SUPERIOR COURT OF THE STATE OF WASHINGTON

FOR THE COUNTY OF [COUNTY]

[PLAINTIFF NAME], an individual residing in the State of Washington,
Plaintiff,

v.

[DEFENDANT NAME], a [STATE] [TYPE OF ENTITY (Corporation/LLC/etc.)] doing business in Washington,
Defendant.

Case No. ____

COMPLAINT FOR:
1. VIOLATION OF THE WASHINGTON CONSUMER PROTECTION ACT, RCW 19.86 et seq.
2. FRAUDULENT MISREPRESENTATION (Alternative / Supplemental)
3. UNJUST ENRICHMENT / RESTITUTION (Alternative / Supplemental)

DEMAND FOR JURY TRIAL

TABLE OF CONTENTS

1. Introduction & Preliminary Statement..................................................... ¶ 1–4
2. Parties.................................................................................... ¶ 5–8
3. Jurisdiction & Venue........................................................................ ¶ 9–12
4. Definitions................................................................................ ¶ 13
5. Factual Allegations........................................................................ ¶ 14–33
6. Count I – Violation of Washington Consumer Protection Act................................... ¶ 34–43
7. Count II – Fraudulent Misrepresentation (Optional)......................................... ¶ 44–50
8. Count III – Unjust Enrichment / Restitution (Optional)..................................... ¶ 51–54
9. Prayer for Relief.......................................................................... ¶ 55–61
10. Demand for Jury Trial..................................................................... ¶ 62
11. Reservation of Rights..................................................................... ¶ 63
12. Certification & Verification.............................................................. ¶ 64–66

[// GUIDANCE: Update page numbers after final formatting.]

INTRODUCTION & PRELIMINARY STATEMENT

1. Plaintiff brings this action to redress Defendant’s unfair, deceptive, and fraudulent business practices in violation of the Washington Consumer Protection Act (“CPA”), RCW 19.86 et seq.
2. Defendant’s misconduct caused Plaintiff and the Washington public to suffer ascertainable monetary losses and non-economic injuries.
3. Pursuant to RCW 19.86.090, Plaintiff seeks:
   a. Actual damages in an amount to be proven at trial;
   b. Treble damages (up to $25,000 per violation) as authorized by statute;
   c. Costs of suit and reasonable attorneys’ fees; and
   d. Preliminary and permanent injunctive relief to prevent further violations.
4. Plaintiff also seeks such other and further relief—including restitution, disgorgement, and/or equitable indemnification of consumer losses—as the Court deems just and proper.

PARTIES

5. Plaintiff [PLAINTIFF NAME] is a natural person residing in [CITY], Washington.
6. Defendant [DEFENDANT NAME] is a [CORPORATION/LLC/etc.] organized under the laws of [STATE] with its principal place of business at [ADDRESS], and at all relevant times conducted substantial business within Washington.
7. Upon information and belief, Defendant derives more than five percent (5%) of its gross revenue from sales and/or services rendered in Washington.
8. Plaintiff reserves the right to amend this Complaint to add additional parties whose identities become known through discovery.

JURISDICTION & VENUE

9. This Court has subject-matter jurisdiction under Wash. Const. art. IV § 6 and RCW 2.08.010.
10. Personal jurisdiction is proper because Defendant purposefully availed itself of the privilege of conducting business in Washington and committed tortious acts within this State.
11. Venue lies in [COUNTY] under RCW 4.12.025(1) because Defendant transacts business and the causes of action arose in this county.
12. Any arbitration clause purporting to govern disputes arising from the transactions at issue is unenforceable or, alternatively, expressly waived by Defendant’s litigation conduct.
    [// GUIDANCE: Delete ¶ 12 if no arbitration clause exists.]

DEFINITIONS

13. The following terms shall have the meanings set forth below:
    a. “CPA” means the Washington Consumer Protection Act, RCW 19.86 et seq.
    b. “Products/Services” means the [DESCRIPTION OF GOODS OR SERVICES] marketed and sold by Defendant to Plaintiff.
    c. “Unfair or Deceptive Act” means any practice declared unlawful by RCW 19.86.020.

FACTUAL ALLEGATIONS

14. From approximately [DATE RANGE], Defendant marketed the Products/Services to Washington consumers, including Plaintiff.
15. Defendant represented, both expressly and by implication, that the Products/Services would [STATE REPRESENTATIONS].
16. In reality, the Products/Services [DESCRIBE DEFECT OR MISCONDUCT], rendering Defendant’s representations false and/or misleading.
17. Defendant knew or should have known that its representations were false at the time they were made.
18. Plaintiff relied on Defendant’s representations when deciding to purchase the Products/Services.
19. As a direct and proximate result, Plaintiff suffered ascertainable losses including, without limitation, the purchase price of $[AMOUNT], out-of-pocket consequential damages, and non-economic harm.
    20-33. [ADD ADDITIONAL FACTS, TIMELINE, COMMUNICATIONS, ADVERTISEMENTS, AND REGULATORY FINDINGS AS APPLICABLE.]

