                                           PAL’s Contract of Carriage   14.  PAL’s refusal to refund customers violates its Contract of Carriage (“COC”),  attached as Exhibit A.1  Specifically, this dispute is governed by Article 10 of PAL’s COC.   Article 10, Section 1 provides that the “[r]efund of a Ticket or any of its unused portion . . . shall be  subject to these Conditions of Carriage.”     Unjust Enrichment  112.  Plaintiff reincorporates and realleges each preceding paragraph herein.  This claim  is brought in the alternative to the contract-based cause of action.  113.  Plaintiff brings this claim on behalf of herself and members of the Class.  114.  Plaintiff and the Class conferred benefits on Defendants by purchasing airline  tickets with PAL.  115.  Defendants have been unjustly enriched in retaining the revenues derived from  Plaintiff and Class Members’ purchase of airline tickets, where it has subsequently canceled or  significantly changed the schedule for Class Members’ flights and have not issued a refund.   Retention of those moneys under these circumstances is unjust and inequitable because  Defendants’ failure to issue refunds is in violation of its Contract of Carriage, and is in violation of  California law.  These acts and omissions caused injuries to Plaintiff and the Class because they  would not have purchased their airline tickets at all, or on the same terms, if the true facts were  known.  116.  Because Defendants’ retention of the non-gratuitous benefits conferred on them by  Plaintiff and the Class is unjust and inequitable, Defendants must pay restitution to Plaintiff and the  Class for its unjust enrichment, as ordered by the Court. 