90.  Plaintiffs bring this action on behalf of themselves and on behalf of all other  persons similarly situated (“the Class”).   92.  Numerosity.  The members of the Class are so numerous that joinder of all of  them is impracticable. While the exact number of Class Members is unknown to Plaintiffs at this  time, based on information and belief, the Class consists of thousands of patients of Defendant  TH whose data was compromised in the Ransomware attack.   94.  Typicality. Plaintiffs’ claims are typical of those of other Class Members because  Plaintiffs’ information, like that of every other Class member, was compromised in the  Ransomware Attack.   95.  Adequacy of Representation. Plaintiffs will fairly and adequately represent and  protect the interests of the members of the Class.  Plaintiffs’ Counsel are competent and  experienced in litigating class actions.   97.  Superiority. A class action is superior to other available methods for the fair and  efficient adjudication of the controversy. Class treatment of common questions of law and fact is  superior to multiple individual actions or piecemeal litigation. Absent a class action, most Class  Members would likely find that the cost of litigating their individual claim is prohibitively high  and would therefore have no effective remedy. The prosecution of separate actions by individual  Class Members would create a risk of inconsistent or varying adjudications with respect to  individual Class Members, which would establish incompatible standards of conduct for  Defendant. In contrast, the conduct of this action as a class action presents far fewer management  difficulties, conserves judicial resources and the parties’ resources, and protects the rights of  each class member.   98.  Defendant has acted on grounds that apply generally to the Class as a whole, so  that class certification, injunctive relief, and corresponding declaratory relief are appropriate on a  class-wide basis.  NEGLIGENCE  (On Behalf of Plaintiffs and All Class Members)  