Salenga

This is an appeal from an order dismissing a first amended cross-complaint, in which defendant, cross-complainant and appellant Suezane Salenga (Appellant) sought to plead a class cause of action under the unfair competition law (UCL; Bus. & Prof. Code, § 17200 et seq.). Appellant sought to restrict the business practice in which creditors obtain deficiency judgments against vehicle buyers who have defaulted on their auto loans, under certain circumstances, pursuant to the body of law known as the Rees-Levering Motor Vehicle Sales and Finance Act (the Act; Civ. Code, § 2981 et seq.; all statutory references are to the Civil Code unless otherwise indicated).

The trial court sustained, without leave to amend, demurrers brought by cross-defendants Mitsubishi Motors Credit of America, Inc. (MMCA), and Cavalry Portfolio Services, LLC (Cavalry) (sometimes together cross-defendants). The demurrers were based on the four-year limitations period of the UCL. (Bus. & Prof. Code, § 17208; Cortez v. Purolator Air Filtration Products Co. (2000) 23 Cal.4th 163, 178-179 [ 96 Cal.Rptr.2d 518 , 999 P.2d 706 ].)

In the underlying complaint, Cavalry (as an assignee of MMCA) sued Appellant,…