97.  The experiences of Plaintiff Torres at NCU were similar to those experienced by  numerous other students attempting to navigate NCU’s doctoral programs across all NCU’s doctoral  disciplines.    98.  NCU’s marketing materials (e.g., webpages) available to all prospective students  uniformly promised shorter timeframes to program completion than was supported.    99.  Further, when NCU recruiters made personal representations to students about shorter  timeframes to graduate, upon information and belief, they did so from recruitment materials/scripts  which contained false timelines to completion within them. Such recruitment materials/scripts would  provide the basis for such uniform misrepresentations.   100.  Plaintiff requests that the Court certify this lawsuit as a class action pursuant to Rule 23  of the Federal Rules of Civil Procedure.   101.  In the first instance, Plaintiff seeks certification of a nationwide Class under Arizona  law, including certification of claims for fraud in the inducement under Arizona law (First Cause of  Action), unjust enrichment under Arizona law (Second Cause of Action), breach of contract under  Arizona law (Third Cause of Action), violations of the Arizona Uniform Deceptive Trade Practices Act  (Fourth Cause of Action) and Breach of Implied Covenant of Good Faith and Fair Dealing under  Arizona Law (Fifth Cause of Action). Thus, Plaintiff seeks to certify the following nationwide Class  pursuant to Rule 23:   All current or former students of NCU who enrolled in and paid for a doctoral degree program from  NCU from 2006 until 2017 (“Arizona Nationwide Class”).   19  Breach of Contract Against NCU  (Under New Jersey Law on Behalf of Alternative New Jersey Sub-Class)  260.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   261.  Plaintiff Torres brings this cause of action in the alternative on behalf of a New Jersey  Subclass under New Jersey common law. NCU has systematically violated its contracts with Plaintiff  Torres and each member of the New Jersey Subclass.   262.  Plaintiff Torres and each member of the New Jersey Subclass contracted with NCU to  receive doctoral educational services. Implied in each contract was a covenant of good faith and fair  dealing.   263.  As part of the contract, NCU promised, inter alia, that, in connection with providing  doctoral educational services (1) dissertation/doctoral study committee members would work as a team,  directly guiding students through the various stages of the dissertation process including the proposal;  and (2) their respective programs could be completed in the promised time.   264.  Rather than provide doctoral educational services as per its contractual agreement, NCU  knowingly and intentionally created and implemented a process fraught with inefficiencies, meant to  ensure that students receive neither adequate resources, nor the timely responses and attention that they  were promised. All of this was done without honesty or transparency by NCU regarding the actual  length of time the doctoral programs would take and the expense that would be incurred by its doctoral  45  Breach of Implied Covenant of Good Faith and Fair Dealing Against NCU  (Under New Jersey Law on Behalf of Alternative New Jersey Subclass)  271.  Plaintiff realleges and incorporates the preceding allegations by reference as if set forth  fully herein.   272.  Plaintiff Torres brings this cause of action in the alternative on behalf of a New Jersey  Subclass under California common law. NCU has systematically violated its contracts with Plaintiff  Torres and each member of the New Jersey Subclass.   273.  Plaintiff Torres and each member of the New Jersey Subclass contracted with NCU to  obtain doctoral education services.   274.  Implied in each contract was a covenant of good faith and fair dealing.   275.  Plaintiff Torres and each member of the New Jersey Subclass provided value to NCU in  the form of tuition payments and other costs for their doctoral programs as contracted.   276.  By the scheme and conduct detailed herein, NCU has breached the implied duty of good  faith and fair dealing implied in its contracts.   47  Breach of Contract Against NCU  (Under Arizona Law on Behalf of the Arizona Nationwide Class)  142.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   143.  Plaintiff Torres brings this cause of action on behalf of a Nationwide Class under  Arizona common law. NCU has systematically violated its contracts with Plaintiff Torres and each  member of the Arizona Nationwide Class.   144.  Plaintiff Torres and each member of the Arizona Nationwide Class contracted with NCU  to receive doctoral educational services. Implied in each contract was a covenant of good faith and fair  dealing.   