16.  RTS is the owner of numerous patents and patent applications (the  “Patents”) around the world.  The Patents must be periodically renewed in each  country in order to maintain and protect RTS’s intellectual property rights.     17.  Such renewals require the payment of certain fees to, and may require  the filing of documents with, patent offices in each country in which Plaintiff has  registered Patents.  Timely renewal of patents in each country is vital because patents  are lost or abandoned if not properly renewed.   18.  CPA is in the business of managing foreign registration payments for  U.S. patents. In order to manage its payments, RTS entered into the Renewal Service  Agreement (“Agreement”) with CPA on March 18, 2016.  The Agreement set forth  the terms on which CPA would renew RTS’s patents.  Section 5.1 of the Agreement  states that:  Our basic fees in relation to Services that comprise the  provision of renewal of intellectual property rights  registrations are set out in Clause 4 of the Operating  Procedures.   40.  RTS brings this action as a class action pursuant to the Federal Rules  of Civil Procedure 23(a) and 23(b) on behalf of a class (the “Class”) defined as:  All  persons or entities who entered into a Renewal Service Agreement using  Defendants’ standard agreements.  RTS also seeks to represent a subclass of all Class  members who reside in California (the California Subclass”).    41.  Excluded from the Class are: (i) Defendants and its employees,  principals, affiliated entities, legal representatives, successors, and assigns; (ii) any  entity in which Defendant has a controlling interest, and Defendants’ legal  representatives; (iii) the judges to whom this action is assigned and any members of  their immediate families; and (iv) any member of the Class who timely elects  exclusion.     42.  RTS reserves the right to amend or modify the definition of the Class  or Subclass with greater specificity or further division into subclasses as discovery  and the orders of this Court warrant.   53.  Plaintiff re-alleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   54.  Defendants entered into written contracts with Plaintiff and the Class  for renewal of patents.  The contracts included that Defendants would charge  “Official Fee(s)” and “Country Charge(s)” to Plaintiff and the Class.   59.  Plaintiff re-alleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   60.  Defendants have received a benefit, the retention of which would  unjustly enrich Defendants, by its conduct in overcharging Plaintiff and the Class.   61.  Defendants should be required to return that benefit, disgorge their  unlawful gains and provide restitution to Plaintiffs and the Class.   62.  Plaintiff re-alleges and incorporates by reference each preceding  paragraph as though set forth at length herein.   Breach of Contract  (Brought on behalf of the Class)   Unjust Enrichment – Restitution  (Brought on behalf of the Class)   Violation of Cal. Bus. & Prof. Code § 17200, et seq.  (Brought on behalf of the California Subclass)  