch. 93A, § 9(1). Michigan Michigan Consumer Protection Act, Mich Comp. Laws §§ 445.901 - 445.922  91. LDR has violated Mich Comp. Laws § 445.903(bb), entitling class members, who comprise persons and entities that made their purchases primarily for personal, family, or household purposes as provided by Mich Comp. Laws § 445.902(d), to $250 per violation under Mich Comp. Laws § 445.911 and injunctive relief under Mich Comp. Laws § 445.911(1)(b). Minnesota Minnesota Unlawful Trade Practices Act, Minn. Stat. §§ 325D.09 - 325D.16  92. LDR has violated Minn. Stat. §§ 325D.44(13), entitling class members to actual damages and other equitable relief as determined by the Court under Minn. Stat. § 8.31(3a). Mississippi Mississippi Consumer Protection Act, Miss. Code Ann. §§ 75-24-1 - 75-24-27  93. LDR has violated Miss. Code Ann. § 75-24-5(1), entitling class members, who comprise persons and entities that made their purchases primarily for personal, family, or household purposes as provided by Miss. Code Ann. § 75-24-15(1), to actual damages under Miss. Code Ann. § 75-24-15(1). Missouri Merchandising Practices Act, Mo. Rev. Stat. §§ 407.010 - 407.1500  95. LDR has violated Mont. Code Ann. § 30-14-103, entitling class members, who comprise persons and entities that made their purchases primarily for personal, family, or household purposes as provided by Mont. Code Ann. § 30-14-102(1), to $500 per violation and any other equitable relief that the Court considers necessary or proper under Mont. Code Ann. § 30-14-133(1). Nebraska Consumer Protection Act, Neb. Rev. Stat. §§ 59-1601 - 59-1622  96. LDR has violated Neb. Rev. Stat. § 59-1602, entitling class members to actual damages; additional damages, in the discretion of the Court up to$1,000, of an amount that bears a reasonable relation to the actual damages that have been sustained and which are not susceptible to measurement by ordinary pecuniary standards; injunctive relief, under Neb. Rev. Stat. § 59-1609. Nevada Deceptive Trade Practices Act, Nev. Rev. Stat. §§ 598.0903 - 598.0999  97. LDR has violated Nev. Rev. Stat. § 598.0915(15),  entitling class members to actual damages under Nev. Rev. Stat. §§ 41.600(1), (2)(e), and (3)(a). New Hampshire Regulation of Business Practices for Consumer Protection law, N.H. Rev. Stat. Ann. §§ 358-A:1 - 358-A:13  A. Defendant’s Scheme  [Breach of Contract]  [Breach of the Implied Covenant of Good Faith and Fair Dealing]  [Consumer-Protection Laws]  [Fraud] 