27  Breach of Contract Against NCU  (Under New York Law on Behalf of Alternative New York Sub-Class)  321.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   322.  Plaintiff Torres brings this cause of action in the alternative on behalf of a New York  Subclass under New York common law. NCU has systematically violated its contracts with Plaintiff  Torres and each member of the New York Subclass.   323.  Plaintiff Torres and each member of the New York Subclass contracted with NCU to  receive doctoral educational services. Implied in each contract was a covenant of good faith and fair  dealing.   53  Breach of Contract Against NCU  (Under California Law on Behalf of the California Nationwide Class)  196.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   197.  Plaintiff Torres brings this cause of action, on behalf of a Nationwide Class under  California common law. NCU has systematically violated its contracts with Plaintiff Torres and each  member of the California Nationwide Class.   198.  Plaintiff Torres and each member of the California Nationwide Class contracted with  NCU to receive doctoral educational services. Implied in each contract was a covenant of good faith  and fair dealing.   35  Breach of Implied Covenant of Good Faith and Fair Dealing Against NCU  (Under Arizona Law on Behalf of the Arizona Nationwide Class)  31  Breach of Implied Covenant of Good Faith and Fair Dealing Against NCU  (Under California Law on Behalf of California Nationwide Class)  227.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   228.  Plaintiff Torres brings this cause of action on behalf of a California Nationwide Class  under California common law. NCU has systematically violated its contracts with Plaintiff Torres and  each member of the California Nationwide Class.   229.  Plaintiff and each member of the California Nationwide Class contracted with NCU to  receive doctoral education services.   230.  Implied in each contract was a covenant of good faith and fair dealing.   231.  Plaintiff and each member of the California Nationwide Class provided value to NCU in  the form of tuition and fee payments for their respective doctoral programs as contracted.   232.  By the scheme and conduct detailed herein, NCU has breached the implied duty of good  faith and fair dealing implied in its contracts.   233.  This breach on the part of NCU has resulted in NCU doctoral students being damaged  because they were required to enroll in courses that would not have otherwise been necessary, thereby  41  Breach of Implied Covenant of Good Faith and Fair Dealing Against NCU  (Under New York Law on Behalf of Alternative New York Sub-Class)  332.  Plaintiff realleges and incorporates the preceding allegations by reference as if set forth  fully herein.   55  Fraud in the Inducement Against NCU  (Under Arizona Law on Behalf of the Arizona Nationwide Class)   24  Fraud in the Inducement Against NCU  (Under New York Law on Behalf of Alternative New York Sub-Class)    295.  Plaintiff brings this cause of action in the alternative on behalf of a state-wide Subclass  under New York common law.   296.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   297.  NCU made actual or implied false representations concerning the cost and length of time  to get a doctoral degree, while concealing the truth from prospective and actual students.  298.  NCU had a duty to disclose that NCU’s doctoral programs were designed to take much  longer than was represented to prospective students.  299.  Instead, NCU concealed how long NCU’s doctoral programs take to complete.  300.  For example, NCU intentionally misled Plaintiff Torres and each member of the New  York Subclass with statements that the program would take a shorter timeframe, and that Plaintiff  50  Fraud in the Inducement Against NCU  (Under New Jersey Law on behalf of alternative New Jersey Sub-Class)    234.  Plaintiff brings this cause of action in the alternative on behalf of a state-wide Subclass  under New Jersey common law.   235.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   236.  NCU made actual or implied false representations concerning the cost and length of time  to get a doctoral degree, while concealing the truth from prospective and actual students.  237.  NCU had a duty to disclose that NCU’s doctoral programs were designed to take much  longer than was represented to prospective students.  238.  Instead, NCU concealed how long NCU’s doctoral programs take to complete.  239.  For example, NCU intentionally misled Plaintiff Torres and each member of the New  Jersey Subclass with statements that the program would take a shorter timeframe, and that Plaintiff  Torres and each member of the New Jersey Subclass would have control over how quickly they could  complete the program.  