35.   Plaintiff incorporates by reference each allegation set forth above.   36.    Actions for relief under the unfair competition law may be based on any  business act or practice that is within the broad definition of the UCL.  Such  violations of the UCL occur as a result of unlawful, unfair or fraudulent business  acts and practices.  A plaintiff is required to provide evidence of a causal  connection between a defendant's business practices and the alleged harm--that is,  evidence that the defendant's conduct caused or was likely to cause substantial  injury. It is insufficient for a plaintiff to show merely that the defendant's conduct  created a risk of harm.  Furthermore, the "act or practice" aspect of the statutory  definition of unfair competition covers any single act of misconduct, as well as  ongoing misconduct.  Violation of Unfair Business Practices Act  