(Declaratory Judgment)  (On Behalf of Plaintiffs and the Class)  Plaintiff re-alleges and incorporates by reference herein all of the allegations  contained in paragraphs 1 through 55.    (Negligence)  (On Behalf of Plaintiff and the Class)  Plaintiff re-alleges and incorporates by reference herein all of the allegations  contained in paragraphs 1 through 43.   13.  The SFERS is the city workers pension fund, which includes over 74,000  members.  The SFERS uses a vendor, 10up Inc. to manage and maintain member  23. Plaintiff brings this nationwide class action pursuant to Rule 23(b)(2),  23(b)(3), and 23(c)(4) of the Federal Rules of Civil Procedure, individually and  on behalf of all members of the following class: All individuals whose PII  was compromised in the data breach announced by the SFERS in or about  February to June 2020 (the “SFERS Class”).    44.  Defendants owed a duty to Plaintiff and Class members to exercise  reasonable care in obtaining, using, and protecting their PII from unauthorized  third parties.   45.  The legal duties owed by Defendants to Plaintiff and Class members include,  but are not limited to the following:  i. To exercise reasonable care in obtaining, retaining, securing,  safeguarding, deleting, and protecting the PII of Plaintiff and Class  members in its possession;  ii. To protect PII of Plaintiff and Class members in its possession using  reasonable and adequate security procedures that are compliant with  industry-standard practices; and  iii. To implement processes to quickly detect a data breach and to timely  act on warnings about data breaches, including promptly notifying  Plaintiff and Class members of the data breach.   57.  Plaintiff re-alleges and incorporates by reference herein all of the allegations  contained in paragraphs 1 through 56.   64.  Plaintiff re-alleges and incorporates by reference herein all of the allegations  contained in paragraphs 1 through 63.   Plaintiff re-alleges and incorporates by reference herein all of the allegations  contained in paragraphs 1 through 22.   Violation of California’s Unfair Competition Law Cal. Bus. & Prof. Code  §17200 – Unfair Business Practices  (On Behalf of Plaintiff and   the California Class)   Violation of California’s Unfair Competition Law  Cal. Bus. & Prof. Code §17200 – Unlawful Business Practices  (On Behalf of Plaintiff and the Class)  