BCBSM, Inc. v. GS Labs, LLC

U.S. District Court, District of Minnesota

BCBSM, Inc. v. GS Labs, LLC

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF MINNESOTA                                


BCBSM, Inc., a Minnesota nonprofit          File No. 22-cv-513 (ECT/DJF) 
corporation, on behalf of itself and its self-                            
insured groups d/b/a Blue Cross and Blue                                  
Shield of Minnesota,                                                      

         Plaintiff and Counter-                                          
         Defendant,                     OPINION AND ORDER                

v.                                                                        

GS Labs, LLC,                                                             

         Defendant and                                                   
         Counterclaimant.                                                
________________________________________________________________________  
Charles Gokey, Geoffrey H. Kozen, Jeffrey Sullivan Gleason and Stephanie Alicia Chen, 
Robins Kaplan LLP, Minneapolis, MN for Plaintiff and Counter-Defendant BCBSM, Inc. 
Kyle R. Kroll, Thomas H. Boyd, David M. Aafedt and Christianna L. Finnern, Winthrop 
& Weinstine, PA, Minneapolis, MN, and Kajetan Rozga, Yonaton M. Rosenzweig and 
Adam  Sieff,  Davis  Wright  Tremaine,  LLP,  Los  Angeles,  CA  for  Defendant  and 
Counterclaimant GS Labs, LLC.                                             
________________________________________________________________________  
    This case began with a dispute over payment for COVID-19 diagnostic testing.  
Defendant and Counterclaimant GS Labs claims to have provided COVID diagnostic tests 
to over 300,000 Minnesotans, more than 70,000 of whom were insured, or had insurance 
administered by, Plaintiff and Counter-Defendant BCBSM (“Blue Cross”).  GS Labs says 
that the tests it provided were necessary, high-quality, and contributed positively to the 
nation’s pandemic response.  Blue Cross, on the other hand, says GS Labs is a pandemic 
profiteer that charged unreasonably high prices for unnecessary, faulty tests. 
    Blue Cross brought the case.  It asserts one claim under federal law and four claims 
under Minnesota law.  It seeks damages comprised of the millions of dollars it has paid GS 

Labs and additional sums it has incurred to address GS Labs’ alleged misconduct.  Blue 
Cross also seeks a declaration that it is not legally obligated to pay GS Labs for outstanding 
claims, an injunction essentially forbidding GS Labs from seeking payment from Blue 
Cross members and plans, and attorneys’ fees and costs.                   
    GS Labs responded to Blue Cross’s Complaint with an Answer and Counterclaim, 
and it has since amended the Counterclaim.  The Amended Counterclaim has twenty-one 

counts.  In seven of these, GS Labs asserts claims arising under federal law, including the 
CARES Act, ERISA, the Lanham Act, and the Sherman Act.  In twelve counts, GS Labs 
asserts claims under Minnesota law.1  The remaining two counts describe requested 
remedies:  a declaratory judgment and punitive damages.  For relief, GS Labs seeks 
reimbursement for diagnostic testing services it provided to individuals covered under 

benefit plans insured or administered by Blue Cross, millions in additional damages it 
claims to have incurred as a result of Blue Cross’s conduct, treble antitrust damages, 
punitive damages, declaratory relief, and attorneys’ fees and costs.      
    Blue  Cross  has  filed  a  motion  seeking  dismissal  of  GS  Labs’  Amended 
Counterclaim in its entirety under Federal Rule of Civil Procedure 12(b)(6).  The short 

version of a longer story is that most of GS Labs claims will be dismissed.  Left to proceed 

1    The Amended Counterclaim references Minnesota law specifically for statutory 
claims, but not claims under the common law.  Though GS Labs’ allegations imply that 
the case may have connections to other states, GS Labs made clear at the hearing on this 
motion that it asserts all of its state claims under Minnesota law.       
will be GS Labs’ claims for promissory estoppel and for benefits due under ERISA’s civil 
enforcement provision, 
29 U.S.C. § 1132
(a)(1)(B).                         

                               *                                         
    This order’s structure.  This order addresses GS Labs’ 21 claims in the order they 
appear in the Amended Counterclaim.  Though some claims might reasonably have been 
grouped together—that is how the parties approached the problem—each claim is analyzed 
separately.  The Roman numeral appearing at the beginning of each section corresponds to 
the Count being analyzed.  Rather than provide a detailed facts section up front, the relevant 

factual allegations will be described as each Count is analyzed.  Regardless, a few basic 
background facts deserve mention up front to provide context.             
    Basic background facts.  GS Labs was formed in January 2020.  Am. Countercl. 
[ECF No. 22] ¶ 16.  When the COVID pandemic began, GS Labs entered the diagnostic 
testing market, developing infrastructure and opening and staffing over fifty COVID 

