A negative credit rating is not an identifiable sum of money." Smith v. Nat'l City Mortg., No. 2:10-CV-00359 JAM, 2010 WL 5477688, at *7 (E.D. Cal. Dec. 30, 2010). The Court finds Plaintiffs have failed to sufficiently allege their economic injury to satisfy the second element of a UCL claim.

Courts have also rejected the argument that the entity that initiates the foreclosure process must produce the note before undertaking foreclosure, observing that California's comprehensive provisions for non-judicial foreclosure contain no such requirement. Garfinkle v. Superior Court, 21 Cal.3d 268, 274 (1978) (non-judicial forfeiture provisions contained in Cal. Civ. Code §§ 2924 through 2924i); Phillips v. MERS, 2009 WL 3233865, at *9 (E.D. Cal. Oct. 2, 2009) (provisions cover all aspects of foreclosure process); Smith v. National City Mortgage, 2010 WL 5477688, at *5 (E.D. Cal. Dec. 30, 2010) (nonjudicial foreclosure provisions do not require possession of the promissory note to initiate foreclosure).

Courts have also rejected the argument that the entity that initiates the foreclosure process must produce the note before undertaking foreclosure, observing that California's comprehensive provisions for non-judicial foreclosure contain no such requirement. Garfinkle v. Superior Court, 21 Cal.3d 268, 274 (1978) (non-judicial forfeiture provisions contained in Cal. Civ. Code §§ 2924 through 2924i); Phillips v. MERS, 2009 WL 3233865, at *9 (E.D. Cal. Oct. 2, 2009) (provisions cover all aspects of foreclosure process); Smith v. National City Mortgage, 2010 WL 5477688, at *5 (E.D. Cal. Dec. 30, 2010) (nonjudicial foreclosure provisions do not require possession of the promissory note to initiate foreclosure).