With no explanation, chose the best option from "A", "B", "C" or "D". particularity, Plaintiffs may include a claim for unjust enrichment under California law as well as the laws of the other states. In a recent decision, which the Court believes is worth quoting at length, the Northern District of California summarized the competing approaches to unjust enrichment and explained that the two approaches do not necessarily conflict: Decisions in both this federal district as well as in California state courts diverge on the proper way to conceptualize unjust enrichment. The differences center on the availability of the unjust enrichment theory as an independent claim for relief. Sometimes, courts read a plaintiffs claim for unjust enrichment as a cause of action. See, e.g., Ghirardo v. Antonioli, 14 Cal.4th 39, 50, 57 Cal.Rptr.2d 687, 924 P.2d 996 (1996) (<HOLDING>). As such, these courts focus on whether the

A: holding that a plaintiff could not proceed on her procedural due process claim brought under  1983 because she did not show that she had exhausted her state law remedies or alleged that those remedies were inadequate
B: holding that there is no cause of action in california for unjust enrichment
C: recognizing that a plaintiff may advance a standalone claim for unjust enrichment particularly where he or she seeks restitution and other remedies are inadequate
D: holding that cause of action for unjust enrichment accrues upon payment of sum giving rise to duty of restitution
C.