testing sites across the country, including eleven in Minnesota.  
Id.
 ¶¶ 17–22, 24.   Blue 
Cross is a health insurer and an administrative services provider to self-funded health plans.  
Id. ¶ 72
.  Under these third-party health plans, also known as Administrative Services Only 
or “ASO” plans, the plan funder assumes the risk of the plan and contracts with an 
insurance company (here, Blue Cross) to provide administrative services and manage the 

plan’s day-to-day operations.  
Id. ¶ 73
.  GS Labs, without requiring prepayment, performed 
thousands of COVID-19 tests for Blue Cross insureds or for persons whose plans Blue 
Cross administered.  
Id. ¶¶ 40, 78
.  GS Labs submitted its first request for reimbursement 
to Blue Cross on December 22, 2020.  
Id. ¶ 41
.  Blue Cross reimbursed GS Labs for a time, 
but eventually stopped paying because of the allegations it makes in this case.  See 
id.
 ¶¶ 
43–48; 58; 61–62.                                                         

    The familiar Rule 12(b)(6) standards.  In reviewing a motion to dismiss for failure 
to state a claim under Rule 12(b)(6), a court must accept as true all of the factual allegations 
in the complaint and draw all reasonable inferences in the plaintiff's favor.  Gorog v. Best 
Buy Co., 
760 F.3d 787, 792
 (8th Cir. 2014).  Although the factual allegations need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative level.”  Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must “state a claim to 

relief that is plausible on its face.”  
Id. at 570
.  “A claim has facial plausibility when the 
plaintiff pleads factual content that allows the court to draw the reasonable inference that 
the defendant is liable for the misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 
(2009).  A court need not, however, accept as true wholly conclusory allegations or legal 
conclusions couched as factual allegations.  Hager v. Ark. Dep’t of Health, 
735 F.3d 1009, 1013
 (8th Cir. 2013).  Matters outside the pleadings are also not ordinarily considered on 
a motion to dismiss.  See Fed. R. Civ. P. 12(d).  This includes “any written or oral evidence 
in support of or in opposition to the pleading that provides some substantiation for and does 
not merely reiterate what is said in the pleadings.”  Hamm v. Rhone-Poulenc Rorer Pharm., 
Inc., 
187 F.3d 941, 948
 (8th Cir. 1999).  A court may, however, consider exhibits attached 

to the pleadings, materials embraced by the pleadings, and matters of public record.  Illig 
v. Union Elec. Co., 
652 F.3d 971, 976
 (8th Cir. 2011).                    
     In Count I, GS Labs asserts a claim under § 3202 of the Coronavirus Aid, Relief, 
and Economic  Security (or “CARES”) Act.  Am.  Countercl. 4] 273-308.  The issue is 
whether § 3202 creates a private right of action.  Section 3202 reads: 
     SEC. 3202. PRICING OF DIAGNOSTIC TESTING. 
         (a) REIMBURSEMENT RATES.—A  group  health  plan  or  a health 
     insurance issuer providing coverage  of items and services described 
     in  section  6001(a)  of division  F  of the  Families  First  Coronavirus 
     Response  Act  (
Public Law 116-127
)  with  respect  to  an  enrollee 
     shall  reimburse  the  provider  of the  diagnostic  testing  as  follows: 
             (1)  If the health 1 Plan  or issuer has  a  negotiated  rate  with 
         such  provider  in  effect  before  the  public   health  emergency 
         declared  under  section  319  of  the  Public  Health  Service  Act 
         (42  U.S.C.  247d),  such  negotiated  rate  shall  apply  throughout 
         the period of such declaration. 
             (2)  If the health plan or issuer does not have a negotiated 
         rate  with  such  provider,  such  plan  or  issuer  shall  reimburse 
         the  provider in  an amount that equals the cash  price  for  such 
         service  as  listed  by the  provider  on  a  public  internet  website, 
         or such plan or issuer may negotiate a rate with such  provider 
         for less   than such cash price. 
         (b)  REQUIREMENT  TO  PUBLICIZE  CASH  PRICE  FOR  DIAGNOSTIC 
     TESTING FOR COVID-19.— 
             (1)  IN  GENERAL.—During  the  emergency  period  declared 
         under  section  319 of the Public  Health  Service Act (42  U.S.C. 
         247d),  each  provider  of a  diagnostic  test  for  COVID-19  shall 
         make  public the  cash  price  for  such  test  on  a  public  internet 
         website of such provider. 
             (2)  CIVIL MONETARY PENALTIES.—The  Secretary  of Health 
         and  Human  Services  may  impose  a  civil  monetary  penalty 
         on  any  provider  of  a  diagnostic  test  for  COVID-19  that  is 
         not  in  compliance  with  paragraph  (1)  and  has  not  completed 
         a  corrective  action  plan  to  comply  with  the  requirements  of 
         such  paragraph,  in  an  amount  not  to  exceed  $300  per  day 
         that the violation is ongoing. 
Pub. L. No. 116-136, § 3202
, 
134 Stat. 281
, 367 (2020).  The section of the Families First 
Coronavirus Response Act (or “FFCRA”) referenced in § 3202(a) requires group health 
plans  and their insurers  to  “provide  coverage,”  and forbids them  from imposing  “cost 
sharing” or “prior authorization or other medical management requirements,” for FDA-

approved “diagnostic products . . . for the detection of SARS-CoV-2 or the diagnosis of 
the virus that causes COVID-19.”  
Pub. L. No. 116-127, § 6001
(a), 
134 Stat. 178
, 201–02 

