40.  Plaintiff brings this suit as a class action on behalf of himself and all other similarly  situated Cree customers (the “Class”) pursuant to Fed.R.Civ.P.23.  Plaintiff seeks to represent the  following Class:  All persons in Oregon who purchased the LED Lightbulbs during  the applicable limitations period.  Excluded from the Class are (a)  any Judge or Magistrate presiding over this action and members of  their families; (b) the Defendant and its subsidiaries and affiliates;  and (c) all persons who properly execute and file a timely request  for exclusion from the Class (the “Class”).    41.  Plaintiff reserves the right to re-define the Class (hereinafter referred to as the  “Class,” unless otherwise specified) prior to moving for class certification.   51.  Plaintiff re-alleges and incorporates by reference the allegations contained in all  preceding paragraphs of this Complaint as though set forth fully herein.   68.  Plaintiff re-alleges and incorporates by reference the allegations contained in all  preceding paragraphs of this Complaint as though set forth fully herein.    69.  Defendant, either directly and/or through agents, made material misrepresentations  and concealed material information concerning the qualities, characteristics, reliability, durability,  longevity, benefits and lifespan of the LED Lightbulbs from its customers as set forth above.   70.  At the times Defendant misrepresented and concealed these material facts, Plaintiff  and the members of the Class had no knowledge of the material facts that Defendant  misrepresented and failed to disclose.   71.  At all times relevant, Defendant had superior knowledge regarding the qualities,  characteristics, reliability, durability, longevity, benefits and lifespan of the LED Lightbulbs than  did Plaintiff and Class members.   77.  Plaintiff re-alleges and incorporates by reference the allegations contained in all  preceding paragraphs of this Complaint as though set forth fully herein.    FRAUDULENT MISREPRESENTATION AND CONCEALMENT   STOLL STOLL BERNE LOKTING & SHLACHTER P.C.  209 S.W. OAK STREET, SUITE 500  PORTLAND, OREGON 97204  UNJUST ENRICHMENT   VIOLATION OF THE OREGON UNLAWFUL TRADE PRACTICES  LAW,   ORS 646.605, et seq.  