17.45(3), as it is a corporation, and business entity and/or association.     29.   Plaintiff brings this action on behalf of herself and all others similarly  situated, as a member of the proposed class (the “Class”), defined as follows:   All persons within the United States who purchased the  Products within four years prior to the filing of this  complaint through to the date of class certification.    30.  Plaintiff also brings this action on behalf of herself and all others  similarly situated, as a member of the proposed sub-class (the “Sub-Class”), defined  as follows:  All persons within Texas who purchased the Products  within four years prior to the filing of this complaint  through to the date of class certification.   31.  Defendants, their employees and agents are excluded from the Class  and Sub-Class. Plaintiff does not know the number of members in the Class and Sub- Class, but believes the members number in the thousands, if not more. Thus, this  matter should be certified as a Class Action to assist in the expeditious litigation of  the matter.   43.  Plaintiff incorporates all of the allegations and statements made in  paragraphs 1 through 42 above as if fully reiterated herein.   44.  Plaintiff is a “person” as defined in Tex. Bus. & Com. Code § 17.45(3),  as she is a natural person.   45.  Defendant is a “person” as defined in Tex. Bus. & Com. Code §   46.  Tex. Bus. & Com. Code § 17.46(a) states:  False, misleading, or deceptive acts or practices in the  conduct of any trade or commerce are hereby declared  unlawful and are subject to action by the consumer  protection division under Sections 17.47, 17.58, 17.60,  and 17.61 of this code.   53.  Plaintiff incorporates all of the allegations and statements made in  paragraphs 1 through 52 above as if fully reiterated herein.   54.  Through its false advertisements that the Products can be colored and  bleached, Defendant made false statements of material fact.    55.  At the time Defendant made its statements that the Products can be  colored and bleached to Plaintiff, it knew, or reasonably should have known, that  the statements described above were false.   56.  At the time Defendant made the statements to Plaintiff, it intended to  induce Plaintiff to purchase the Products.   57.  Plaintiff relied upon the truth of the statements described above and  purchased the Products, only to find that the Products are damaged and unusable  when colored or bleached.   58.  As a result of their reasonable reliance upon Defendant’s false  statements of material fact as set forth above, Plaintiff and other members of the  Class and Sub-Class have suffered concrete and particularized injuries, harm and  damages which include, but are not limited to, the loss of money spent on products  they did not want to buy, and stress, aggravation, frustration, inconvenience,  emotional distress, mental anguish, and similar categories of damages.  59.   Plaintiff incorporates all of the allegations and statements made in  paragraphs 1 through 58 above as if fully reiterated herein.   7.  Defendant manufactures, advertises, markets, sells, and distributes hair  extension and wig products throughout California and the United States under brand  name “Mayvenn Hair.”    COMMON LAW FRAUD   UNJUST ENRICHMENT   Violations of the Texas Deceptive Trade Practices Act  Tex. Bus. & Com. Code § 17.46, et seq.  