(2020).                                                                   
    As  factual  support  for  this  claim,  GS  Labs  alleges  that  it  has  no  negotiated 
reimbursement rate with Blue Cross.  Am. Countercl. ¶ 305.  It contends that § 3202 entitles 
it to receive reimbursement at whatever price it published on its website and gives it a cause 
of action to obtain amounts due from group health plans or their insurers.  See id. ¶ 303. 
    “Like substantive federal law itself, private rights of action to enforce federal law 

must be created by Congress.”  Alexander v. Sandoval, 
532 U.S. 275, 286
 (2001).  “The 
judicial task is to interpret the statute Congress has passed to determine whether it displays 
an intent to create not just a private right but also a private remedy.”  Id.; see also 
Transamerica Mortg. Advisors, Inc. v. Lewis, 
444 U.S. 11, 15
 (1979) (“The question 
whether a statute creates a cause of action, either expressly or by implication, is basically 

a  matter  of  statutory  construction.”).    “It  is  now  clear  that  the  proper  focus  is  on 
congressional intent, and nothing short of an unambiguously conferred right will support 
an implied right of action.”  Osher v. City of St. Louis, 
903 F.3d 698, 702
 (8th Cir. 2018) 
(cleaned up).  “It is insufficient to show merely that a particular statute intended to benefit 
the putative plaintiff.”  
Id.
 (cleaned up).                               

    The better answer is that § 3202 does not create a private remedy.  This is so for 
several reasons: (1) The statute authorizes no judicial proceeding.  (2) Neither does it define 
a class that may bring suit.  (3) That part of the statute concerning reimbursement (on which 
GS Labs chiefly relies) focuses on health plans and health insurance issuers, not on 
providers like GS Labs.  The statute, in other words, “does not contain rights-creating 
language that is phrased in terms of the persons benefitted.”  Id. at 702 (cleaned up).  (4) 

The statute’s only identified enforcement mechanism empowers the Secretary of Health 
and Human Services to impose a specified civil monetary penalty on providers who do not 
comply with the requirement that they publicize the cash price for testing “on a public 
internet website of such provider.”  This seems significant because “[t]he express provision 
of one method of enforcing a substantive rule suggests that Congress intended to preclude 
others[,]” Alexander, 
532 U.S. at 290
, and because the enforcement method Congress 

created runs the opposite direction of the remedy GS Labs seeks to imply. 
    This determination falls in line with the majority of courts that have addressed the 
issue.  Though neither the Supreme Court nor the Eighth Circuit have addressed this 
question, at least five district courts have, and four of those have determined that § 3202 
does not create a private right of action for providers.  Compare GS Labs, Inc. v. Medica 

Ins. Co., No. 21-cv-2400 (SRN/TNL), 
2022 WL 4357542
, at *3–12 (D. Minn. Sept. 20, 
2022); Saloojas Inc. v. Blue Shield of Cal. Life & Health Ins. Co., No. 22-cv-3267-MMC, 
2022 WL 4843071
, at *1 (N.D. Cal. Oct. 3, 2022); Saloojas, Inc. v. Aetna Health of Cal., 
Inc., No. 22-cv-01696-JSC, 
2022 WL 2267786
, at *2–5 (N.D. Cal. June 23, 2022); and 
Murphy Med. Assocs., LLC v. Cigna Health & Life Ins. Co., No. 3:20cv1675, 
2022 WL 743088
, at *2–6 (D. Conn. Mar. 11, 2022), with Diagnostic Affiliates of Ne. Hou, LLC v. 
United Healthcare Servs., Inc., No. 2:21-cv-00131, 
2022 WL 214101
, at *3–9 (S.D. Tex. 
Jan. 18, 2022).                                                           
    GS Labs advances several arguments to show that § 3202 creates a private right of 
action.  Most of these are addressed in the analysis above and in the cases cited in the 

preceding paragraph holding that § 3202 does not create a private right of action.  Two 
contentions deserve additional attention.                                 
    First, GS Labs argues that § 3202(a)’s lack of an enforcement mechanism is an 
implicit indication of Congressional intent to create a private right of action.  Mem. in 
Opp’n [ECF No. 47] at 13–18.  As support for this argument, GS Labs relies on Steele v. 
Louisville & N.R. Co., 
323 U.S. 192
 (1944).  There, the Supreme Court held that when 

