10.  DoorDash has developed significant market power, particularly as a result of the  Covid-19 pandemic. With many restaurants unable or unwilling to offer dine-in services, many  consumers have turned to DoorDash to have restaurant food delivered in lieu of eating out.     11.  The market power is such that restaurants are put in a difficult situation: they can  become Partner Restaurants and pay exorbitant fees and commissions to Defendant, or they  decline to do so and risk losing out on sales.    40.  Plaintiff realleges and incorporates by reference all preceding allegations as though  fully set forth herein.   41.  Defendant’s conduct as set forth herein significantly impacts interstate commerce  and commerce within this district.   42.  As described more fully herein, Defendant has engaged in a course of conduct with  respect to the advertising of its services and the services of restaurants that contains false and/or  misleading statements of fact, or omissions of critical facts, including those of Plaintiff and  members of the Class.   43.  These false and/or misleading statements, or omissions of material facts, include  the following:  a.  Suggesting in its advertising that Defendant has a business relationship with  Plaintiff and members of the Class and that it is authorized to provide information regarding their  services when in fact no such authorization exists;  b.  Providing false and/or misleading information about the operating status of  restaurants, including whether it is open, whether food can be delivered from that restaurant, and  whether other services are available from those establishments.  c.  Failing to advise consumers that restaurants are in fact open and delivery  from restaurants may be available through other services or means.   52.  Plaintiff realleges and incorporates by reference all preceding allegations as though  fully set forth herein.   53.  Cal. Bus. & Prof. Code § 17500 provides:   It is unlawful for any . . . corporation . . . with intent directly or indirectly to dispose  of real or personal property or to perform services, professional or otherwise,. . .  to induce the public to enter into any obligation relating thereto, to make or  disseminate or cause to be made or disseminated … from this state before the  public in any state, in any newspaper or other publication, or any advertising  device, . . . or in any other manner or means whatever, including over the Internet,  any statement . . . . 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.   54.  Defendant caused to be made or disseminated throughout the United States, through  advertising, marketing and other publications, statements, including statements included in its  general advertising and on its website that falsified information about Plaintiff and the Class, and  omitted material information from consumers and members of the Class.    55.  Defendant knew or should have known through the exercise of reasonable care that  the omitted information was material to consumers.   56.  Defendant has violated Cal. Bus. & Prof. Code § 17500 because its omissions  regarding the operations of Plaintiff and members of the Class were material and likely to deceive  a reasonable consumer.   61.  Plaintiff realleges and incorporates by reference all preceding allegations as though  fully set forth herein.    62.  California’s Unfair Competition Law ("UCL"), Cal. Bus. & Prof. Code §§ 17200,  et seq., defines unfair business competition to include any “unfair,” “unlawful,” or “fraudulent”  business act or practice. The Act also provides for injunctive relief, restitution, and disgorgement  of profits for violations.    9.  DoorDash has relationships with certain restaurants around the country (“Partner  Restaurants”) where DoorDash will take online orders from consumers using DoorDash’s  websites and/or mobile apps which are then relayed on to the Partner Restaurants, and then  DoorDash’s drivers will pick up the orders and deliver them to the consumers.  Upon information  and belief, DoorDash collects payments for these orders, and then Partner Restaurants have  various commissions and related fees held back from funds collected from orders in payment to  DoorDash for the services that it provides.   FALSE ADVERTISING  (Lanham Act § 43(a) (15 U.S.C. § 1125(a)))   VIOLATION OF CALIFORNIA FALSE ADVERTISING LAW  (California Business & Professions Code §§ 17500, et seq.)   VIOLATION OF CALIFORNIA UNFAIR COMPETITION LAW  (California Business & Professions Code §§ 17200, et seq.)  