21. Plaintiffs bring this action pursuant to I.R.C.P. 77(a) and (bX3) on behalf of the following class (the "Class"): All persons who are or were royalty owners in Idaho wells where Defendants Alta Mesa Resources, Inc., Alta Mesa Services, L.P., Alta Mesa Holdings, L.P.; AM Idaho, LLC, High Mesa Holdings, L.P., and High Mesa Services, LLC (including their affiliated predecessors and affiliated successors, collectively "Alta Mesa") are or were the operator (or a working interest owner who marketed its share of gas and directly paid royalties to the royalty owners) from January 1,2014 to the date Class Notice is given ("Class Period"). The Class claims relate to royalty payments for gas and its constituents (such as residue gas, natural gas liquids, or drip condensate). Excluded from the Class are: (l) agencies, departments or instrumentalities of the United States of America, including but not limited to the U.S. Department of the Interior (the United States, Indian tribes, and Indian allottees); (2) Defendants, their affiliates, predecessors, and employees, officers, and directors; (3) any entity that produces, gathers, processes, or markets gas, and its affiliates; (4) overriding royalty owners and others whose interest was carved out from the lessee's interest; and, (5) royalty owners only to the extent they take gas in-kind, if any. 90. Plaintiffs and the Class incorporate by reference the allegations in all other paragraphs of this Complaint as if fully set forth in this section.  91. Plaintiffs and the other Class Members entered into written, fully executed, oil and gas leases with Defendants, and those leases include implied covenants requiring Defendants to prepare the gas and its constituent parts for market at Defendants' sole cost. The leases also place upon Defendants the obligation to properly account for and pay royalty to royalty owners under the mutual benefit rule, the best reasonable price, and good faith and fair dealing.  92. At all material times, Plaintiffs and the Class have performed their terms and obligations under the leases.  93. Defendants conspired to and did breach the leases, including the express terms and/or implied covenants, by their actions and/or inactions in underpaying royalty or not paying royalty on all products sold from the gas stream and in using transactions with affiliates in calculating royalties.  94. As a result of Defendants' breaches, Plaintiffs and the Class have been damaged through underpayment of the actual amounts due for which they are entitled to recover in an amount to be proven at trial. 95. Plaintiffs and the Class incorporate by reference the allegations in all other paragraphs of this Complaint as if fully set forth in this section.  96.  The Defendants intentionally made omissions regarding the price, volume, various products produced, and deductions to suggest that the price was a third-party commercial price STATE OF IDAHO,IN AND FOR THE COUNTY OF PAYETTE Defendants. CLASS ACTION COMPLAINT. 1 Electronically Filed