225. Defendants and the other known and unknown defendants used and/or profited from slave labor and have retained the benefits and use of those profits and products derived from that slave labor. Defendants knew that the plaintiff class was subject to physical and mental abuse and inhuman treatment at the time they earned those profits and since.

226. Defendants conspired with each other with intentions to violate plaintiffs' ancestors' basic human rights and by so doing, to profit from these violations.