155. ALTMANN incorporates here by reference paragraphs 1 through 97.

156. The AUSTRIAN GALLERY has engaged in unlawful and unfair business practices by displaying the looted Klimt paintings in its museum.

157. For almost 60 years, the AUSTRIAN GALLERY has unjustly and unfairly profited from the display of the looted Klimt paintings by obtaining entrance fees and selling concessions and memorabilia to museum visitors, including ones form California, who would not have otherwise visited the museum or made such purchases were it not for the presence of the Klimt paintings in the museum.  One of the Klimt paintings, Adele I, appears on the cover of the AUSTRIAN GALLERY’s official guidebook to the museum. Thousands of visitors each year come to the museum for the sole reason of viewing the looted Klimt paintings that were taken from Ferdinand Bloch-Bauer and unlawfully and improperly detained from his heirs.

158. As a result, the Court should require an accounting of the ill-gotten gains of the AUSTRIAN GALLERY, and order that those illicit profits be disgorged and paid to ALTMANN, who could have earned those profits were it not for the unfair practices of the AUSTRIAN GALLERY.