17.  Ring offers a variety of Wi-Fi enabled security and safety devices, most  notably video doorbells and cameras. The Ring video doorbell is the company’s  flagship product. It is a smart doorbell that contains a high-definition camera, a  motion sensor, a microphone and speaker for two-way audio communication. It  integrates with an associated mobile app, which allows users to view real-time video  from the camera, receive notifications when the doorbell is rung, and communicate  with visitors at the door via the integrated speaker.    18.  In 2015, Ring released the first of its internal wireless IP cameras. Like  the video doorbell, the cameras provide high definition video and microphone-speaker  functionality for two-way communication. Since 2015, Ring has expanded its  selection to include a range of indoor and outdoor cameras, each with video and two- way audio communication. 1   58.  Plaintiff realleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   59.  Defendants had full knowledge of the purpose for which its security  cameras were being used and the sensitivity of the people and things the cameras were  designed to secure and protect.  Defendants also knew the types of harm that Plaintiff  and Class Members could and would suffer if the integrity of the cameras were  compromised.   60.  Defendants had a duty to exercise reasonable care in ensuring their  cameras were secure, safe to use and inviolable by unauthorized parties.  This duty  includes, among other things, ensuring that reasonable and proper protocols and  safeguards are in place, so that the Wi-Fi enabled cameras are not easily compromised  by unauthorized users.   61.  Plaintiff and Class Members were the foreseeable and probable victims  of any inadequate security practices and procedures. Defendants knew of or should  have known of the inherent risks of allowing Ring cameras to be set up and used  without adequate security protocols and safeguards.    68.  Plaintiff realleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   79.  Plaintiff realleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   80.  Defendants are in the business of manufacturing, designing, supplying,  marketing, advertising, warranting, and selling security cameras. Defendants  impliedly warranted to Plaintiff and Class Members that the Product was of a certain  quality, free from defects, fit for the ordinary purpose of observing and recording  events for the purpose of securing property and maintaining safety of its residents.   81.  The Ring cameras were and are unfit for ordinary use and not of  merchantable quality as warranted by Defendants because the Products are defective  in that they are not secure and can easily be hacked by unauthorized third parties.   Before purchase, Plaintiff and Class Members could not have readily discovered that  the cameras were not merchantable for use to protect their homes and occupants.     82.  Defendants have failed to provide adequate remedies under their limited  warranty, which have caused that warranty to fail of its essential purpose, thereby  permitting remedies under these implied warranties.   83.  Defendants had unequal bargaining power and misrepresented the  Products’ reliability and performance properties, and the limited remedies  unreasonably favor Defendants and fail Plaintiff’s reasonable expectations for product  performance.   85.  Plaintiff realleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   86.  Defendants sold Ring cameras to Plaintiff and Members of the Class for  which they received a benefit in the form of monetary payment.    87.  Defendants have acknowledged the benefit and accepted or retained the  benefit conferred.    88.  Implicit in the agreement between the Defendants and Plaintiff and Class  Members was to provide cameras that were suitable for their purpose and not designed  with flaws that render them vulnerable to hacking resulting in the compromise of user  safety and security.   89.  Without such implied contracts, Plaintiff and Class Members would not  have paid for and conferred a benefit upon Defendants, but rather chosen one of the  numerous alternative cameras that were available to them and which did not present a  hidden safety risk.    90.  Plaintiff and Class Members fully performed their obligations under the  implied contracts with Defendants, however, Defendants did not.   91.  Defendants breached the implied contracts with Plaintiff and Class  Members by failing to acknowledge the inherent vulnerability in their cameras. These  circumstances are such that it would be inequitable for Defendants to retain the benefit  received.    93.  Plaintiff realleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   94.  As the intended and expected result of their conscious wrongdoing,  Defendants have profited and benefited from the purchase of the Product by Plaintiff  and the Class.   95.  Defendants have voluntarily accepted and retained these profits and  benefits, with full knowledge and awareness that, as a result of Defendants’  misconduct, Plaintiff and the Class did not receive Product of the quality, nature,  fitness, or value that had been represented by Defendants, and that reasonable  consumers expected.   96.  Defendants have been unjustly enriched by their fraudulent and deceptive  withholding of benefits to Plaintiff and the Class at the expense of these parties.   97.  Equity and good conscience militate against permitting Defendants to  retain these profits and benefits.  As a direct and proximate result of Defendants’ unjust enrichment, Plaintiff and  Class Members suffered injury and seek an order directing Defendants’ disgorgement  and the return to Plaintiffs and the classes of the amount each improperly paid to  Defendants.  A. Ring Products and Wi-Fi Connectivity   BREACH OF THE IMPLIED WARRANTY OF MERCHANTABILITY   BREACH OF IMPLIED CONTRACT   INVASION OF PRIVACY   NEGLIGENCE   UNJUST ENRICHMENT  