Congress issues a statutory command with no enforcement mechanism “other than resort 
to the courts,” courts have the “jurisdiction and duty to afford a remedy for a breach of 
statutory duty.”  
Id. at 207
.  Steele, however, is emblematic of an era during which courts 
held and applied a considerably broader view of implied causes of action.  See Ziglar v. 
Abbasi, 
137 S. Ct. 1843, 1855
 (2017).  Binding precedent today counsels caution in 

implying causes of action and directs that the focus be on statutory intent.  See id.; Syngenta 
Seeds, Inc. v. Bunge N. Am., Inc., 
773 F.3d 58, 63
 (8th Cir. 2014).  The determination that 
§ 3202 creates no private right off action is more faithful to the modern, controlling 
approach.                                                                 
    Second, GS Labs refers to parts of the CARES Act’s legislative history that it alleges 

support implying a private right of action.  Am. Countercl. ¶¶ 282–88.  The history on 
which  GS  Labs  relies  consists  largely  of  legislators’  statements  emphasizing  the 
importance of testing to address the COVID-19 pandemic.  See id.  The “ordinary problems 
with relying on legislative history—no bicameralism and presentment, focus on ‘intent’ 
rather than meaning, unfamiliarity of legislators with the material, and so forth” are widely 
recognized.  United States v. Mast, 
938 F.3d 973
, 979–80 (8th Cir. 2019) (Colloton, J., 

dissenting) (citing Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of 
Legal Texts 369–90 (2012)).  These ordinary problems aside, the legislative history GS 
Labs identifies addresses the wisdom of testing from many perspectives, but none of this 
history is specific to § 3202, much more the question whether § 3202 creates the private 
right of action GS Labs seeks to assert here.  GS Labs’ claim under the CARES Act (Count 
I) will be dismissed because § 3202 creates no private right of action for the recovery of 

unpaid or underpaid diagnostic-testing charges.                           
                               II                                        
    The declaratory judgment GS Labs seeks in Count II is derived from and concerns 
the same issue as Count I—whether § 3202 creates a private right of action.  See Am. 
Countercl. ¶¶ 309–14.  Therefore, this claim also will be dismissed.  See Doe v. Univ. of 

St. Thomas, 
240 F. Supp. 3d 984, 989
 (D. Minn. 2017) (recognizing that the Declaratory 
Judgment Act, 
28 U.S.C. § 2201
, “cannot be used as an independent cause of action” when 
the underlying statute contains no private right of action).              
                              III                                        
    GS Labs asserts a typical breach-of-contract claim in Count III.  Under Minnesota 

law, the elements of a breach-of-contract claim are “(1) formation of a contract, (2) 
performance by plaintiff of any conditions precedent to his right to demand performance 
by the defendant, and (3) breach of the contract by defendant.”  Park Nicollet Clinic v. 
Hamann, 
808 N.W.2d 828, 833
 (Minn. 2011).  “The formation of a contract requires 
communication of a specific and definite offer, acceptance, and consideration.”  E. Coast 
Test Prep LLC v. Allnurses.com, Inc., 
307 F. Supp. 3d 952, 970
 (D. Minn. 2018).   

    GS Labs alleges that it had a contract with Blue Cross under which Blue Cross 
“agreed to pay GS Labs at the cash prices publicly posted on GS Labs’ website.”  Am. 
Countercl. ¶ 317.  To show formation of this contract, GS Labs alleges that a Blue Cross 
employee, Senior Provider Contract Manager Kevin L. Jones, emailed GS Labs on March 
31, 2021, stating that Blue Cross “declines to negotiate rates for these services and will 
reimburse eligible services per your pricing as listed on the GS Labs website as required 

by section 3202 of the CARES Act.”  See id.; ECF No. 38-2.  “Mr. Jones also asked GS 
Labs to register as an ‘out-of-network provider’. . . by completing a registration form.”  
Am. Countercl. ¶ 317.  GS Labs alleges that it accepted this “offer” when it “filled out the 
registration form requested by Blue Cross.”  Id. ¶ 318.  GS Labs alleges that Blue Cross 
breached this contract when it “abruptly backtracked on its agreement to pay the cash prices 

posted on GS Labs’ website in August 2021.”  Id. ¶ 322.                   
    The email on which the claim depends cannot plausibly be understood as an offer 
by Blue Cross to contract with GS Labs.  The email’s author explicitly disclaimed an intent 
to contract when he wrote that Blue Cross “declines to negotiate rates for these services.”  
The author’s statement that Blue Cross would pay “as required by section 3202 of the 

