22.  This action is brought against Apple on behalf of Plaintiff and all current and  former owners of the Watches.   23.  Apple designed, manufactured, distributed, marketed, warranted, and sold the  Watches. Upon information and belief, Apple has sold—directly or indirectly through authorized  stores and other retail outlets—millions of Watches in California and nationwide.  Watches Manufactured, Advertised, and Sold by Apple   24.  Apple began selling its Watches in April 2015, when it introduced the Series 0  Watch. Apple exclusively manufactured and sold Series 0 Watches from April 2015 until  September 2016, when Apple discontinued their manufacture. Upon information and belief,  consumers of the Series 0 Watch could choose between a number of models varying in price when  purchasing their Watch: The Watch, Sport, Edition, or Hermès. Depending on the model, Series  0 Watches had steel, aluminum, or gold cases, and “Ion-X glass” or “Sapphire crystal” screens.  Consumers could further select between a smaller, 38mm case, or a larger 42mm case. Prices for  Series 0 Watches ranged from $349 to $1,099, depending on the model and other above-described  features.   25.  Starting in September 2016, Apple discontinued the manufacture of its Series 0  Watches and began to produce and sell both the Series 1 and Series 2 Watches. Apple still sells  the Series 1 Watch, but discontinued manufacture of the Series 2 Watch in September 2017.    26.  The Series 1 Watches only use aluminum cases with “Ion-X glass” screens, but  consumers can choose a 38mm case or a 42mm case. Initially, prices for Series 1 watches varied  between $269 and $299—depending on the size chosen—but have since dropped to $249 and  $279.   58.  Plaintiff requests this Court certify the following Class under Rule 23 of the  Federal Rules of Civil Procedure:  All current and former consumer owners of all models and sizes of First  Generation, Series 1, Series 2, and Series 3 Apple Watches purchased in the  United States.   59.  Alternatively, Plaintiff requests this Court certify the following Class under Rule  23 of the Federal Rules of Civil Procedure:  All residents of Colorado who are current and former consumer owners of  all models and sizes of First Generation, Series 1, Series 2, and Series 3  Apple Watches purchased in the United States.   60.  Plaintiff reserves the right to amend these Class definitions and, if deemed  appropriate, to divide the class into additional subclasses.   64.  Plaintiff incorporates by reference all paragraphs of the Complaint as if fully set  forth herein.   65.  Apple’s business practices, as alleged above, constitute unlawful, unfair, and  fraudulent business practices in violation of California Business & Professions Code §§ 17200,  et seq.   66.  Plaintiff and the Class reasonably expected that their Watches would not be  defective such that the screens would detach, crack, or shatter unexpectedly during normal use.   75.  Plaintiff incorporates by reference all paragraphs of the Complaint as if fully set  forth herein.   76.  This claim arises under the CLRA.   93.  Plaintiff incorporates by reference all paragraphs of the Complaint as if fully set  forth herein.   94.  Apple provided a one-year written Limited Warranty to consumers in connection  with every sale of an Apple Watch (this warranty period is two years for Hermès and Edition  models). Under the terms of the Limited Warranty, Apple warranted “against defects in materials  and workmanship” in the Apple Watch “when used normally in accordance with Apple’s  published guidelines for a period of ONE (1) YEAR from the date of original retail purchase by  the end-user purchaser. . . .”   95.  Apple’s Limited Warranty provides that if the warranty is triggered during the  warranty period, Apple will either: “(i) repair the Apple Product using new or previously used  parts that are equivalent to new in performance and reliability, (ii) replace the Apple Product with  the same model (or with your consent a product that has similar functionality) formed from new  and/or previously used parts that are equivalent to new in performance and reliability, or (iii)  exchange the Apple Product for a refund of your purchase price.”14   CAL. CIV. CODE §§ 1750, ET SEQ.  On Behalf of the Nationwide Class   IN VIOLATION OF CAL. BUS. & PROF. CODE §§ 17200, ET SEQ. (UCL)  On Behalf of the Nationwide Class   On Behalf of the Nationwide Class and Colorado Subclass  