20.  Plaintiff brings this action pursuant to Federal Rule of Civil Procedure 23, on  behalf of the following “Class”:  All persons in the United States who purchased tickets for travel on a Swoop flight  scheduled to operate to, from, or within the United States whose flights were  cancelled or were subject to a significant schedule change and not refunded.   21.  Subject to additional information obtained through further investigation and  discovery, the foregoing definition of the Class may be expanded or narrowed by amendment to  the complaint or narrowed at class certification.   22.  Specifically excluded from the Class are Defendant, Defendant’s officers,  directors, agents, trustees, parents, children, corporations, trusts, representatives, employees,  principals, servants, partners, joint ventures, or entities controlled by Defendant, and their heirs,  successors, assigns, or other persons or entities related to or affiliated with Defendant and/or  Defendant’s officers and/or directors, the judge assigned to this action, and any member of the  judge’s immediate family.   24.  Typicality.  The claims of the representative Plaintiff are typical of the claims of  the Class in that the representative Plaintiff, like all members of the Class, paid for a Swoop  flight that was cancelled, and did not receive a refund for the cancelled flight or for any  consequential damages and cancelations caused by the original cancelled flight.  The  representative Plaintiff, like all members of the Class, has been damaged by Defendant’s  misconduct in the very same way as the members of the Class.  Further, the factual bases of  Defendant’s misconduct are common to all members of the Class and represent a common thread  of misconduct resulting in injury to all members of the Class.    26.  Adequacy of Representation.  Plaintiff will fairly and adequately protect the  interests of the Class.  Plaintiff has retained counsel who are highly experienced in complex  consumer class action litigation, and Plaintiff intends to vigorously prosecute this action on  behalf of the Class.  Plaintiff has no interests that are antagonistic to those of the Class.   27.  Superiority.  A class action is superior to all other available means for the fair  and efficient adjudication of this controversy.  The damages or other financial detriment suffered  by members of the Class is relatively small compared to the burden and expense of individual  litigation of their claims against Defendant.  It would, thus, be virtually impossible for members  of the Class, on an individual basis, to obtain effective redress for the wrongs committed against  them.  Furthermore, even if members of the Class could afford such individualized litigation, the  court system could not.  Individualized litigation would create the danger of inconsistent or  contradictory judgments arising from the same set of facts. Individualized litigation would also  increase the delay and expense to all parties and the court system from the issues raised by this  action.  By contrast, the class action device provides the benefits of adjudication of these issues  in a single proceeding, economies of scale, and comprehensive supervision by a single court, and  presents no unusual management difficulties under the circumstances.   29.  Plaintiff incorporates and realleges each preceding paragraph as though fully set  forth herein.   30.  Plaintiff brings this claim on behalf of herself and members of the Class against  Defendant.     31.  Plaintiff and the Class conferred a benefit on Defendant in the form of monies  paid to purchase airline tickets for flights that were later cancelled or subject to a significant  schedule change by Swoop.     32.  Defendant has knowledge of these benefits.   33.  Defendant voluntarily accepted and retained these benefits.  Defendant voluntarily  retained the benefit of the purchase price of the tickets in addition to consequential damages  resulting from the cancelation (such as associated fees).   34.  Because this benefit was obtained unlawfully, namely by selling airline tickets for  flights that were later cancelled by Swoop, it would be unjust and inequitable for the Defendant  to retain it without paying the value thereof.  35.  Plaintiff incorporates and realleges each preceding paragraph as though fully set  forth herein.   37.  Plaintiff and members of the Class have an ownership right to the monies paid for  the tickets for cancelled flights sold by Defendant, as well as for the consequential damages  resulting therefrom.   38.  Defendant has wrongly asserted dominion over the payments illegally diverted to  them for the cancelled flights, and consequential damages resulting therefrom.  Defendant has  done so every time that Plaintiff and members of the Class paid to purchase a ticket for a flight  that was later cancelled or subject to a significant schedule change by Emirates Airlines.   39.  As a direct and proximate cause of Defendant’s conversion, Plaintiff and  members of the Class suffered damages in the amount of the payments made for each time they  purchased a ticket for a flight that was cancelled or subject to a significant schedule change by  Emirates Airlines, and in the amount of consequential damages resulting therefrom.  40.  Plaintiff incorporates and realleges each preceding paragraph as though fully set  forth herein.   41.  Plaintiff brings this claim on behalf of herself and members of the Class.   42.  Defendant entered into contracts with Plaintiff and members of the Class to  provide services in the form of flights in exchange for a set amount of money.   43.  Defendant has breached these contracts by retaining Plaintiff and members of the  Class’ ticket prices while not providing flight services.   45.  Plaintiff hereby incorporates by reference the allegations contained in all  preceding paragraphs of this complaint.   46.  Plaintiff brings this claim individually and on behalf of the members of the  proposed Class against Defendant.   47.  Defendant received money in the form of airline ticket fees that was intended to  be used for the benefit of Plaintiff and the Class.   48.  Those airline ticket fees were not used for the benefit of Plaintiff and the Class,  and Defendant has not given back or refunded the wrongfully obtained money and airline ticket  fees to Plaintiff and the Class.   49.  Defendant obtained roughly money in the form of airline ticket fees that was  intended to be used to provide flights for Plaintiff and the Class.  However, Defendant has  retained all of the airline ticket fees while cancelling its flights that Plaintiff and members of the  Class were supposed to be passengers on.   50.  Plaintiffs incorporate by reference the allegations in the preceding paragraphs as  if fully set forth herein.  Breach of Contract   Conversion   Money Had And Received   Unjust Enrichment  