27.  The named Plaintiff in this action is representative of a much larger class of  persons who were insured by the Farmer’s Insurance Group, who had claims for PIP and/or  Med-Pay benefits through the Farmer’s Insurance Group, and were paid the lesser of paid  medical vs. the contractually agreed upon incurred medical.    28.  Plaintiffs bring this action pursuant to Rule 23 of the Federal Rules of Civil  Procedure, as individuals and on behalf of all members of the following class:  All persons located in the State of Texas who were policyholders of automobile insurance  through any of the named Defendants, and any related entities, who carried Personal Injury  Protection (PIP) benefits and / or Medical Payment (Med-Pay) benefits, and who presented  claims for benefits pursuant to the policy, and who were paid less than the incurred medical  expenses as prescribed in the policy (the "Class").   29.  The Class is so numerous that joinder of all members is impracticable.   Ultimately, the precise number of Class members must be the subject of discovery, but Plaintiffs  allege that the numbers for the Class are at least in the thousands.   31.  Plaintiffs' claims are typical of the claims of all Class members in that they all  maintained policies of auto insurance with the Farmer’s Insurance Group, and presented claims  for benefits.     32.  Plaintiffs will fairly and adequately protect the interests of the Class and are not in  conflict with the interests of Class members.  Further, Plaintiffs have retained competent counsel  and counsel will fairly and adequately protect and represent the interests of the Class.   33.  Plaintiffs assert that, pursuant to Fed. R. Civ. P. 23(b)(2), the Farmer’s Insurance  Group actions apply generally to the Class and that, if necessary, final injunctive or declaratory  relief is appropriate for the Class as a whole.   34.  Plaintiffs assert that, pursuant to Fed. R. Civ. P. 23(b)(3), the questions of law  and/or fact common to the Class members predominate over the question of individual members,  and that this class action is a superior method for the fair and efficient adjudication of these  claims, as individual class members may not decide to individually prosecute their claims with  the Farmer’s Insurance Group given the length of time and expenses associated with such  lengthy litigation.  INSURANCE COMPANY; TRUCK  INSURANCE EXCHANGE; MID- CENTURY INSURANCE COMPANY; 