(Breach of Contractl 43- Plaintiff reoeats. reiterates and incoroorates the allegations contained in paragraphs numbered "1" through "42" herein with the same force and effect as if the same were set forth at lenqth herein.  (Violations of AIYS Gen. Bus, Law 5349, 53501  10. There are questions of law and fact which are common to the Class and which predominate over questions affecting any individual Class member. These common questions of law and fact include, without limitation: (i) Whether Defendant violated various provisions of the NYS GBL SS 349 and 350; (ii) Whether Plaintiff and the Class have been injured by Defendant's conduct; (c) Whether Plaintiff and the Class have sustained damages and are entitled to restitution as a result of Defendant's wrongdoing and, if so, what is the proper measure and appropriate statutory formula to be applied in determining such damages and restitution; and, (iv) Whether Plaintiff and the Class are entitled to declaratory and/or injunctive relief.  11. Plaintiff's claims are typical of the claims of the Class, and Plaintiff has no interests adverse or antagonistic to the interests of other members of the Class.  12. A class action is superior to other methods for the fair and efficient adjudication of the claims herein asserted,  13. The members of the Class are generally unsophisticated individuals, whose rights will not be vindicated in the absence of a class action.  15. A class action will permit a large number of similarly situated persons to prosecute their common claims in a single forum simultaneously, efficiently, and without the duplication of effort and expense that numerous individual actions would engender. Class treatment also will permit the adjudication of relatively small claims by many Class members who could not othenruise afford to seek legal redress for the wrongs complained of herein.  16. Plaintiff will fairly and adequately represent the Class members' interests, in that the Plaintiff's counsel is experienced and, further, anticipates no impediments in the pursuit and maintenance of the class action as sought herein.  17. Absent a class action, the Class members will continue to suffer losses borne from Defendant's breaches of their statutorily protected rights as well as monetary damages, thus allowing and enabling: (a) Defendant's conduct to proceed and; (b) Defendant to further enjoy the benefit of its ill-gotten gains.  18. Defendant has acted, and will act, on grounds generally applicable to the entire Class, thereby making appropriate a final injunctive relief or corresponding declaratory relief with respect to the Class as a whole. 19. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "1" through "18" herein with the same force and effect as if the same were set forth at length herein.  21. Said vehicle was a 2015 Chevrolet Tahoe (hereinafter referred to as "the Vehicle").  22. The Vehicle, and allvehicles manufactured by Defendant are equipped with an OnStar@ navigation system.  23. According to Plaintiff's lease agreement, Plaintiff and, upon information and belief, all consumers who lease Defendant's vehicles, are supplied with OnStal@ navigation system at no cost for a period of six (6) months.  24. Accordingly, Plaintiff's six-month free OnStar@ service would end on Aprrl2T , 2015.  25. In or about March, 2015, Plaintiff received a letter purporting to be from OnStarwhich letter informed Plaintiff that OnStar@ had reason to believe that The Vehicle had been sold or traded and therefore the OnStar@ services would be discorttinued within a very short period of time unless Plaintiff contacted Onstar.  26. ln or about March 2015, Plaintiff placed a telephone call to Defendant and was connected to a female employee who identified herself as a representative of OnStar@. Plaintiff referenced the letter and informed Defendant's representative that this information was incorrect and that The Vehicle, had only recently been leased on October 28,2014 and had been neither sold nor traded. Defendant's representative then stated that she would correct her records accordingly and the call concluded.  27. On April 10, 2015, Plaintiff received an electronic communication from Defendant, a copy of which is attached hereto as Exhibit "A."  28. Defendant's e-mailfeatured extremely large letters stating: "CANCELLATION 36. Plaintiff repeats, reiterates and incorporates the allegations contained in paragraphs numbered "1" through "35" herein with the same force and effect as if the same were set forth at length herein.  39. Defendant violated (9) b of N.Y. GBS.LAW $349:NY Code-Section 349 by communicating to consumers using unfair and unconscionable threatening language and warnings. On April 10,2015 prior to the end of the six-month period, which ended on April 27,2015, Defendant communicated to Plaintiff by e-mail purportedly signed by "Terry M. lnch, OnStar, Chief Operating Officer," that Plaintiff's service was terminated, making a point to emphasize: "This means that, even in an emergency, you will no longer be able to count on OnStar to provide critical services, including: Automatic Crash Response; Live, 2417 OnSlar Advisor emergency assistance; Stolen Vehicle Assistance. We hope you keep us in mind as you move on to your next vehicle and allow us to continue to keep you and your loved ones safe and secure while on the road."  41. Defendant's communications imply that any consumer who declines to renew OnStar, prior to the actual expiration of the free six month Onstar trial period, will knowingly decline to "keep you and your loved ones safe and secure while on the road" and will agree that "... even in an emergency, OnStar will be unable to provide you with critical services." Consumers, like Plaintiff, an older adult with medical challenges, may well respond with the alarm Defendant unfairly intends to provoke with such threatening communications and actions such as prematurely terminated services. Defendant's deceptive sales practices are designed to intentionally cause plaintiff and other consumers fear and trepidation as a means to sell Onstar services. The use of sales tactics of this nature is reprehensible, causing Plaintiff and similarly situated consumers alarm, distress and emotional harm.  42. As a result of Defendant's above violations of the New York General Business Law. the Plaintiff has been damaged and is entitled to damages in accordance with the New York General Business Law. 45. The Vehicle, and all vehicles manufactured by Defendant are equipped with an OnStar navigation system.  46. According to the Plaintiff's lease agreement, Plaintiff and, upon information and belief, all consumers who lease Defendant's vehicles, are supplied with OnStar navigation system at no cost for a period of six (6) months, which free service period would end on Apri!27,2015. 4T . ln or about March 2015, Plaintiff received a letter from OnStar, stating that OnStar had reason to believe that the Vehicle had been sold or traded and therefore the OnStar services would be discontinued within a very short time unless Plaintiff contacted OnStar.  48. ln or about March 2015, Plaintiff contacted Defendant via telephone, and informed a representative for Defendant that this information was incorrect. and that the Vehicle had been neither sold nor traded. Defendant's reoresentative said she would correct her records accordingly.  50. On April 22,2015, Plaintiff received a second electronic communication from Defendant (Exhibit "B"). This communication threatened to discontinue Plaintiff's OnStar service unless he accepted the OnStar User Terms and Privacy Statement immediately. The notice went on to say "To avoid deactivation, please act immediately. Only then can you unsure that OnStar will be there for you 24 hours a day, 7 days a week."  51. These communications from Defendant to Plaintiff were in breach of the lease agreement, which provided that Plaintiff would receive free OnStar service through and until April2T , 2015.  6.  Plaintiff brings this action as a class action, pursuant to Federal Rules of Civil Procedure ("FRCP") Rule 23, on behalf of himself and all persons/consumers, along with their successors-in-interest, who have received similar letters/communications from Defendant which, as alleged herein, are in violation of the NYS GBL SS 349 and 350 as of the date of Plaintiffs Complaint (the "Class"). Excluded from the Class is Defendant herein, and any person, firm, trust, corporation, or other entity related to or affiliated with the Defendant, including, without limitation, persons who are officers, directors, employees, associates or partners of Defendant. Upon information and belief, hundreds of persons have received debt collection notices and/or letters/communications from Defendant, which violate various provisions of the NYS GBL SS 349 and 350.  7.  This Class satisfies all the requirements of FRCP Rule 23 for maintaining a class action,  9.  The letters/communications from Defendant, received bythe Class, are to be evaluated by the objective standard of the hypothetical "least sophisticated consumer". 