CARES Act” expressed an “at-this-time” intention to comply with the law as Blue Cross 
understood it.  The email neither required nor invited formation of a contract to follow 
through on that intention.  Instead, the email invited GS Labs to register as an “out-of-
network” provider.  But the registration form implies, ECF No. 38-3, and cases confirm, 
that non-participating, out-of-network providers generally do not have contracts with 
insurers.  See, e.g., N. Cypress Med. Ctr. Operating Co., Ltd. v. Aetna Life Ins. Co., 
898 F.3d 461, 469
 (5th Cir. 2018) (“In-network providers contract with Aetna to provide 
services at pre-arranged reimbursement rates in exchange for access to Aetna’s members 
as patients.  Out-of-network providers do not; they have no contract with Aetna and instead 
set their own fees for services.”); Weight Loss Healthcare Ctrs. of Am., Inc. v. Off. of Pers. 
Mgmt., 
655 F.3d 1202, 1208
 (10th Cir. 2011) (“Non-participating providers have no 
contract with Blue Cross.”).  GS Labs’ allegations confirm—and plainly do not refute—

the presence of this non-contractual out-of-network relationship here.    
                              IV                                         
    To state a promissory estoppel claim, GS Labs must allege facts plausibly showing 
that (1) a clear and definite promise was made; (2) the promisor intended to induce reliance 
and the promisee in fact relied to its detriment; and (3) the promise must be enforced to 

prevent injustice.  Martens v. Minn. Mining & Mfg. Co., 
616 N.W.2d 732, 746
 (Minn. 
2000).  Promissory estoppel “impl[ies] a contract in law where none exists in fact.”  Grouse 
v. Grp. Health Plan, Inc., 
306 N.W.2d 114, 116
 (Minn. 1981).  “The second element of 
promissory estoppel is satisfied when the promisor should reasonably have expected to 
induce the promisee’s reliance, and the promisee reasonably relies to its detriment.”  

Heffron v. Burlington N. & Santa Fe. Ry. Co., No. A11-2039, 
2012 WL 3262968
, at *4 
(Minn. Ct. App. Aug. 6, 2012); accord Myrlie v. Countrywide Bank, 
775 F. Supp. 2d 1100, 1107
 (D. Minn. 2011).                                                     
    GS Labs’ promissory-estoppel theory is straightforward.  It alleges that Blue Cross 
promised “to pay GS Labs at the cash prices publicly posted on GS Labs’ website, as 

required by the CARES Act, in its email dated March 31, 2021.”  Am. Countercl. ¶ 327.  
GS Labs alleges that it relied on this promise to its detriment when it “filled out the 
registration form requested by Blue Cross[,]” and when it “provided COVID-19 diagnostic 
testing to Blue Cross[] insureds” and billed Blue Cross for those services.  Id. ¶ 329.  And 
GS Labs alleges that “[t]he injustice of Blue Cross’[s] conduct, and that conduct’s unjust 
effects, can be avoided by enforcement of Blue Cross’[s] promise.”  Id. ¶ 332. 

    Though it is a close call, I conclude this claim is plausible.  Whether the statement 
on which GS Labs relies is a “clear and definite promise” seems fairly debatable.  In Blue 
Cross’s favor, the statement includes no mention of the promise’s duration and the author’s 
use of the phrase “at this time” implies obvious hedging.  In GS Labs’ favor, the “at this 
time” phrase might reasonably be understood to apply only to Blue Cross’s unwillingness 

“to negotiate rates” and not to Blue Cross’s commitment to reimburse per GS Labs’ 
website-listed pricing.  The promise to pay “as required by section 3202 of the CARES 
Act” begs the question of what precisely § 3202 required.  But the email thread preceding 
the promise included a link to GS Labs’ website pricing and CPT coding, see ECF No. 38-
2 at 2–3, and the plausible inference is that the promise’s author reviewed that pricing and 

related information on GS Labs’ website before committing to pay “per your pricing as 
listed on GS Labs website[,]” id. at 2.  Regarding the reliance element, Blue Cross has a 
point: GS Labs hasn’t alleged what, if anything, it did differently after receiving Blue 
Cross’s promise.  GS Labs’ theory seems to be that it continued business-as-usual to 
provide diagnostic testing services to Blue Cross insureds.  GS Labs does not allege 
explicitly that it would have stopped providing these services but for Blue Cross’s promise, 

but that seems to be the point.  It makes practical sense that continuing a business 
relationship  based  on  a  promise  plausibly  may  count  as  reliance  for  purposes  of  a 
promissory  estoppel  claim.    No  authority  has  been  cited  that  might  undermine  this 
commonsense notion, and some Minnesota authorities support the understanding that both 
an affirmative change of position and forbearance may show reliance for purposes of a 
promissory estoppel claim.  See Meriwether Minn. Land & Timber, LLC v. State, 
818 N.W.2d 557, 567
 (Minn. Ct. App. 2012) (“The promise must be such that it ‘might 
reasonably induce the promisee’s action or inaction.’”) (emphasis added) (quoting Faimon 
v. Winona State Univ., 
540 N.W.2d 879, 882
 (Minn. Ct. App. 1995), review denied (Minn. 
Feb. 9, 1996)); see also Restatement (Second) of Contracts § 90(1) (Am. L. Inst. 1981).  
Therefore, the promissory estoppel claim survives.                        

