10.  Mental Health and substance abuse treatment is a covered service. (Id. at 44).  This includes biologically-based mental conditions, non-biologically based mental, behavior  or emotional disorders. In-patient, intermediate treatments and outpatient services are all  covered. (Id. at 44-46). All “wilderness” types of coverage, even those that include licensed  mental health providers, psychotherapy and clinical programs, are expressly excluded by  the certificate. (Id. at 45).   11.  A.C., who is covered under her father’s plan and is thus entitled to receive  health insurance coverage based on the same plan language as her father’s, has struggled  for years with mental health issues such as depression, low self-esteem, suicidal ideation,  and drug use. On May 24, 2016, her therapist concluded that A.C. was no longer treatable in  an out-patient setting, and recommended an intensive, in-patient treatment. Her parents  chose, and she was transmitted, to Evoke Therapy, a mental health service provider based  in Santa Clara, Utah.   13.  Cotten appealed Blue Cross’s denial on June 6, 2016. Two days later, Blue  Cross affirmed its benefit denial. Again, the coverage denial was based exclusively on the  plan’s exclusion for all wilderness-related treatment without regard to the services’  medical necessity. The denial affirmation expressly states that, with its determination,  Cotten had exhausted Blue Cross’s internal administrative appeal process.    14.  Blue Cross’s wilderness therapy exclusion violates the federal Parity Act. The  Parity Act was “designed to end discrimination in the provision of coverage for mental  health and substance use disorders as compared to medical and surgical conditions in  employer-sponsored group health plans and health insurance coverage offered in  connection with group health plans.” American Psychiatric Ass’n v. Anthem Health Plans, 50  F. Supp.3d 157, 160 (D. Conn. 2014).  In relevant part, the Parity Act states:  In the case of a group health plan (or health insurance coverage offered in  connection with such a plan) that provides both medical and surgical benefits and  mental health or substance use disorder benefits, such plan or coverage shall ensure  that—  (ii) the treatment limitations applicable to such mental health or substance  use disorder benefits are no more restrictive than the predominant  treatment limitations applied to substantially all medical and surgical  benefits covered by the plan (or coverage) and there are no separate  treatment limitations that are applicable only with respect to mental health  or substance use disorder benefits.   29 U.S.C. § 1185a(a)(3)(A)(ii).   16.  Blue Cross’s plan violates the Parity Act in exactly the same manner. Its  blanket exclusion for services rendered at wilderness treatment centers is a separate  treatment limitation applicable only to mental health benefits and thus violative of the  Parity Act.  17.  Plaintiff brings this lawsuit on their own behalf and on behalf of the following  class: All persons who are covered under any contract or plan of health insurance that is  administered, underwritten or insured by Blue Cross and Blue Shield of Massachusetts HMO  Blue that insures behavioral or mental health care and whose claim for coverage for  wilderness therapy was denied because the contract or plan excluded such coverage.   19.  Plaintiff’s claims are typical of all other class members.  All class members’  claims are unified, as all were improperly denied coverage in a manner that violated the  protection of the federal Parity Act.    20.  Plaintiff’s interests are coincident with, and not antagonistic to, those of the  other members of the class.   21.  Plaintiff will adequately represent the class because he has interests in  common with the proposed class members and plaintiff has retained attorneys who are  experienced in class action litigation.   22.  There is a well-defined community of interest in the questions of law and fact  involving and affecting the class to be represented by plaintiff. Common questions of law  and/or fact predominate over any questions affecting only individual members of the class.   Common questions include, but are not limited to, the following:  a. Whether defendant’s blanket denial of coverage for wilderness therapy  violate the Parity Act?   b. If the defendant’s acts violate the Parity Act, what is the appropriate remedy?  c. What is the appropriate measure of damages?   24.  The class action method is appropriate for the fair and efficient prosecution  of this action.    25.  Individual litigation of all claims that might be asserted by all class members  would produce such a multiplicity of cases that the judicial system, having jurisdiction of  the claims, would remain congested for years.  Class treatment, by contrast, provides  manageable judicial treatment calculated to bring a rapid conclusion to all litigation of all  claims arising out of the conduct of the defendants.   26.  The certification of the above class would allow litigation of claims that, in  view of the expense of the litigation, may be an insufficient amount to support separate  actions.  A.  Coverage  