12.  Plaintiff incorporates by reference Paragraphs 1-11 as though fully set forth herein.   13.  Plaintiff sustained injuries when she was rear-ended by another car while driving  in Key West in May of 2015.   14.  She subsequently received treatment for her injuries at the Hospital and incurred  30.  Plaintiff incorporates by reference Paragraphs 1-11, 16, and 17 as though fully set  forth herein.   31.  Each Class member is a PIP insured who was treated at the Hospital in question for  injuries as a result of a motor vehicle accident.   32.  Each Class member’s PIP insurer reimbursed the Hospital for some, but not all, of  the statutorily allowed amount for medical services administered to the Class member.   33.  After each Class member’s PIP insurer paid a portion of the statutorily allowed  amount, instead of billing the Class member for the remaining percentage of the statutorily allowed  amount, Defendant billed the Class member for that percentage of the entire gross medical bill.   34.  Defendant knew it could legally bill and attempt to collect from each Class member  only the percentage of the statutorily allowed amount that the PIP insurer did not pay.   35.  Defendant nonetheless billed, and has attempted and continues to attempt to collect,  that percentage of the entire gross medical bill.   36.  Defendant has demanded that each Class member pay it far in excess of what it can  legally recoup.   37.  Knowing the proclaimed debt to be illegitimate, Defendant has threatened to and  attempted to enforce the illegitimate debt against all Class members.   38.  Knowing the legal right to collect the proclaimed debt does not exist, Defendant  has nonetheless asserted to each Class member the existence of that putative legal right.  45.  Plaintiff incorporates by reference Paragraphs 1-11, 16, 17, and 31-44 as though  fully set forth herein.   46.  The money, if any, that each Class member owes Defendant constitutes a “debt” or  “consumer debt” for purposes of Fla. Stat. § 559.55(6).   47.  Defendant and persons acting under the direction of Defendant have, in violation  53.  Plaintiff incorporates by reference Paragraphs 1-11, 16, 17, 31-44, 46, and 47 as  though fully set forth herein.   54.  The Florida Deceptive and Unfair Trade Practices Act (“FDUTPA”), Fla. Stat. §  501.201 et seq., is designed to “protect the consuming public and legitimate business enterprises  from those who engage in unfair methods of competition, or unconscionable, deceptive, or unfair  acts or practices in the conduct of any trade or commerce.” Fla. Stat. § 501.202(2).   55.  At all material times:  a.  Each Class member was a consumer. See Fla. Stat. § 501.203(7);  b.  The Hospital was a merchant engaged in the provision of services; and  c.  The Hospital engaged in commerce by providing services to each Class member in  exchange for the promise of payment. See Fla. Stat. § 501.203(8).   559.55 ET SEQ., FLORIDA STATUTES   56.  A provider of services violates and is deemed liable under the FDUTPA by, inter  alia, violating “any law, statute, rule, regulation, or ordinance which proscribes unfair methods of  competition, or unfair, deceptive, or unconscionable acts or practices.” Fla. Stat. § 501.203(3)(c).   57.  Defendant’s violation of Section 559.72 et seq., the Florida Consumer Collection  Practices Act —a law that proscribes unfair, deceptive, or unconscionable acts or practices—thus  constitutes a per se violation of the FDUTPA.  Money Damages   58.  As a direct and proximate result of the Defendant’s deceptive and unfair trade  68.  Plaintiff incorporates by reference Paragraphs 1 through 44 as though fully set forth  herein.   69.  The Florida Legislature explicitly provided for violations of Fla. Stat. § 559.72 to  be remedied via class action. See Fla. Stat. § 559.77(2).   70.  Plaintiff seeks to represent the following Class:  All United States citizens who have been billed by the Hospital for medical  services that are required personal injury protection benefits under Section  627.736(1), Florida Statutes (2012), and against whom the Hospital has  attempted to enforce a debt for such services exceeding the maximum  amount allowed to be charged by the Hospital in accordance with Section  627.736(5), Florida Statutes (2012).   71.  Included within this Class is a Sub-Class:  All members of the Class who have paid the asserted debt in an amount  exceeding the amount the Hospital is allowed to bill the Class member  SECTION 501.201 ET SEQ., FLORIDA STATUTES  