                               V                                         
    GS Labs asserts an unjust enrichment claim in Count V.  The Minnesota Supreme 
Court has described the elements of an unjust enrichment claim as follows: 
         To establish an unjust enrichment claim, the claimant must      
         show that the defendant has knowingly received or obtained      
         something of value for which the defendant in equity and good   
         conscience should pay.  [U]njust enrichment claims do not lie   
         simply  because  one  party  benefits  from  the  efforts  or   
         obligations of others, but instead it must be shown that a party 
         was unjustly enriched in the sense that the term unjustly could 
         mean illegally or unlawfully.                                   
Caldas v. Affordable Granite & Stone, Inc., 
820 N.W.2d 826, 838
 (Minn. 2012) (quoting 
ServiceMaster of St. Cloud v. GAB Bus. Servs., Inc., 
544 N.W.2d 302, 306
 (Minn. 1996)); 

see also Klass v. Twin City Fed. Sav. & Loan Ass’n, 
190 N.W.2d 493
, 494–95 (Minn. 
1971) (“Very broadly defined, the [unjust-enrichment] cause of action was described by 
Mr. Justice Mitchell in Brand v. Williams, 
29 Minn. 238, 239
, 
13 N.W. 42
, as one which 
‘can be maintained whenever one man has received or obtained the possession of the 
money of another, which he ought in equity and good conscience to pay over.’”); Cady v. 
Bush, 
166 N.W.2d 358, 361
 (Minn. 1969) (“[T]he theory of unjust enrichment . . . ‘is 

founded on the principle that no one ought unjustly to enrich himself at the expense of 
another, and the gist of the action is that the defendant has received money which in equity 
and good conscience should have been paid to the plaintiff, and under such circumstance 
that he ought, by the ties of natural justice, to pay over.’”) (citation omitted). 
    GS Labs alleges that Blue Cross received value in two ways.  First, GS Labs says 

that it provided diagnostic testing services to Blue Cross members “without prepayment” 
from Blue Cross and that this lack of prepayment “enabled Blue Cross to use its money for 
other purposes, which corresponded to avoidance of the cost of capital for those purposes.”  
Am. Countercl.  ¶ 337.  Second, GS Labs alleges that its services “improved health 
outcomes, which have dramatically reduced Blue Cross’[s] health care spend and the 

spending it would have outlaid in the absence of GS Labs’ testing.”  Id. ¶ 338.  GS Labs 
alleges that “studies have shown that increased availability of rapid COVID-19 testing, 
which is facilitated and made readily accessible by providers like GS Labs, dramatically 
improves patient health outcomes, reduces the spread of the virus, saves lives, and prevents 
and (consequently) reduces Blue Cross’[s] spend.”  Id.  GS Labs’ assertion that Blue 
Cross’s receipt of value was unjust seems derived entirely from its contention that § 3202 

of the CARES Act required Blue Cross to pay.  See id. ¶¶ 343, 348.        
    These allegations do not plausibly show that Blue Cross received something of 
value or, if it did, that the receipt was unjust.  A vendor’s provision of services to an insured 
ordinarily does not enrich the insured’s insurer.  The patient—not the insurer—receives the 
services’ benefits.  See Air Evac EMS Inc. v. USAble Mut. Ins. Co., No. 4:16-CV-00266 
BSM, 
2018 WL 2422314
, at *9 (E.D. Ark. May 29, 2018) (noting that “a number of courts 

have found that medical providers cannot bring unjust enrichment claims against insurers 
because patient-subscribers, and not insurers, are the ones receiving benefits from the 
provider’s services[]” and citing cases), aff’d, 
931 F.3d 647
 (8th Cir. 2019).  And for an 
insurer, claims are expenses, not something of value.  See Travelers Indem. Co. of Conn. 
v. Losco Grp., Inc., 
150 F. Supp. 2d 556, 563
 (S.D.N.Y. 2001) (“The insurance company 

derives no benefit from those services; indeed, what the insurer gets is a ripened obligation 
to pay money on the insured—which hardly can be called a benefit.”).  GS Labs’ second 
theory—that COVID testing prevented the contraction and wider spread of more and more 
serious illness, which in turn saved costs—doesn’t show that Blue Cross was enriched in 
the relevant sense.  According to this theory, those higher costs would have been incurred 

by  countless  individuals,  governmental  units,  health  insurers,  and  non-health-related 
businesses—really, just about everyone.  In other words, in GS Labs’ view, just about 
everyone benefitted from diagnostic testing for COVID.  The problem is that it is difficult 
to understand how a society-wide benefit may be the “something of value” to support an 
unjust-enrichment claim.  The Minnesota Supreme Court’s descriptions of the cause of 
action quoted above seem at least to assume the presence of a more specific benefit, like 

