11.  The claims of the named Plaintiff Bouas are typical of the claims of the Class.  Plaintiff’s claims are typical of those of other members of the Class as there are no material  differences in the facts and law underlying the claims of Plaintiff and the Class, and by prosecuting  his claims, Plaintiff will advance the claims of class members.    12.  While the exact number of class members is unknown to Plaintiff now, the Class— upon information and belief—contains thousands of members. The potential class members are so  numerous that joinder of all members of the Class is impracticable.  Commonality And Predominance   14.  These common questions of law and fact among all class members predominate  over any issues affecting individual members of the class.  Superiority   15.  Class treatment of the claims set forth herein is superior to other available methods  for the fair and efficient adjudication of this controversy. The expense and burden of individual  litigation would make it impracticable or impossible for proposed class members to prosecute their  claims individually. Absent a class action, a multiplicity of individual lawsuits would be required  to address the claims between class members and Harley-Davidson, and inconsistent treatment and  adjudication of the claims would likely result.   16.  The litigation and trial of Plaintiff’s claims is manageable. The defects affecting the  subject 2008-2010 Harley-Davidson Touring model motorcycles were common across all models  and model years of the subject motorcycles, and Harley-Davidson maintains records making these  motorcycles, and their purchasers, easily identifiable. The consistent provisions of the relevant  laws, and the readily ascertainable identities of the subject motorcycles and many class members  demonstrate that there would be no significant manageability problems with prosecuting this  lawsuit as a class action.   18.  Under Federal Rule of Civil Procedure 23(b)(2), Harley-Davidson has acted and  refused to act on grounds that apply generally to the Class as a whole, making injunctive and  declaratory relief appropriate.   19.  The conduct at issue—Harley-Davidson’s practices in refusing to disclose the  existence of a dangerous defect in 2008–2010 Touring and CVO Touring models—apply to all  members of the putative Class equally. This conduct is ongoing. A finding that such conduct is  unlawful and changes to those practices will apply to all class members equally.  20.  Harley-Davidson manufactures motorcycles for sale to the public.   21.  Harley-Davidson added an optional anti-lock braking system (“ABS”) to its 2008  model year Touring and CVO Touring model motorcycles, which went on sale to the public in  September 2007.   22.  Because it was an optional feature, Harley-Davidson charged significantly more for  motorcycles with ABS as opposed to previous and non-ABS motorcycles. For instance, the list  price of a 2007 Harley-Davidson Road King Classic was $18,255.1 The list price of a 2008 Harley- Davidson Road King Classic with ABS was $19,320.2 Harley-Davidson suggested a list price of  $795 for the ABS option on its Touring and CVO Touring motorcycles.3   1  Pricing  information  obtained  from  9.  Plaintiff brings this action as a class action pursuant to Rules 23(b)(2) and (3) of  the Federal Rules of Civil Procedure, and proposes the following class:  All individuals and entities in Illinois who purchased or leased a  model year 2008 – 2010 Harley-Davidson Touring or CVO Touring  model Motorcycle (the “Class Motorcycle”).    Allegations Common To All Class Members  