19.  Plaintiffs bring this action on their own behalf and on behalf of the following  Classes: (1) an “iOS 9 Purchaser Class” consisting of all persons or entities in the United States  who purchased an iPhone or iPad with a cellular data plan with iOS 9 pre-installed for purposes  other than resale or distribution, and (2) an “iOS 9 Upgrade Class” consisting of all persons or  entities in the United States who upgraded an iPhone or iPad with a cellular data plan to iOS 9.    20.  Plaintiffs also bring this action on their own behalf and on behalf of the  following California Business and Professions Code Subclasses: (1) an “iOS 9 California  Claims Purchaser Class” consisting of all persons or entities who purchased an iPhone or iPad  with a cellular data plan with iOS 9 pre-installed for purposes other than resale or distribution  with respect to California Business & Professions Code 17200 claims, and (2) an “iOS 9  California Claims Upgrade  Class” consisting of all persons or entities in the United States who  upgraded an iPhone or iPad with a cellular data plan to iOS 9 with respect to California  Business & Professions Code 17200 claims.    29.  Plaintiffs reallege the foregoing paragraphs as if fully set forth herein.   30.  Plaintiffs bring this claim on behalf of themselves and the proposed Class.   31.  The UCL prohibits acts of unfair competition, including any “unlawful, unfair or  fraudulent business act or practice.”   32.  The UCL imposes strict liability. Plaintiffs do not have to prove Defendant  intentionally or negligently engaged in unlawful, unfair or fraudulent business acts or practices.  Instead, Plaintiffs only have to prove such acts or practices occurred.   46.  Plaintiffs reallege the foregoing paragraphs as if fully set forth herein.   47.  Plaintiffs bring this claim on behalf of themselves and the proposed Class.   48.  Defendant Apple Inc. is a California company disseminating advertising from its  California headquarters throughout the United States.   49.  The FAL provides that “[i]t is unlawful for any . . . corporation . . . with intent . .  . to dispose of . . . personal property . . . to induce the public to enter into any obligation relating  thereto, to make or disseminate or cause to be made or disseminated . . . from this state before  the public in any state, in any newspaper or other publication, or any advertising device, or by  public outcry or proclamation, or in any other manner or means whatever, including over the  Internet, any statement . . . which is untrue or misleading, and which is known, or which by the  exercise of reasonable care should be known, to be untrue or misleading . . . .”   57.  Plaintiffs reallege the foregoing paragraphs as if fully set forth herein.   58.  Plaintiffs bring this claim on behalf of themselves and the proposed Class.   NEGLIGENT MISREPRESENTATION   VIOLATION OF CALIFORNIA’S UNFAIR COMPETITION LAW (“UCL”)  (Cal. Bus. & Prof. Code §§ 17200, et seq.)   VIOLATION OF CALIFORNIA’S FALSE ADVERTISING LAW (“FAL”)   (Cal. Bus. & Prof. Code §§ 17500, et seq.)  