their stockholders with treasure. . . and with "overhead that would shame an antebellumplantation." "Yelp's business model profits
the unpaid work ofreviewers".
Defendant's business model and slip-shod approach to its policies and practices havebecome suspect in both the public forum, as witnessed by the proliferation and popularity
and within the courtrooms. I9. The practice
classifying employees as "reviewers" or "Yelpers"
"Elites" or"independent contractors"
"volunteers" or "contributors" to avoid paying wagesis prohibited by federal law, which requires employers to pay all workers who provide materialbenefit to their employer,
least the minimum wage. Defendant, by virtue
its managementand control over the nature
wages and work
ts writers, is an "employer" under applicablelabor law.
Additionally, Defendant, has been, and continues to be, unjustly enriched by the unpaidcontributions provided by these plaintiffs and all those similarly situated.Unjust enrichment
based upon society's interest in preventing the injustice
a person's retaining a benefit for whichno payment has been made to the provider.
The named plaintiffs, and persons similarly situated, are persons who each worked asubstantial number
hours for Defendant over a number
years, and were not paid a single cent20 for their work. The
they perfonned --writing, researching, editing, lodging reviews,
and generally promoting the site
central to Defendant's business22 model as a publisher.23
On infonnation and belief, Defendant employs
thousands other "reviewers" in
IOregon Superior Court Judge Henry Kantor stated that Yelp's business model
"offensive" and "highly problematic." California Superior Court Judge Peter Doft, characterizedYelp's actions as
modem day version
the Mafia going to stores and saying
ou wannanot be bothered
you wanna not have incidents
your store? Pay