14.  Robinhood has grown substantially since its start in 2013. The firm raised $323  million in funding in 2019 at a $7.6 billion valuation. With its marketing geared primarily  towards younger investors, Robinhood now claims over 10 million users of its trading app.    34.  Pursuant to Rule 23 of the Federal Rules of Civil Procedure, Plaintiff brings this  action on behalf of himself and the following proposed class, within which the term  “Outages” is defined to include Robinhood’s total outages on March 2, 2020, March 3, 2020,  and March 9, 2020:  All Robinhood customers within the United States who were not able to execute trades on  securities or change limit orders during the Outages and incurred financial losses.   35.  Excluded from the proposed class are Defendants; any affiliate, parent, or  subsidiary of Defendants; any entity in which any Defendant has a controlling interest; any  officer, director, or employee of Defendants; any successor or assign of any Defendant;  anyone employed by counsel in this action; any judge to whom this case is assigned and his or  her spouse; and members of the judge’s staff.     36.  Numerosity. Robinhood has millions of customers.  Although the precise  number of proposed class members is presently unknown to Plaintiff, there are likely  thousands of proposed class members based on publicly available news reports.  Proposed  class members are thus too numerous to practically join in a single action.  Class members  may be notified of the pendency of this action by reference to Robinhood’s records, or by  other alternative means.   42.  Plaintiff incorporates the above allegations by reference.   43.  As set forth above, Plaintiff and proposed class members entered into binding  and enforceable contracts with Robinhood.   48.  Plaintiff incorporates the above allegations by reference.   49.  As set forth above, Plaintiff and proposed class members entered into binding  and enforceable contracts with Robinhood.   54.  Plaintiff incorporates the above allegations by reference.   55.  As a licensed provider of financial services, Robinhood at all times relevant  herein was a fiduciary to Plaintiff and proposed class members and owed them the highest  good faith and integrity in performing its financial services on their behalf.    58.  Plaintiff incorporates the above allegations by reference.   59.  Robinhood owed Plaintiff and proposed class members a duty to exercise  reasonable care in executing trades and other requested customer actions in a full and prompt  manner.    63.  Plaintiff incorporates the above allegations by reference.   64.  Robinhood owed Plaintiff and proposed class members a duty to exercise  reasonable care in executing trades and other requested customer actions in a complete and  timely manner.    69.  Plaintiff incorporates the above allegations by reference.   70.  Robinhood is a “person” within the meaning of Civil Code §§ 1761 and 1770,  and it has provided “goods” or “services” within the meaning of Civil Code §§ 1761 and 1770.   71.  Plaintiff and members of the proposed class are “consumers” within the  meaning of Civil Code §§ 1761 and 1770, and have engaged in a “transaction” within the  meaning of Civil Code §§ 1761 and 1770.   85.  Plaintiff incorporates the above allegations by reference.   86.  Robinhood has obtained unjust benefits from Plaintiff and proposed class  members resulting in inequity.   Breach of Contract   Breach of Fiduciary Duty   Breach of the Implied Covenant of Good Faith and Fair Dealing   Gross Negligence   Negligence   Unjust Enrichment   Violation of California’s Consumers Legal Remedies Act,  Cal. Civ. Code §§ 1750, et seq.   Violation of California’s Unfair Competition Law,  Cal. Bus. & Prof. Code §§ 17200, et seq.  