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1 SECOND CAUSE OF ACTION <br /> 2 VIOLATION OF BUSINESS AND PROFESSIONS CODE §17200 ET SEQ. <br /> (UNFAIR COMPETITION) <br /> 3 <br /> 4 14. Plaintiff realleges Paragraphs 1 through 13, inclusive. <br /> 5 15. By the acts described herein, GMRI engaged in daily acts of unlawful and/or unfair <br /> 6 competition prohibited by California Business and Professions Code sections 17200 -17208. <br /> 7 Each act constitutes an unlawful and/or unfair business practice. <br /> 8 16. Pursuant to California Business and Professions Code section 17206, GMRI is liable <br /> 9 for civil penalties for each violation. <br /> 10 17. GMRI must immediately and permanently be enjoined from engaging in activities <br /> 11 that violate Chapter 6.95 of Division 20 of the California Health and Safety Code, and which <br /> 12 thereby constitutes unfair competition within the meaning of California Business and <br /> 13 Professions Code section 17200. <br /> 14 PRAYER <br /> 15 WHEREFORE, PLAINTIFF PRAYS FOR THE FOLLOWING RELIEF: <br /> 16 1. A permanent injunction requiring GMRI to comply with those provisions of <br /> 17 California Health and Safety Code, Division 20, Chapter 6.95, which GMRI is alleged to have <br /> 18 violated. <br /> 19 2. A permanent injunction prohibiting GMRI from engaging in activities that violates <br /> 20 the provisions of Chapter 6.95 of Division 20 of the California Health and Safety Code as <br /> 21 alleged in this complaint, which thereby constitutes unfair competition within the meaning of <br /> 22 California Business and Professions Code section 17200; <br /> 23 3. Civil penalties according to proof against GMRI pursuant to California Health and <br /> 24 Safety Code section 25514; <br /> 25 4. Civil penalties according to proof against GMRI pursuant to California Business and <br /> 26 Professions Code section 17206 for each act of unfair competition engaged in by GMRI; <br /> 27 5. Grant the Plaintiff its costs of inspection, investigation, attorneys fees, enforcement, <br /> 28 prosecution, and suit herein; and, <br /> s <br />