(BREACH OF CONTRACT)   17.  In 2007, then President of the Republic of France, Nicolas Sarkozy,  implemented the PEC program, which provided a non-income-based tuition subsidy to  expatriate high school students enrolled in French government-approved French high  schools outside of France.  The PEC tuition grants were designed to promote the French  educational system abroad and to encourage French expatriate students to attend French  government-approved high schools when they resided outside of France.  The PEC program  fulfilled President Sarkozy’s campaign pledges to foster “free” French education for French  citizens abroad, though eventually, in December 2009, tuition payments were capped at  2007/2008 levels.   18.  The PEC program provided PEC tuition grants for approximately 8,000  French high school students each year, including Plaintiff’s daughter, Belle.  Belle was a  student at the French-American School of New York.     19.  Plaintiff applied for a PEC tuition grant to pay for her daughter Belle’s  tuition at the French-American School of New York for the academic year 2012/2013.  On  or about April 20, 2012, the French Consul General, Phillipe Lalliot, sent Plaintiff Martine  Violet a letter advising her that her daughter Belle had been approved by the Local  Commission for Financial Aid for a PEC award for the 2012/2013 academic year in the  amount of $25,820.    20.  The letter, written in French, states the following:  28.   Plaintiff seeks to be appointed as the class representative of a Class composed  of and defined as follows:  All persons who, on or about April 20, 2012, were notified that they had been  awarded PEC tuition grants by the French government for the 2012/2013  academic year to pay for tuition of their children at French government- approved French-American high schools in the United States and subsequently  had those PEC tuition grants cancelled prior to the 2012/2013 academic year.  Excluded from the Class are Defendants and any Judge presiding over this  matter and the members of his or her immediate family. Also excluded from this  Class are the legal representatives, heirs, successors, and attorneys of any  excluded person or entity, and any person acting on behalf of any excluded  person or entity.   29.  As to the above Class, this action is appropriately suited for class action  treatment. Plaintiff is informed, believes, and thereon alleges, that the Class is sufficiently  numerous – consisting of several thousand individuals -- such that a class action is superior  to other available methods for the fair and efficient adjudication of this controversy because  joinder of all Class members is impractical.   31.  The questions of law and fact common to the Class members predominate over  any questions affecting only individual members, including legal and factual issues relating to  liability and available remedies.   32.  Plaintiff’s claims are typical of the claims of Class members, and Plaintiff will  fairly and adequately protect the interests of the Class. Plaintiff was awarded a PEC tuition  grant to pay for her daughter’s high school tuition by Defendants on or about April 20,  2012, and that grant was unilaterally cancelled by Defendants on or about July 5, 2012.   Plaintiff suffered an injury-in-fact as a result of Defendants’ conduct, as did all Class  members who were similarly awarded PEC tuition grants by Defendants on or about April 20,  2012 and had those grants unilaterally cancelled by Defendants on or about July 5, 2012.   33.  Plaintiff’s interests are coincident with and not antagonistic to those of the  other Class members. Plaintiff is represented by counsel who is competent and experienced  in the prosecution of class action litigation.     35.   On behalf of herself and the Class members, as defined in Paragraph 28  above, Plaintiff hereby realleges, and incorporates by reference as though set forth fully  herein, the allegations contained in paragraphs 1 through 34 above.   37.  Defendants’ actions described herein constitute breaches of their  contracts between Defendants and Plaintiff and the other Class members.   38.  Defendants’ breaches of contract, as set forth above, have caused Plaintiff  and the other Class members to incur substantial monetary damages for which they seek  recovery herein. 