“the money of another” described in Brand, 
29 Minn. at 239
, 
13 N.W. at 42
.  And no 
authority has been cited or identified in our research that might support the idea that 
something as indeterminate as widespread cost reduction might plausibly support an 
unjust-enrichment claim.  Enrichment aside, GS Labs does not allege what made the 
absence of prepayment unjust.  It cannot be § 3202 of the CARES Act.  That would enable 
GS Labs to turn a private-right-of-actionless statute into a common-law claim, something 

Minnesota generally forbids.  See Palmer v. Ill. Farmers Ins. Co., 
666 F.3d 1081, 1087
 
(8th Cir. 2012).  Regardless, § 3202 says nothing about the prepayment of insurance 
benefits.                                                                 
                              VI                                         
    Turn next to GS Labs’ negligence per se claim in Count VI.  “Negligence per se is 

a form of ordinary negligence that results from violation of a statute.”  Anderson v. State, 
Dep’t of Nat. Res., 
693 N.W.2d 181, 189
 (Minn. 2005) (quoting Seim v. Garavalia, 
306 N.W.2d 806, 810
 (Minn. 1981)).  “The only difference [between negligence and negligence 
per se] is that the measure of legal duty for actual negligence is determined upon common-
law principles[,] while the measure of duty for negligence per se is fixed by the statute, so 

that its violation constitutes conclusive evidence of negligence.”  Kronzer v. First Nat’l 
Bank of Minneapolis, 
235 N.W.2d 187, 192
 (Minn. 1975).  Not all statutes or ordinances 
create a tort duty of care.  “‘[T]he negligence per se doctrine . . . is not a magic transforming 
formula that automatically creates a private right of action for the civil enforcement, in tort 
law, of every statute.’”  In re Medtronic, Inc. Sprint Fidelis Leads Prods. Liab. Litig., 
592 F. Supp. 2d 1147, 1163
 (D. Minn. 2009) (quoting Talley v. Danek Med., Inc., 
179 F.3d 154
, 158 (4th Cir. 1999)).  “In other words, the doctrine simply sets the standard of care 
‘where an underlying common law cause of action [already] exists.’”  Id. (quoting Elder v. 
Allstate Ins. Co., 
341 F. Supp. 2d 1095, 1100
 (D. Minn. 2004)).  And Minnesota “ha[s] 
long followed the criteria set forth by the American Law Institute in Restatement, Torts 2d, 
in determining which statutes give rise to a civil duty” such that a violation of the statute 
or ordinance will constitute negligence per se.  Kronzer, 
235 N.W.2d at 193
.  Section 286 

of the Second Restatement of Torts provides:                              
         The court may adopt as the standard of conduct of a reasonable  
         man  the  requirements  of  a  legislative  enactment  or  an   
         administrative  regulation  whose  purpose  is  found  to  be   
         exclusively or in part                                          

         (a) to protect a class of persons which includes the one whose  
           interest is invaded, and                                      

         (b) to protect the particular interest which is invaded, and    

         (c) to protect that interest against the kind of harm which has 
           resulted, and                                                 

         (d) to protect that interest against the particular hazard from 
           which the harm results.                                       

Restatement (Second) of Torts § 286 (Am. L. Inst. 1975).                  
    GS Labs’ negligence per se theory is that Blue Cross “has always owed” providers 
(including GS Labs) “a duty of care of that of an ordinary prudent insurer acting in similar 
circumstances during a public health emergency and viral pandemic.”  Am. Countercl. ¶ 
352.  It alleges that “[t]he CARES Act merely codified this duty owed by an ordinary 
prudent insurer into a statutory standard of care, specifically in the current COVID-19 
pandemic.”  Id. ¶ 354.  And GS Labs alleges that “[t]he CARES Act’s standard of care 

establishes that an ordinary prudent insurer in these circumstances would fully reimburse 
a provider at the publicly-posted cash rate for diagnostic testing in the event there is no 
separately-negotiated rate.”  Id. ¶ 355.                                  
    These allegations do not plausibly show negligence per se.  This is so for purely 
legal reasons.  No authority has been identified supporting the conclusion that a health 
insurer  “has  always  owed”  a  tort-law-created  duty  of  care  in  connection  with  its 

commercial claim reimbursement activities.  GS Labs cites no case creating or identifying 
this duty, whether during a public-health emergency or not.  The case on which it chiefly 
relies, Osborne v. McMasters, concerned a personal injury claim against a drugstore owner 
whose employee “sold to plaintiff’s intestate a deadly poison without labeling it ‘Poison,’ 
as required by statute.”  
41 N.W. 543
 (Minn. 1889).  We don’t have anything like that here.  

