 Ms. Haynes-Glenn also seeks to represent a subclass defined as all Class members  who reside in New York who possess Laundry Cards that are maintained by Defendant (the  “New York Subclass”).    Members of the Class and New York Subclass are so numerous that their  individual joinder herein is impracticable.  On information and belief, members of the Class and  New York Subclass number in the millions.  The precise number of Class members and their  identities are unknown to Plaintiff at this time but may be determined through discovery.  Class  members may be notified of the pendency of this action by mail and/or publication through the  distribution records of Defendant and third-party retailers and vendors.    Common questions of law and fact exist as to all Class members and predominate  over questions affecting only individual Class members.  Common legal and factual questions  include, but are not limited to whether Defendant’s Laundry Card refund policy is false and  misleading.     The claims of the named Plaintiff are typical of the claims of the Class in that the  named Plaintiff was exposed to Defendant’s false and misleading marketing and promotional  materials and representations, possess Laundry Cards, and suffered a loss as a result of  Defendant’s possible prepayment amount and refund policies.    Plaintiff is an adequate representative of the Class and Subclass because her  interests do not conflict with the interests of the Class members she seeks to represent, she has  retained competent counsel experienced in prosecuting class actions, and she intends to  prosecute this action vigorously.  The interests of Class members will be fairly and adequately  protected by Plaintiff and her counsel.    Plaintiff incorporates by reference and re-alleges each and every allegation set  forth above as though fully set forth herein.    Plaintiff brings this claim individually and on behalf of members of the New York  Subclass against Defendant.      By the acts and conduct alleged herein, Defendant committed unfair or deceptive  acts and practices by making false representations in the marketing of Defendant’s Laundry  Card.       The foregoing deceptive acts and practices were directed at consumers.    Plaintiff and members of the New York Subclass were injured as a result because  (a) spent money to fill up their Laundry Card, and (b) were charged a hidden fee in the form of a  balance that was economically impractical to access.    On behalf of herself and other members of the New York Subclass, Plaintiff seeks  to enjoin the unlawful acts and practices described herein, to recover their actual damages or fifty  dollars, whichever is greater, three times actual damages, and reasonable attorneys’ fees.   Plaintiff incorporates by reference and re-alleges each and every allegation set  forth above as though fully set forth herein.    Plaintiff brings this claim individually and on behalf of members of the Class and  New York Subclass against Defendant.    Plaintiff and Class members conferred benefits on Defendant by paying money to  Defendant in the form of adding prepayments to their Laundry Cards.    Defendant has knowledge of such benefits.     Defendant has been unjustly enriched in retaining the revenues derived from  Plaintiff’s and Class members’ Laundry Card balance remainders.  Retention of those moneys  under these circumstances is unjust and inequitable because Defendant did not disclose that their  prepayment, refund policies, and Laundry Card reader replacements were structured in way that  maximized the balance remainders and then made these balances economically unfeasible to  access by requiring a processing and handling fee.    Plaintiff incorporates by reference and re-allege each and every allegation set  forth above as though fully set forth herein.    Plaintiff brings this claim individually and on behalf of members of the Class and  New York Subclass against Defendant.     As discussed above, Defendant misrepresented that its prepayment, refund  policies, and Laundry Card reader replacements were for reasons other than a hidden policy to  generate profits at the expense of Plaintiff and members of the Class and New York Subclass.     The false and misleading representations and omissions were made with  knowledge of their falsehood.     The false and misleading representations and omissions were made by Defendant,  upon which Plaintiff and members of the Class and New York Subclass reasonably and  justifiably relied, and were intended to induce and actually induced Plaintiff and members of the  Class and New York Subclass to add money to their Laundry Cards.     The fraudulent actions of defendant caused damage to Plaintiff and members of  the Class and New York Subclass, who are entitled to damages and other legal and equitable  relief as a result.  Deceptive Acts Or Practices, New York Gen. Bus. Law § 349   Fraud   Unjust Enrichment  