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I <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />SECOND CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />12. Plaintiff is inforined and believes and based on such information and belief alleges that <br />beginning at an exact date that is unknown to Plaintiff, but within four (4) years prior to the filing of <br />this Complaint (B&P §17208), Defendants have engaged in acts unlawful and/or unfair competition <br />prohibited by California Business and Professions Code, sections 17200 et seq. by virtue of the acts <br />described herein, each of which constitutes an unlawful and/or unfair business practice. The use of <br />such unlawful and or unfair business practices constitutes unfair competition within the meaning of <br />California Business and Professions Code, section 17200 et seq. The unlawful and/or unfair business <br />practices committed by the Defendants include, but are not limited to: <br />a. Violation of Health and Safety Code section 25100 et seq., as described in <br />paragraph 11 — 11 f above. <br />PRAYER <br />WHEREFORE, Plaintiff prays that: <br />1. Defendants be permanently restrained and enjoined from engaging in or performing, <br />directly or indirectly, any and all of the following acts: <br />a. Engaging in any acts in violation of Health and Safety Code section 25100 et seq., <br />including but not limited to: <br />1. Violation of Health and Safety Code section 25189(d); <br />2. Violation of California Code of Regulations, title 22 section 66265.16; <br />3. Violation of California Code of Regulations, title 22 section 66265.16(d) <br />4. Violation of California Code of Regulations, title 22 section 66265.31; <br />5. Violation of California Code of Regulations, title 22 section 66265.51; and <br />6. Violation of California Code of Regulations, title 22 section 66265.173(a). <br />b. Engaging in any of the unlawful acts of unfair competition set forth in the First <br />Cause of Action of this Complaint, as well as any other violations of the Business and Professions <br />Code, section 17200 et seq., including but not limited to: <br />1. Violation of Health and Safety Code section 25100 et seq., as described in <br />-4- <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />