(Breach of Contract)   (Negligent Misrepresentation)   (Restitution/Unfair Business Practices, Violation of California Bus. & Prof. Code §17200)   (Rescission)   17.  During the Class Period, Defendants operated approximately 83 spring and/or  summer camps – approximately 71 in California, 11 in Illinois, and 1 in Colorado – with each  camp having multiple sessions over the course of the spring and/or summer.   18.  Defendants offered those camps to the public via their website, email marketing,  and otherwise.  Pursuant to the terms of the agreement, anyone who purchased a camp session  could cancel for a refund.  The exact terms appear to be inconsistent, with some materials stating  that reservations could be canceled at will, while other materials referred to a nominal cancellation  fee.   24.  Named Plaintiff brings this action on behalf of herself and as a class action  pursuant to Federal Rule of Civil Procedure 23.   25.  The class that Named Plaintiff seeks to represent is defined as follows: All  individuals who paid Defendants for spring and/or summer camps that were canceled by  Defendants without refund during the Class Period.   34.  Plaintiffs incorporate the allegations above as though they were fully set forth  herein.     35.  In the time period from 2019 through the present, Plaintiffs entered various  agreements with Defendants pursuant to which Plaintiffs paid consideration to Defendants in  exchange for Defendants providing summer camp sessions to Plaintiffs (or, primarily, their  children) in the spring and summer of 2020.  The agreements contained a material term that the  agreements could be canceled for a refund, either at will or subject only to a nominal cancelation  fee.      36.  In or around April 2020, Defendants breached those agreements by canceling the  camps due to the COVID-19 pandemic, but refusing to give any refunds to Plaintiffs.     37.  Plaintiffs performed all required of them under the agreements, save such  performance as has been waived or excused by Defendants’ own conduct.   38.  As a result of Defendants’ breach, Plaintiffs have been damaged in an amount to be  proved at trial.   39.  Plaintiffs incorporate the allegations above as though they were fully set forth  herein.     43.  Plaintiff incorporates the allegations above as though they were fully set forth  herein.     44.  Defendants’ conduct, as set forth above, violates the California Unfair Competition  Law, Bus. & Prof. Code §17200, et seq. (“UCL”).  Defendants’ conduct constitutes unlawful,  unfair, or fraudulent business acts or practices in that they promoted their camps, accepted  payment for those camps in advance, continued to reassure Plaintiffs and the general public that  those camps would operate, then abruptly canceled those camps and refused to provide refunds.     45.  As a result of Defendants’ unlawful, unfair, and fraudulent conduct, Plaintiffs have  suffered injury in fact and have lost money, while Defendants have been enriched by the retention  of those funds that are the property of Plaintiffs.   49.  Plaintiff incorporates the allegations above as though they were fully set forth  herein.     50.  As set forth above, in the time period from 2019 through the present, Plaintiffs  entered various agreements with Defendants pursuant to which Plaintiffs paid consideration to  Defendants in exchange for Defendants providing summer camp sessions to Plaintiffs (or,  primarily, their children) in the spring and summer of 2020.  The agreements contained a material  term that the agreements could be canceled for a refund, either at will or subject only to a nominal  cancelation fee.      51.  In or around April 2020, Defendants breached those agreements by canceling the  camps, but refusing to give any refunds to Plaintiffs.     52.  Plaintiffs sought to rescind the agreements and recover their payments to  Defendants, but Defendants have refused to either perform or to refund any consideration.  