SUBSCRIBER TRACK CONSOLIDATED CLASS ACTION COMPLAINT

CLASS ACTION COMPLAINT
MDL No. 2406
JURY TRIAL DEMANDED

SUBSCRIBER TRACK CONSOLIDATED CLASS ACTION COMPLAINT

This is a class action brought on behalf of subscribers of the Individual Blue Plans
to enjoin an ongoing conspiracy between and among the Individual Blue Plans and BCBSA to
allocate markets in violation of the prohibitions of the Sherman Act. In addition, this action
seeks to recover damages for classes of subscribers in the form of supra-competitive premiums
that the Individual Blue Plans have charged – and lower competitive premiums that noncompeting
Blue plans have not charged – as a result of this illegal conspiracy. This action also
seeks these damages as a result of anticompetitive conduct the Individual Blue Plans have taken
in their illegal efforts to establish and maintain monopoly power throughout the regions in which
they operate. This action also asserts related claims under the laws of the following states:
Arkansas, California, Florida, Hawai’i, Illinois, Louisiana, Michigan, Mississippi, Missouri, New
Hampshire, North Carolina, Rhode Island, South Carolina, Tennessee, and Texas.

The Subscriber Track Consolidated Class Action Complaint was filed on July 1, 2013