What is the test for "unfairness" and "substantially injurious" debt collection?

With respect to the unfairness prong, "where a claim for an unfair act or practice is predicated on public policy,...[that] public policy must be 'tethered' to specific constitutional, statutory, or regulatory provisions." Scripps Clinic v. Superior Court, 108 Cal. App. 4th 917, 940 (2003). By merely stating that "it is against public policy and substantially injurious to engage in unfair debt collection practices," Plaintiffs' have not adequately 'tethered' their allegation to any particular provision or policy. (Pl.'s Opp'n 15:24-25.) Moreover, Plaintiffs'

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