1.  Hepatitis C was first discovered in 1990 and is a contagious virus that  attacks the liver.  It spreads primarily through contact with the blood of an infected  person.  In 1992, the United States began screening blood utilized in transplants  and transfusions for the presence of contagious diseases including Hepatitis C.   Before 1992, Hepatitis C was commonly spread through blood transfusions or  transplant surgeries.     41.  This is a class action pursuant to Federal Rules of Civil Procedure  Rule 23 on behalf of Plaintiff and all individuals:  whose requests for Harvoni treatment have been denied (at any  time under the applicable statute of limitations) under any  ERISA-governed self-funded or fully-insured group health  insurance plan issued or administered by Blue Shield.   42.   Plaintiff and the Plaintiff Class reserve the right under Federal Rule of  Civil Procedure Rule 23(c)(1)(C) to amend or modify the class to include greater  specificity, by further division into subclasses, or by limitation to particular issues.     43.  This action has been brought and may be properly maintained as a  class action under the provisions of Federal Rules of Civil Procedure Rule 23  because there is a well-defined community of interest in the litigation and the  proposed class is easily ascertainable.   Numerosity   50.  Plaintiff and the Plaintiff Class repeat and re-allege each and every  allegation set forth in all of the foregoing paragraphs as is fully set forth herein.    51.  Plaintiff and the Plaintiff Class are covered by insurance plans issued  by Defendant.  Under the terms and conditions of the insurance plans and  applicable federal law, Blue Shield is required to pay for all medically necessary  prescription medication benefits.   52.  Defendant violated ERISA by wrongfully asserting that Harvoni  treatment is not a covered benefit under the plans.   53.  As a direct and proximate result of Defendant’s actions in denying  claims for medically necessary Harvoni treatment, Plaintiff and the Plaintiff Class  were forced financially to forego treatment altogether.  Plaintiff and the Plaintiff  Class are entitled to the reasonable value of the medically necessary Harvoni  treatment and related expenses.     59.  Plaintiff and the Plaintiff Class repeat and re-allege each and every  allegation set forth in all of the foregoing paragraphs as is fully set forth herein.   60.  Defendant acts as an ERISA fiduciary with respect to the  administration and claims decisions of the group health plans it issues to  employers, such as the Plan at issue, within the meaning of 29 U.S.C. §§ 1109(a)  and 1002(21)(A).  With respect to these plans, Defendant exercises discretionary  authority or control respecting management of the plans, exercises authority or  control respecting management or disposition of the plans’ assets.  Defendant has  the authority, and actually exercises the authority, to fund the plans, make  decisions on claims for benefits and appeals thereof, and to write checks for  benefits.     61.  Defendant has categorically and improperly denied requests for  Harvoni treatment, as alleged above.    62.  In acting and failing to act as described above, Defendant has  breached its fiduciary duties.   FOR BREACH OF FIDUCIARY DUTY UNDER AN ERISA PLAN  [29 U.S.C. § 1132(a)(3)]   FOR DENIAL OF PLAN BENEFITS UNDER ERISA  