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> Whether DoorDash, in adopting, promoting, and/or charging its Delivery Fee, misrepresented material facts to consumers, like Plaintiffs, including the fact that:

> o Dashers did not receive the Delivery Fee for their deliveries and that DoorDash retained the Delivery Fee completely;

> o DoorDash knew or should have known that its advertising tactics regarding discounts on the Delivery Fee were misleading;

> o DoorDash knew or should have known the Delivery Fee had nothing to do with the delivery of orders for consumers, like Plaintiffs, but instead related to the alleged cost to operate DoorDash’s technology;

Personally, I'd be happy if labeling something with a common english meaning but the something doesn't reflect that common meaning counted as fraud when financial gain was involved.



If there's any guarantee (or reasonable reliance) on these facts I guess? But seems like this could be weaseled out of ...




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