19. Acting in concert under color of state law — to-wit, the Ralph C. Dills Act, CAL. GOVT. CODE § 3512 et seq. — the State of California has recognized Local 1000 as the exclusive bargaining agent for the Plaintiffs and other State employees in bargaining units designated as Bargaining Units 1 (Professional, Administrative, Financial and Staff Services bargaining unit), 3 (Professional Educators and Library bargaining unit), 4 (Office and Allied Workers bargaining unit), 11 (Engineering and Scientific Technicians bargaining unit), 14 (Printing Trades bargaining unit), 15 (Allied Services Workers bargaining unit), 17 (Registered Nurses bargaining unit), 20 (Medical and Social Services Specialists bargaining unit), and 21 (Educational Consultants and Librarians bargaining unit).  Local 1000 and the State of California have entered into a series of Memoranda of Understanding (“MOUs”) controlling the terms and conditions of employment for Plaintiffs and the class and subclasses of State employees Plaintiffs seek to represent.  20. Pursuant to the Ralph C. Dills Act, CAL. GOVT. CODE § 3512, the State and Local 1000 have entered into MOUs governing these bargaining units, including a provision requiring that all State employees in Bargaining Units 1, 3, 4, 11, 14, 15, 17, 20, and 21 join Local 1000 as formal union members, or have deducted from their wages full union dues or agency fees, as a condition of continued public employment.  21. Sometime in June 2013, Defendant Local 1000 sent to each Plaintiff and class member a notice by regular, first-class mail, informing nonmember employees of their “right to object to the use of any portion of your fees for what you believe are activities not germane to the collective bargaining functions of SEIU Local 1000, i.e., partisan political or ideological causes only incidentally related to the terms and conditions of employment or the provision of benefits available only to members.”  A true and correct copy of the notice sent to each Plaintiff and class member is attached hereto and incorporated herein as Exhibit A.  22. Not all Plaintiffs and class members — such as Plaintiffs Dawn Ammons, Ryan Christensen, Kelli Giles, Madeline L. Lopez, Clint Miller, Virginia Ollis, and Antonia Toledo — actually received such notices. 