Read the following excerpt from a US court opinion:
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class, so it appears that they seek to include all fifty states. (See Compl. at ¶¶ 94-97.) Again, like the consumer protection issue, courts faced with the question of whether variations in the state law of unjust enrichment bar class certification have reached different outcomes. Compare, e.g., Overka v. Am. Airlines, Inc., 265 F.R.D, 14, 19-21 (D. Mass. 2010) (stating that “unjust enrichment claims in different states are substantially similar” and certifying a 34-state class) and In re Terazosin Hydrochloride Antitrust Litig., 220 F.R.D. 672, 697 n.40 (S.D, Fla. 2004) (stating that the “standards for evaluating various states classes’ unjust enrichment claims are virtually identical”) with Casa Orlando Apartments, Ltd. v. Fed. Nat’l Mortg. Ass’n, 624 F.3d 185, 195 (5th Cir. 2010) ; Rapp v. Green Tree Servicing, LLC, 302 F.R.D.
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What is the most suitable continuation to the opinion? Your options are:
A. holding that erisa does not permit a plaintiff to assert an independent federal common law cause of action such as unjust enrichment to enforce the terms of an erisa plan thus to the extent plaintiffs third cause of action for unjust enrichment is brought pursuant to a federal common law right it must be dismissed
B. holding that there is no cause of action in california for unjust enrichment
C. holding that unjust enrichment is brought about by unlawful or improper conduct as defined by law
D. holding that plaintiffs survey here fails to show that burden of proof standards do not vary or that differences in state unjust enrichment laws are insignificant
E. holding that walsh does not support plaintiffs assertion that they need not allege any actual injury to bring an unjust enrichment claim
Reply with [A, B, C, D, E] only.