15. Defendants’ standardized policy language as to comprehensive and collision coverage for ACV of total loss vehicles is present in every Progressive auto policies issued by Defendants in Florida.    16. Defendants’ standardized policy language as to comprehensive and collision coverage for ACV of total loss vehicles is present in Progressive auto policies issued by subsidiary insurance companies under control of Defendant Progressive Corporation and issuing auto coverage in Florida.   17. Defendants’ standardized policy language as to comprehensive and collision coverage for ACV of total loss vehicles is present in Progressive auto policies issued by Defendants and is present in policies of subsidiary insurance companies under control of Defendants.   18. Defendant Progressive Corporation sets the policy language and the claims process handling, including payment of ACV in the event of total losses.   19. S​ubsidiaries of Progressive Corporation are required to use the practices, policies, and procedures​ ​set by and enforced by Progressive Corporation.   20. Progressive Corporation governs and has full control over all policy, practices and procedures issued and/or enacted by its subsidiaries. Such subsidiaries operation only with Progressive Corporation’s complete and full knowledge, authority and control.   21. Progressive Corporation’s subsidiaries enact the policies, practices and procedures set and enforced by Progressive Corporation, and operate as its agents and alter-ego’s in all operations and actions.   23. At all times material hereto, Plaintiffs Henry Paris, Jr. and Patricia Paris owned a 2004 Jaguar XJ8, VIN # SAJWA71C64SG26787 (“Insured Vehicle”).   24. At all times material hereto, Plaintiff insured the 2004 Jaguar XJ8 under an insurance policy issued by Defendant. ​Ex. D​ (composite Policy-related documents) at 2 (Dec sheet).    25. On or about December 1, 2017, Henry Paris, Jr. and Patricia Paris were involved in an fatal accident while operating the Insured Vehicle. As a result of said accident, Plaintiffs’ Estate filed a claim for property damage with Defendants, claim number 17-1354847-01.    26. Following the filing of said claim, Defendants determined that the Insured Vehicle was a total loss with a base value of $6,324.94.   27. The base value was calculated by a third-party vendor (“CCC”), which bases vehicles valuations on the cost to purchase similar vehicles with similar conditions and mileage. CCC included in its Valuation Report the fact that sales tax was calculated at $421.86. No amount for title transfer fee, tag transfer fee, or any other mandatory fee was included.   28. Defendants’ paid $6,746.70 as the ACV payment.    29. Defendants’ payment of $6,746.70 - and not the FTLP (full total loss payment) including mandatory transfer fees - constituted a breach of its insurance policy.    30. Title transfer fees and tag transfer fees are both mandatory applicable fees that must be paid to replace any vehicle in the State of Florida.    32. Florida law requires that all vehicles have proper license plate (or tag) in order to be legally driven on Florida roadways. Fla. Stat. Ann. § 320.0609. The fee to transfer license plate or tag is $4.60.    33. Plaintiff was owed, at minimum, title transfer fees of $75.25 and tag transfer fees of $4.60.    34. In breach of its contract with Plaintiff, Defendants did not include transfer fees in making the ACV payment for Plaintiff’s total loss and did not make the FTLP.    35. Plaintiff paid all premiums owed and otherwise satisfied all conditions precedent such that their insurance policy was in effect and operational at the time of the accident.  48. Plaintiff brings this action seeking representation of a class pursuant to Fed. R. Civ. P. 23.    49. Plaintiff’s claims are typical to those of all class member because members of the class are similarly affected by Defendants’ failure to make the FTLP upon the total loss of insured vehicles. The material and relevant policy terms for each class member are substantially identical to the terms of Plaintiff’s policy.    50. Plaintiff’s interests are coincident with and not antagonistic to those of other class members, nor is the Plaintiff subject to any unique defenses.    52. Plaintiff’s claims are typical of the claims of all other members of the class because all such claims arise from the allegedly improper failure by Defendants to make a FTLP upon the total loss of insured vehicles.    53. Plaintiff and his counsel will fairly and adequately protect and represent the interests of each member of the class.    54. Plaintiff is committed to the vigorous prosecution of this action and has retained competent counsel experienced in prosecuting and defending class actions. Plaintiff’s counsel has successfully litigated other class action cases similar to that here, where insurers breached contracts with insureds by failing to include sales tax and/or total loss fees after total losses.   55. Class action is necessary, pursuant to Fed. R. Civ. P. 23(b)(1)(a), because the prosecution of separate actions by or against individual Class Members would create the risk of inconsistent or varying adjudications with respect to individual Class Members that would establish incompatible standards of conduct for Defendants.    57. Pursuant to Rule 23(b)(3), a class action is superior to the other available methods for a fair and efficient adjudication of the controversy because, among other reasons, it is desirable to concentrate the litigation of the Class Members’ claims in one forum, as it will conserve party and judicial resources and facilitate the consistency of adjudications. Furthermore, because the damages suffered by individual Class Members is relatively small, their interests in maintaining separate actions is questionable and the expense and burden of individual litigation makes it impracticable for Class Members to seek individual redress for the wrongs done to them. Plaintiff knows of no difficulty that would be encountered in the management of this case that would preclude its maintenance as a class action.    58. Any argument that class treatment is not viable or productive in the present action is undercut by the fact that the Middle District very recently treated as a class action a case that is substantially identical in fact and in law to the present action. See ​Bastian v. United Servs. Auto. Ass'n​, 150 F. Supp. 3d 1284 (M.D. Fla. December 10, 2015). ​Bastian ​is in the process of being successfully settled as a class, and stands as incontrovertible evidence demonstrating the efficacy and viability of class treatment in the present action. Similarly, ​Roth v. Geico General Insurance Co​., Case No. 16-62942-CIV-Dimitrouleas (S.D. Fla. June 14, 2018) is a substantially similar case recently certified as a class action with judgment entered in favor of the class.  