Chong petitioned the university for a refund based on the pedagogical inferiority of online instruction, and when that was rejected, he and Gallo filed a class action on behalf of similarly situated students, saying that the university either breached its contract with them or engaged in unjust enrichment.

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Rising circulations were made possible by increased literacy and by technological advances in mechanical typesetting, in high-speed printing rotary press , in communications telegraph and telephone , and in transport railway.