240.  Instead, at the time Plaintiff Torres and each member of the New Jersey Subclass were  recruited and enrolled in their respective doctoral degrees, NCU concealed that the programs in which  they enrolled were designed to take longer than disclosed.  241.  Similar, if not identical, false representations and omissions were also made to other  members of the Subclass about their degree programs via recruiters, in NCU marketing materials, and  on NCU webpages.  42  Fraud in the Inducement Against NCU  (Under California Law on Behalf of the California Nationwide Class)   172.  Plaintiff brings this cause of action on behalf of a nationwide Class under California  common law.   173.  Plaintiff realleges and incorporates the preceding allegations by reference as if set forth  fully herein.   32  Unjust Enrichment Against NCU  (Under California Law on Behalf of the California Nationwide Class)  187.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   188.  Plaintiff Torres brings this cause of action on behalf of a Nationwide Class under  California common law.   189.  NCU has engaged in unjust conduct, to the detriment of Plaintiff Torres and each  member of the California Nationwide Class.   190.  Plaintiff Torres and each member of the California Nationwide Class provided  significant value to NCU in the form of tuition payments for doctoral program courses.   191.  NCU appreciated or had knowledge of the benefit received by retaining the money paid  by Plaintiff Torres and each member of the California Nationwide Class.   192.  Although NCU accepted the tuition payments and retained and received benefit  therefrom, it did not provide students with the doctoral programs that were promised and expected in  connection with the payment of the tuition. On the contrary, NCU intentionally and deliberately  34  Unjust Enrichment Against NCU  (Under Arizona Law on Behalf of the Arizona Nationwide Class)  133.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   134.  Plaintiff Torres brings this cause of action on behalf of a Nationwide Class under  Arizona common law.   135.  NCU has engaged in unjust conduct to the detriment of Plaintiff Torres and each  member of the Arizona Nationwide Class.   136.  Plaintiff Torres and each member of the Arizona Nationwide Class provided significant  value to NCU in the form of tuition and costs payments for doctoral program courses.   137.  NCU appreciated or had knowledge of the benefit received by retaining the money paid  by Plaintiff Torres and each member of the Arizona Nationwide Class.   138.  Although NCU accepted the tuition payments and retained and received benefit  therefrom, it did not provide students with the doctoral programs that were promised and expected in  connection with the payment of tuition and costs. On the contrary, NCU intentionally and deliberately  26  Unjust Enrichment Against NCU   (Under New Jersey Law on Behalf of Alternative New Jersey Sub-Class)  252.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   253.  Plaintiff Torres brings this cause of action in the alternative on behalf of a New Jersey  Subclass under New Jersey common law. NCU has engaged in unjust conduct, to the detriment of  Plaintiff Torres and each member of the New Jersey Subclass.   254.  Plaintiff Torres and each member of the New Jersey Subclass provided significant value  to NCU in the form of tuition and fee payments.   255.  NCU appreciated or had knowledge of the benefit received by retaining the money paid  by Plaintiff Torres and each member of the New Jersey Subclass.   256.  Although NCU accepted the tuition and fee payments and retained and received benefit  therefrom, it did not provide students with the doctoral process that was promised and contemplated in  connection with the payment of tuition. To the contrary, NCU intentionally and deliberately used its  doctoral programs as a means of improperly extracting tuition and fees and generating revenue. NCU  has intentionally and knowingly created and implemented doctoral programs fraught with  inefficiencies, meant to ensure that students do not receive the timely responses and attention that they  were promised. All of this was done without any honesty or transparency by NCU regarding the actual  time and expense that NCU’s doctoral students would incur to complete their degrees.   257.  This unjust conduct on the part of NCU has resulted in its doctoral students enrolling in  more courses than would be necessary had NCU not acted unjustly and incurring significant additional  tuition and costs. It has also caused certain New Jersey Subclass members to stop pursuing their  doctoral degrees.  44  Unjust Enrichment Against NCU   (Under New York Law on Behalf of Alternative New York Sub-Class)  313.