(Unjust Enrichment)  (Violation of Massachnsetts Unfair Trade Practices Act, Mass. Gen. Laws ch. 93A)  18. Plaintiffrepeats and re-alleges the allegations contained in the paragraphs above as if fully set forth herein.  19. Mass. Gen. Laws Ch. 93 § 105(a) provides that: No person, firm, partnership, corporation or other business entity that accepts a credit card for a business transaction shall write, cause to be written or require that a credit card holder write personal identification information, not required by the credit card issuer, on the credit card transaction form. Personal identification information shall include, but shall not be limited to, a credit card holder's address or telephone number. The provisions of this section shall apply to all credit card transactions.  20. Williams-Sonoma is a corporation that accepts credit cards for retail transactions.  22. The ZIP code is part of a credit card holder's address, and is therefore personal identification information under Mass. Gen. Laws Ch. 93 § 105(a). Williams-Sonoma and other retailers are also able to use a customer's name and ZIP code to determine their address or telephone number using commercially available databases.  23. Mass. Gen. Laws ch. 93 § I05(c) provides that the collection ofpersonal identification information is a per se violation ofMass. Gen. Laws ch. 93A § 2: "Any violation ofthe provisions ofthis chapter shall be deemed to be an unfair and deceptive trade practice, as defined in section 2 of chapter 93A."  24. Mass. Gen. Laws ch. 93A § 9 provides that: Any person ... who has been injured by another person's use or employment of any method, act or practice declared to be unlawful by section two ... may bring an action in the superior court ... for damages and such equitable relief, including an injunction, as the court deems to be necessary and proper ... Any persons entitled to bring such action may, if the use or employment of the unfair or deceptive act or practice has caused similar injury to numerous other persons similarly situated and if the court finds in a preliminary hearing that he adequately and fairly represents such other persons, bring the action on behalf ofhimself and such other similarly injured and situated persons.  26. In compliance with Mass. Gen. Laws. Ch. 93A § 9(3), on March 14,2013, Plaintiffs counsel sent Defendant a written demand for relief by Federal Express, identifying Ms. Brenner as a claimant and reasonably describing the unfair or deceptive act alleged herein and the injury she and other Class members suffered. 27. Plaintiff repeats and re-alleges the allegations contained in the paragraphs above as iffully set forth herein.  28. Defendant knowingly and willingly accepted benefits from Plaintiffand the Class, to wit, their economically valuable personal identification information which Defendant used for its own profit, while providing Plaintiff and the Class nothing in return.  29. Under the circumstances described herein, it is inequitable for Defendant to retain the full monetary benefit ofthat information at the expense of Plaintiff and the Class. 