11.  Every human hair contains three distinct parts: the shaft, root, and follicle. The hair  shaft is the strand of hair that is visible above the skin. The hair root is the section of the hair that  lies beneath the skin. The hair follicle is the skin that holds the hair root.1   42.  Plaintiff brings this action on her own behalf and on behalf of all other persons  similarly situated. The Class which Plaintiff seeks to represent comprises:    56.  Plaintiff repeats and re-alleges the allegations set forth in the preceding paragraphs  and incorporates the same as if set forth herein at length.   57.  This cause of action is brought pursuant to Business and Professions Code Section  17200, et seq., on behalf of Plaintiff and a Class consisting of all persons residing in the United  States and/or State of California who purchased the Products for personal use and not for resale  during the time period of four years prior to the filing of the complaint through the present.   A.  “Unfair” Prong   58.  Under California’s Unfair Competition Law, Cal. Bus. & Prof. Code Section 17200,  et seq., a challenged activity is “unfair” when any injury it causes outweighs any benefits provided  to consumers and the injury is one that the consumers themselves could not reasonably avoid.  Camacho v. Auto Club of Southern California, 142 Cal. App. 4th 1394, 1403 (2006).   59.  Defendant’s false and deceptive advertising as alleged herein does not confer any  benefit to consumers.   60.  Defendant’s false and deceptive advertising as alleged herein causes injuries to  consumers, who do not receive a product consistent with their reasonable expectations.   61.  Defendant’s false and deceptive advertising as alleged herein causes injuries to  consumers, who end up overpaying for the Products that are not as advertised.   62.  Consumers cannot avoid any of the injuries caused by Defendant’s false and  deceptive advertising.   63.  The injuries cause by Defendant’s false and deceptive advertising outweighs any  benefits.   86.  Plaintiff repeats and re-alleges the allegations set forth in the preceding paragraphs  and incorporates the same as if set forth herein at length.   87.  This cause of action is brought pursuant to Business and Professions Code Section  17500, et seq., on behalf of Plaintiff and the Class consisting of all persons residing in the United  States and/or State of California who purchased the Products for personal consumption and not for  resale during the time period of four years prior to the filing of the complaint through the present.   96.  Plaintiff repeats and re-alleges the allegations set forth in the preceding paragraphs  and incorporates the same as if set forth herein at length.   97.  This cause of action is brought pursuant to Civil Code Section 1750, et seq., the  Consumers Legal Remedies Act (“CLRA”), on behalf of Plaintiff and a Class consisting of all  persons residing in the United States and/or State of California who purchased the Products for  personal consumption and not for resale during the time period of four years prior to the filing of  the complaint through the present.   98.  The Class consists of thousands of persons, the joinder of whom is impracticable.   FALSE AND MISLEADING ADVERTISING IN VIOLATION OF BUSINESS &  PROFESSIONS CODE § 17500, et seq.  (On Behalf of the Class)   Hair Loss   VIOLATION OF CALIFORNIA CONSUMERS LEGAL REMEDIES ACT,  CALIFORNIA CIVIL CODE § 1750, et seq.  (On Behalf of the Class)   VIOLATION OF CALIFORNIA UNFAIR COMPETITION LAW  BUSINESS & PROFESSIONS CODE § 17200, et seq.  (On Behalf of the Class)  