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.   314.  Plaintiff Torres brings this cause of action in the alternative on behalf of a New York  Subclass under New York common law. NCU has engaged in unjust conduct, to the detriment of  Plaintiff Torres and each member of the New York Subclass.   315.  Plaintiff Torres and each member of the New York Subclass provided significant value  to NCU in the form of tuition and fee payments.   316.  NCU appreciated or had knowledge of the benefit received by retaining the money paid  by Plaintiff Torres and each member of the New York Subclass.   317.  Although NCU accepted the tuition and fee payments and retained and received benefit  therefrom, it did not provide students with a doctoral process that was promised and contemplated in  connection with the payment of the tuition. To the contrary, NCU intentionally and deliberately used its  doctoral programs as a means of improperly extracting tuition and generating revenue. NCU has  52  Untrue and Misleading Advertising in Violation of Cal. Bus. & Prof.  Code §17500 et seq.   (On behalf of California Nationwide Class)  222.  Plaintiff re-alleges and incorporates by reference the allegations contained in the  paragraphs above as if fully set forth herein.  223.  Plaintiff Torres brings this cause of action, on behalf of a Nationwide Class under  California Business & Professions Code §17500.  224.  California Business & Professions Code §17500 prohibits various deceptive practices in  connection with the dissemination in any manner of representations which are likely to deceive  members of the public to purchase products and services such as enrollment and re-enrollment in  NCU’s doctoral programs.  225.  NCU disseminated, through common advertising, untrue statements about NCU and its  doctoral programs as described within this Complaint. NCU knew or should have known that its  40  Violation of New Jersey’s Consumer Fraud Act 56:8 (Unconscionable   Commercial Practices)  (On Behalf of Alternative New Jersey Sub-Class)   278.  Plaintiffs repeat and allege each and every allegation set forth in paragraphs above and  incorporate said allegations as if fully set forth herein.   279.  Plaintiff brings this cause of action in the alternative on behalf of an New Jersey Sub- Class.   280.  New Jersey’s Consumer Fraud Act ("CFA"), N.J.S.A. 56:8-2 prohibits:   The act, use or employment by any person of any unconscionable commercial practice,  deception, fraud, false pretense, false promise, misrepresentation, or the knowing []  concealment, suppression, or omission of any material fact with intent that others rely upon  such concealment, suppression or omission, in connection with the sale or advertisement of any  merch subsequent performance of such person as aforesaid, whether or not any person has in  fact been misled, deceived or damaged thereby...  281.  The CFA defines "merchandise" as including "any objects, wares, goods, commodities,  services or anything offered, directly or indirectly to the public for sale." N.J.S.A. 56:8-1(c).   282.  As described in this Complaint, NCU has engaged in the advertisement and sale of  services within the meaning of N.J.S.A. 56:8-1(c), including through its website, recruiters, and other  materials.   283.  NCU has engaged in unconscionable commercial practices including, but not limited to,  misrepresenting the length of time and cost it would take to complete a doctoral degree.  48  Violation of NY CLS Gen Bus § 349 (New York Consumer Protection Act)   Against NCU   (On Behalf of Alternative New York Sub-Class)  339.  Plaintiff realleges and incorporates the preceding allegations by reference as if set forth  fully herein.  340.  Plaintiff brings this cause of action in the alternative on behalf of an New York Sub- Class. NCU has engaged in unfair, unlawful, and fraudulent business practices, as set forth above.  341.  NY CLS Gen Bus § 349 specifically prohibits the use of unfair or deceptive trade  practices in the conduct of any business, trade, or commerce or in the furnishing of any service in New  York.   56  Violations of California Business and Professions Code §17200 on behalf of California  Nationwide Class  (On Behalf of the California Nationwide Class)  207.  Plaintiff Torres brings this cause of action, on behalf of a Nationwide Class under  California Business & Professions Code §17200.   37  Violation of Arizona Consumer Fraud Act, A.R.S. § 44-1521 et seq.   Against NCU  (Arizona Nationwide Class)   153.  Plaintiff Torres realleges and incorporates the preceding allegations by reference as if set  forth fully herein.  29  Violations of the Consumer Legal Remedies Act, California Civil Code §1750 et seq.   (On behalf of California Nationwide Class)  38 