This brief addresses the law of unjust enrichment and its relationship to restitution has failed to state a valid cause of action for restitution relief. Defendant incorrectly insists that plaintiff must plead a tort to seek restitution remedies as well as Both arguments belie the basic tenets of unjust enrichment law. Simply, plaintiff may seek restitution remedies based either a separate tort nor an allegation of the lack of bona fide purchaser status is required to survive these challenges.