In Jenkins v. JPMorgan Chase Bank, N.A. (2013) 216 Cal.App.4th 497, the plaintiff alleged that the defendants violated section 17200 by recording fraudulent documents in violation of Penal Code section 115.5 and the nonjudicial foreclosure statutes (Civ. Code, 2924 et seq.). As a result of these unlawful, unfair, and fraudulent business practices, the plaintiff alleged that her home was subject to foreclosure and that she had suffered monetary damages. The Court of Appeal concluded that the plaintiff could not satisfy the causation element which required her to plead a causal link between her economic injury (the impending nonjudicial foreclosure) and the allegedly unfair or unlawful acts. The plaintiff admitted that she had defaulted on her loan and that this default triggered the lawful enforcement of the power of sale clause in the deed of trust, which subjected the house to nonjudicial foreclosure. (Jenkins, supra, at p. 522--523.) The court reasoned that the plaintiff could not assert that the impending foreclosure was caused by the defendants' wrongful actions, and therefore a demurrer to the cause of action was proper. (Id. at p. 523.) The Jenkins court concluded that amendment could not cure the causation defect because the purported wrongdoing by the defendants occurred after the plaintiff defaulted on her loan. (Id. at pp. 523--524.)