What are the non-desny causes of action for breach of the implied covenant of good faith and fair dealing?

Rosen's non-Desny causes of action fall with the Desny cause of action. His second cause of action, for breach of the implied covenant of good faith and fair dealing, assumes the implied-in-fact Desny contract. His third cause of action, for unjust enrichment, does not necessarily require a contractual basis. However, where the claimed enrichment arises out of a conversion of an idea, there is no independent cause of action for unjust enrichment. (Melchior v. New Line Productions, Inc. (2003) 106 Cal.App.4th 779, 793.)

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