13.  At all times material hereto, Defendants were each agents, servants, employees and/or  representatives of each other and acted within the course and scope of their employment and/or  agency and/or acted for a common purpose or as part of a joint venture.   14.  This Class Action lawsuit deals with all current and former guests at all Sandals’ resorts,  including but not limited to:   Turks and Caicos Islands, St. Lucia, Antigua, and Barbuda who  were charged a local government tax and/or deceived into paying such tax that in whole or in  part was secretly retained by Sandals for their own use and benefit.  This fraudulent deceptive  practice has been ongoing for decades.    25.  At all times material hereto, the Class Representative and Class Members were paying  guests at Sandals’ resorts.    26.  This action is brought by Plaintiff on his own behalf, and on behalf of all others similarly  situated, under the provisions of Rule 23(a) and 23(b)(3) of the Federal Rules of Civil Procedure.   27.  Plaintiff brings this action as a class action and proposes the following two classes, as  defined below:   41.  This Count is brought pursuant to the Florida Deceptive and Unfair Trade Practices Act  52.  Sandals received certain monies from Plaintiff and others similarly situated as a result of  its uniform charging of a local government tax that was surreptitiously retained in whole or in  part by Sandals.   53.  The benefits conferred on Sandals by Plaintiff and others similarly situated was non- gratuitous, and Sandals had knowledge of these benefits and voluntarily retained these benefits.   A. Class Definitions   UNJUST ENRICHMENT  Plaintiff re-alleges, adopts, and incorporates by reference the allegations in paragraphs 1  through forty (40) as though alleged originally herein and further alleges:   VIOLATION OF FLORIDA’S DECEPTIVE AND UNFAIR TRADE PRACTICES ACT  Plaintiff re-alleges, adopts, and incorporates by reference the allegations in paragraphs 1  through forty (40) as though alleged originally herein and further alleges:  