15.  So Be was adopted from Russia when she was 20 months old after being  removed from her natural parents because of their neglect. By the time she was 14, she  was diagnosed with Unspecified Mood Disorder and Generalized Anxiety Disorder. She  also struggled with learning challenges, and was diagnosed with Developmental  Disorder of Scholastic Skills and Mathematics Disorder. All of these disorders are  recognized by the Diagnostic and Statistical Manual.   16.  These disorders manifested in a variety of ways.  So Be developed eating  disorders, engaged in suicideation, and was severely depressed.  After continued  suicideation, So Be’s caregivers recommended that she enroll as an inpatient at a  wilderness therapy program. With their advice, Su Be selected New Vision Wilderness  Therapy, where So Be was treated between July 5, 2017 and September 1, 2017. Su Be was  charged, and paid $29,205 for those medically necessary services.  Defendants’ Denial of Coverage   18.  Su Be brings this class action on behalf of two classes. The “Comcast Class”  is:  All persons (a) insured by a certificate of coverage (b) underwritten by Comcast  Corporation  (c) whose wilderness therapy coverage requests were denied (d)  because the applicable health insurance plan specifically excluded wilderness  therapy from coverage.    19.  The “Magellan Class” is  All persons (a) whose self-funded ERISA-regulated health insurance plans were (b)  administered by Magellan and (c) whose wilderness therapy coverage requests were  denied (d) because the applicable health insurance plan specifically excluded  wilderness therapy from coverage.    20.  The class period for both classes began six years before the  commencement of this action and concludes on the date the classes are certified.   21.  The exact number of members of either class is not known, but it is  estimated there are at least hundreds of persons in either class.  Accordingly, class  membership is so numerous that joinder of individual members of the two classes in this  action is impracticable.  Individual class members are identifiable as the names and  addresses of all members of both classes are contained in business records maintained by  defendants and may be obtained through discovery.    23.  The claims of Su Be are typical of the claims of all members of either class  because Defendants employ the same or similar  coverage language, and coverage  practices, for each and every member of the two classes.  The same legal theories are  raised for each member of the two classes.   24.  Su Be can fairly and adequately protect and represent the interests of each  member of both classes because she has no conflict of interest in this cause of action with  either of the two classes and their membership.  Su Be’s interests are perfectly aligned  with the members of both classes and Su Be and the members of both classes have a  mutual interest in seeking damages and other relief against Defendants. Su Be is  represented by competent and experienced class action counsel.   25.  This action is maintainable under Fed. R. Civ. P. 23(b)(1) because the  prosecution of separate actions by individual members of either class would create a risk  of inconsistent or varying adjudications with respect to individual members of the class  that would establish incompatible standards of conduct for Defendants.   27.  Su Be realleges and incorporates paragraphs 1-26 as if fully set forth.    28.  Su Be’s first legal claim is brought under 29 U.S.C. § 1132(a)(1)(B) for  violations of the Parity Act, which is incorporated into ERISA, at 29 U.S.C. § 1185a. It is  brought on her own behalf, and on behalf of the Comcast Class.    29.  Under the Parity Act, health insurers must “treat sicknesses of the mind in  the same way that they would a broken bone.” New York State Psychiatric Ass’n, Inc. v.  United Health Grp., 980 F. Supp.2d 527, 542 (S.D.N.Y.), aff'd in part, vacated in part, 798 F.3d  125 (2d Cir. 2015).    30.  A “treatment limitation” is a limit on either “the scope or duration of  treatment.” 29 U.S.C. § 1185(a)(3)(B)(iii).     32.  Second, any limitation applied to mental health treatment must be  scrutinized by comparing it to the limitations placed on an analogous medical or surgical  treatment in the same classification. 45 C.F.R. § 146-136(c)(2)(i)-(ii).    33.  Comcast’s health insurance plans exclude from coverage medically  necessary services rendered at wilderness therapy programs while expressly covering  comparable medically necessary services rendered at skilled nursing facilities and  rehabilitation hospitals.    34.  This disparate treatment for comparable services results in Comcast being  out of parity. This disparate treatment in comparable services violates the federal Parity  Act as incorporated into Comcast’s health plans.   35.  Su Be realleges and incorporates paragraphs 1-26 as if fully set forth.    36.  Su Be’s second claim is brought under 29 U.S.C. § 1132(a)(1)(B) for  violations of the Parity Act, which is incorporated into ERISA, at 29 U.S.C. § 1185a. It is  brought on her own behalf, and on behalf of the Magellan Class.    37.  Under the Parity Act, health insurers must “treat sicknesses of the mind in  the same way that they would a broken bone.” New York State Psychiatric Ass’n, Inc. v.  United Health Grp., 980 F. Supp.2d 527, 542 (S.D.N.Y.), aff'd in part, vacated in part, 798 F.3d  125 (2d Cir. 2015).    39.  Regulations promulgated under this statute focus the Court’s analysis in  two respects. First, both “quantitative” and “nonquantitative” treatment limitations may  run afoul of the Parity Act.  45 C.F.R § 146-136(a). Whereas a quantitative limitation is  reduceable to a number, a nonquantitative treatment limitation is any other limitation on  the scope or duration of treatment. 45 C.F.R. § 146-136(c)(4)(i).    40.  Second, any limitation applied to mental health treatment must be  scrutinized by comparing it to the limitations placed on an analogous medical or surgical  treatment in the same classification. 45 C.F.R. §  146-136(c)(2)(i)-(ii).    41.  Magellan administers  health insurance plans that exclude from coverage  medically necessary services rendered at wilderness therapy programs while expressly  covering comparable medically necessary services rendered at skilled nursing facilities  and rehabilitation hospitals.    42.  This disparate treatment for comparable services results in Magellan being  out of parity and in violation of the federal Parity Act as incorporated into the health  plans it administers.  WHEREFORE, Plaintiff Su Be, and all other persons similarly situated, demands  judgment against Defendants, for benefits, damages, interest, costs, attorney’s fees  including enhancement of fees, a trial by jury for all issues so triable, and such other relief  as this Court deems just and proper.   Insurance coverage promises   VIOLATING  PARITY ACT PROTECTIONS  BROUGHT INDIVIDUALLY AND ON BEHALF OF THE COMCAST CLASS   VIOLATING INCORPORATED PARITY ACT PROTECTIONS  BROUGHT INDIVIDUALLY AND  ON BEHALF OF THE MAGELLAN CLASS  