In an opinion ordered published on Monday, the Court of Appeal rejected a UCL "unlawful" prong claim, holding that the plaintiff had not alleged any violation of the underlying, "borrowed" statute. Violante v. Communities Southwest Devel. & Constr. Co., ___ Cal.App.4th ___ (Mar. 16, 2006) (slip op. at 6-10). The opinion does not address the UCL's "unfair" prong, suggesting that the plaintiff made no attempt to plead an "unfair" prong claim separate and apart from the "unlawful" prong claim. I always like to reiterate how important it is to plead each of the three prongs—"unlawful," "unfair," and "fraudulent"—separately.