COUNT I – VIOLATION OF THE WASHINGTON CONSUMER PROTECTION ACT

(Against All Defendants)
34. Plaintiff realleges ¶¶ 1–33 as if fully set forth herein.
35. RCW 19.86.020 declares unlawful any unfair or deceptive act or practice in trade or commerce.
36. Defendant’s conduct constitutes an unfair and deceptive act in trade or commerce.
37. Defendant’s acts affect the public interest because [PUBLIC-INTEREST FACTORS—e.g., potential to injure other consumers, repeat conduct, prior complaints].
38. Plaintiff suffered injury in his/her business or property as required by RCW 19.86.090.
39. Pursuant to RCW 19.86.090, Plaintiff is entitled to recover actual damages, treble damages (up to the statutory cap), and attorney fees and costs.
40-43. [OPTIONAL: Plead additional statutory violations—e.g., RCW 19.86.030 (unlawful restraints of trade) if applicable.]

COUNT II – FRAUDULENT MISREPRESENTATION

(Optional Alternative Cause of Action)
44. Plaintiff realleges ¶¶ 1–43.
45. Defendant made material representations of fact to Plaintiff.
46. Such representations were false when made.
47. Defendant knew of the falsity or acted with reckless disregard.
48. Plaintiff justifiably relied on the representations.
49. Plaintiff sustained damages as a proximate result.
50. Plaintiff is therefore entitled to compensatory and punitive damages as allowed by law.

COUNT III – UNJUST ENRICHMENT / RESTITUTION

51. Plaintiff realleges ¶¶ 1–50.
52. Defendant was unjustly enriched through the retention of monies paid by Plaintiff.
53. Equity and good conscience require restitution or disgorgement to Plaintiff.
54. Plaintiff seeks restitution of all monies wrongfully retained by Defendant.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in favor of Plaintiff and against Defendant as follows:
55. Actual damages in an amount to be determined at trial;
56. Treble damages pursuant to RCW 19.86.090;
57. Restitution, disgorgement, and/or equitable indemnification of consumer losses;
58. Preliminary and permanent injunctive relief enjoining Defendant from continuing the unlawful conduct alleged herein;
59. Pre- and post-judgment interest as permitted by law;
60. Reasonable attorney fees and costs of suit pursuant to RCW 19.86.090 and CR 54(d);
61. Such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

62. Pursuant to Wash. Const. art. I § 21 and CR 38, Plaintiff demands a trial by jury on all triable issues.

RESERVATION OF RIGHTS

63. Plaintiff reserves the right to amend this Complaint to assert additional claims or parties as discovery progresses.

CERTIFICATION & VERIFICATION

64. Pursuant to CR 11, the undersigned counsel certifies that he/she has read the foregoing Complaint, that to the best of his/her knowledge, information, and belief formed after reasonable inquiry it is well-grounded in fact and warranted by existing law, and that it is not interposed for any improper purpose.
65. [OPTIONAL IF VERIFIED COMPLAINT] I, [PLAINTIFF NAME], verify under penalty of perjury under the laws of the State of Washington that the foregoing is true and correct.
66. Executed at [City], Washington, on [DATE].

EXECUTION BLOCK

Dated: [DATE]

Respectfully submitted,

[ATTORNEY NAME], WSBA No. [#####]
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Attorney for Plaintiff [PLAINTIFF NAME]

[// GUIDANCE: Add co-counsel signature lines or pro hac vice information if needed.]

OPTIONAL ATTACHMENTS

• Exhibit A – Copies of advertisements / representations
• Exhibit B – Transaction receipts / invoices
• Exhibit C – Consumer declarations or complaints

[// GUIDANCE: Label each exhibit sequentially and reference in the body (e.g., “See Ex. A”).]

NOTES & PRACTICE POINTERS

[// GUIDANCE:
1. Treble damages under RCW 19.86.090 are discretionary; bolster the request with facts showing willful or flagrant misconduct.
2. If seeking class certification, file a separate motion under CR 23 and amend this template accordingly.
3. Verify the complaint if relying on administrative shortcut procedures or to forestall a CR 12(b)(6) motion based on conclusory allegations.
4. Consider including a CR 56(f) affidavit timeline for anticipated discovery hurdles.
5. Ensure service of process complies with CR 4 and any corporate registered-agent requirements.]