10.  Defendant is a manufacturer that is engaged in the manufacture,  marketing, supplying and distributing of printers advertised to have HP Smart  Install included with the printer but in fact do not.    11.  Consumers pay for the HP Smart Install feature as part of the  payment for the printers. When consumers purchase the printer they are  purchasing the printer for the features that are advertised to come with them.     12.  Defendant profits from both the sale of the printers and the HP  Smart Install feature. Without the HP Smart Install feature, many of the  consumers would not have purchased these printers because of the difficulty of  installing standard printers and the deterrence to the purchase of printers that the  difficulty in installation causes.    13.  In actual fact, the HP Smart Install feature is disabled and  unavailable for use on the printers that the Defendant advertises them to have.    31.  On or around April 25, 2015 Plaintiff went to a Staples store located  at 3370 Yucaipa Blvd, Yucaipa, California, 92399, and purchased a LaserJet Pro  P1102w printer (“the printer”).    32.  For the printer, Plaintiff paid more than valuable consideration.   33.  Including taxes and fees Plaintiff paid over $140.38. In addition,  Plaintiff purchased other items from Defendant as ancillary to the purchase of  the printer for more than valuable consideration. In total, including taxes and  fees the total price of the purchase came out to $194.25. A receipt of the  purchase is enclosed for the record (see “Exhibit B”).    34.  Defendant manufactured the printer with all relevant packaging and  materials.   35.  On the box of the printer Defendant advertised easy printer software  installation through the preinstalled HP Smart installed feature (see “Exhibit A”).  In relevant part, the box said:  “Start printing right away with effortless setup – no CD  installation required – using HP Smart Install.”   51.  Plaintiff brings this action, on behalf of herself and all others  similarly situated, and thus, seeks class certification under Federal Rule of Civil  Procedure 23.   67.  Plaintiff incorporates by reference each allegation set forth above.    68.  Pursuant to California Business and Professions Code section  17500, et seq., it is unlawful to engage in advertising “which is untrue or  misleading, and which is known, or which by the exercise of reasonable care  should be known, to be untrue or misleading...or...to so make or disseminate or  cause to be so made or disseminated any such statement as part of a plan or  scheme with the intent not to sell that personal property or those services,  professional or otherwise, so advertised at the price stated therein, or as so  advertised.”     69.  California Business and Professions Code section 17500, et seq.’s  prohibition against false advertising extends to the use of false or misleading  written statements.   7.  Consumers purchase printers advertised to have the HP Smart Install  feature included with the printers.    70.  Defendant misled consumers by making misrepresentations and  untrue statements about the Class Products, namely, Defendant sold the printers  advertised to have the HP Smart Install feature included fully knowing this  feature was disabled and non-functional, and made false representations to  Plaintiff and other putative class members in order to solicit these transactions.     79.  Plaintiff incorporates by reference each allegation set forth above.   8.  On the outside of the boxes of these printers, there is a statement  assuring customers that these printers will be easy to install because of the  inclusion of the HP Smart Install feature (See “Exhibit A”).    80.  Actions for relief under the unfair competition law may be based on  any business act or practice that is within the broad definition of the UCL.  Such  violations of the UCL occur as a result of unlawful, unfair or fraudulent business  acts and practices.  A plaintiff is required to provide evidence of a causal  connection between a defendant's business practices and the alleged harm--that  is, evidence that the defendant's conduct caused or was likely to cause substantial  injury. It is insufficient for a plaintiff to show merely that the defendant's  conduct created a risk of harm.  Furthermore, the "act or practice" aspect of the  statutory definition of unfair competition covers any single act of misconduct, as  well as ongoing misconduct.  9.  Consumers rely on the representations and advertisements of  retailers in order to know which printers to purchase. The difficulty of having to  install a printer can often times deter one from buying the printer.   Violation of the California False Advertising Act   (Cal. Bus. & Prof. Code §§ 17500 et seq.)   Violation of Unfair Business Practices Act   (Cal. Bus. & Prof. Code §§ 17200 et seq.)  