MDL No.: 2406

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

CASE MANAGEMENT ORDER NO.3 – ORDER APPOINTING INTERIM COMMITTEE CHAIRS AND COMMITTEE MEMBERS FOR THE PLAINTIFF SUBSCRIBER AND PROVIDER TRACKS

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL No.:2406)

Master File No.: 2:13-CV-20000-RDP

CASE MANAGEMENT ORDER NO.3 – ORDER APPOINTING INTERIM COMMITTEE CHAIRS AND COMMITTEE MEMBERS FOR THE PLAINTIFF SUBSCRIBER AND PROVIDER TRACKS

On April 29, 2013, the Special Master filed his Report Recommending Interim Committee Chairs and Committee Members for Plaintiffs’ Subscriber and Provider Tracts. (Doc.# 62).

Case Management Order No. 3 Appointing Interim Committee Chairs (June 4, 2013)

Case Management Order No. 2 Appointing Interim Co-Lead Class Council

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL No.: 2406)

Master File No.: 2:13-CV-20000-RDP

CASE MANAGEMENT ORDER NO. 2 – ORDER APPOINTING INTERIM CO-LEAD CLASS COUNSEL, LOCAL FACILITATING COUNSEL, PLAINTIFFS’ STEERING COMMITTEE, AND DISCOVERY LIAISON COUNSEL

Case Management Order No. 2 Appointing Interim Co-Lead Class Council (April 26, 2013)

ORDER APPOINTING PLAINTIFFS’ LIAISON COUNSEL AND INVITING APPLICATIONS FOR PLAINTIFFS’ LEADERSHIP COMMITTEE POSITIONS

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL No.: 2406)

Master File No.: 2:13-CV-20000-RDP

ORDER APPOINTING PLAINTIFFS’ LIAISON COUNSEL AND INVITING APPLICATIONS FOR PLAINTIFFS’ LEADERSHIP COMMITTEE POSITIONS

I.  Appointment of Plaintiffs’ Liaison Counsel

On February 21, 2013, the court held an initial status conference in this MDL proceeding.  Prior to that conference, the court proposed the appointment of Barry A. Ragsdale to serve as Plaintiffs’ Liaison Counsel in this matter.

Order Appointing Plaintiffs Liason (Feb 28, 2013)

Case Management Order No. 1 Regarding Initial Status Conference

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL No.: 2406)
Master File.: 2:13-CV-20000-RDP

Initial Status Conference

A. This matter is SET for a status conference at 9:30 a.m., Thursday February 21, 2013, in Courtroom 7A at the Hugo L. Black United States Courthouse, 1729 5th Avenue North, Birmingham, Alabama.

Case Management Order No. 1 Regarding Initial Status Conference (Jan 9, 2013)

ORDER APPOINTING SPECIAL MASTER

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION (MDL No.: 2406)

Master File No.: 2:13-CV-20000-RDP

ORDER APPOINTING SPECIAL MASTER

Pursuant to federal Rule of Civil Procedure 53, and in the exercise of the court’s general powers and responsibilities over class actions, and with the agreement of the parties, the court hereby APPOINTS Edgar C. Gentle, III to serve a a Special Master in this action.

Order Appointing Special Master (Jan 1, 2013)

UNITED STATES JUDICIAL PANEL on MULTIDISTRICT LITIGATION

UNITED STATES JUDICIAL PANEL on MULTIDISTRICT LITIGATION

IN RE: BLUE CROSS BLUE SHIELD ANTITRUST LITIGATION             MDL No. 2406

TRANSFER ORDER

Before the Panel:  Pursuant to 28 U.S.C §1407, plaintiffs in the Northern District of Alabama GC Advertising action move to centralize this litigation in the Northern District of Alabama.  This antitrust litigation concerns the licensing agreements between and among the Blue Cross Blue Shield Association (BCBSA) and its 38 licensees (Blue Plans) and currently consists of seven actions pending in the Northern District of Alabama and a action each in the Western District of Tennessee and Western District of North Carolina, as listed on Schedule A.

MDL Transfer Order (Dec 12, 2012)