McLychok

I. BACKGROUND

24 On October 14, 2020, Plaintiff Marilyn McLychok filed a Complaint in the Superior 25 Court for the State of California, County of San Diego, against Defendants Diamond 26 Resorts U.S. Collection Development, LLC (“Diamond Resorts”) and Does 1 through 10. 27 (Ex. A to Notice of Removal, ECF No. 1-3). In the Complaint, McLychok alleges that 28 Diamond Resorts is an international timeshare company headquartered in Las Vegas, Nevada. McLychok alleges that Diamond Resorts sells “membership points” to consumers, which can be redeemed for vacation stays. McLychok alleges that she is a 76-year old widow who needs assistance to walk and “suffers from cognitive decline, particularly as it relates to finances.” (Id. ¶ 11). McLychok alleges that Diamond Resorts has been selling membership points to her since 2014. McLychok alleges that her purchases of membership points were “historically modest in size and generally only occurred on an annual basis.” (Id. ¶ 8). McLychok alleges that beginning in November 2018, “Diamond Resorts ramped up its efforts to target Ms. McLychok and get her to purchase additional points.” (Id. ¶ 11). McLychok…