Regardless,  if  §  3202  may  be  described  as  addressing  reimbursement  for  COVID 
diagnostic  testing,  it  cannot  possibly  be  described  as  addressing  tort-like  or  extra-
reimbursement harm a provider might incur if it is not reimbursed.  In other words, the 
statute does not protect the particular interest or against the kind of harm that GS Labs 
seeks to vindicate through its negligence per se claim.                   

                              VII                                        
    GS Labs asserts a claim for tortious interference with prospective business relations 
in Count VII.  For this claim to survive a Rule 12(b)(6) motion, GS Labs must allege facts 
plausibly showing five elements:                                          
         (1) The existence of a reasonable expectation of economic       
         advantage; (2) Defendant’s knowledge of that expectation of     
         economic  advantage;  (3)  That  defendant  intentionally       
         interfered with plaintiff’s reasonable expectation of economic  
         advantage,  and  the  intentional  interference  is  either     
         independently tortious or in violation of a state or federal    
         statute or regulation; (4) That in the absence of the wrongful  
         act of defendant, it is reasonably probable that plaintiff would 
         have realized his economic advantage or benefit; and (5) That   
         plaintiff sustained damages.                                    

Gieseke ex rel. Diversified Water Diversion, Inc. v. IDCA, Inc., 
844 N.W.2d 210, 219
 
(Minn. 2014).  To show that an expectation of economic advantage is “reasonable,” a 
plaintiff must “specifically identify a third party with whom the plaintiff had a reasonable 
probability of a future economic relationship.”  
Id. at 221
; see also CH Bus Sales, Inc. v. 
Geiger, No. 18-cv-2444 (SRN/KMM), 
2019 WL 1282110
, at *12 (D. Minn. Mar. 20, 
2019) (dismissing a tortious-interference claim because the plaintiff did not “identify any 
specific customers or business relations it has lost, or may lose, due to [the defendants’] 
conduct”).                                                                
    In support of this claim, GS Labs alleges that it “had a valid and reasonable business 
expectancy and relationship with the ASO plans administered by Blue Cross.”  Am. 
Countercl. ¶ 363.  GS Labs alleges, albeit “[o]n information and belief,” that “Blue Cross 
intentionally interfered with the ASO plans’ reimbursement of claims” GS Labs submitted 
when it “caused the ASO plans to refuse to reimburse” these claims.  
Id.
 ¶¶ 367–68; see 
also 
id. ¶ 370
.  To support the element that the alleged interference be “independently 
tortious or in violation of a state or federal statute or regulation,” Gieseke, 
844 N.W.2d at 219
, GS Labs alleges only that “Blue Cross’[s] interference violated the CARES Act (or, 
alternatively, state law), as set forth herein.”  Id. ¶ 369.              

    These allegations are not sufficient.  GS Labs’ reliance on the CARES Act presents 
a problem with respect to the requirement that “the intentional interference [be] either 
independently tortious or in violation of a state or federal statute or regulation.”  Id.  I’ve 
concluded that § 3202 of that Act creates no private right of action, and in Minnesota, “the 
law is settled that a litigant cannot directly . . . use an alleged violation of [a] statute [lacking 
a private right of action] to prove elements of a common law claim.”  Schermer v. State 

Farm Fire & Cas. Co., 
702 N.W.2d 898, 905
 (Minn. Ct. App. 2005).  GS Labs does not 
identify the alternative state law to support this element.  Therefore, GS Labs has not 
plausibly alleged facts showing that Blue Cross’s alleged interference was tortious in the 
relevant sense.                                                           
                              VIII                                       

    GS Labs asserts a second breach-of-contract theory in Count VIII, this one based on 
an assignment of contract rights.  It alleges that Blue Cross “issue or facilitates” non-
ERISA health insurance plans.  Am. Countercl. ¶ 375.2  GS Labs alleges that, when 
individuals who are insured under these plans receive COVID diagnostic testing from GS 
Labs, “they assign to GS Labs any rights they have under their plans of insurance issued 

or facilitated by Blue Cross.”  Id. ¶ 378.  This assignment “entitles GS Labs to pursue [the 

2    ERISA does not apply to some employee benefit plans, including plans sponsored 
by certain organizations (e.g., governmental plans).  
29 U.S.C. § 1003
(b).  Such plans 
ordinarily are governed by state law.  See, e.g., Hampton v. Standard Ins. Co., 815 Fed. 
App’x 100 (8th Cir. 2020) (Mem.).                                         
insured’s] contractual claims against Blue Cross.”  
Id. ¶ 379
.  Central to this claim, GS 
Labs alleges: “These plans of insurance provide that Blue Cross will provide coverage for 

the full publicly-posted cash price of COVID-19 diagnostic testing because all plans of 
insurance were amended, by operation of law pursuant to FFCRA § 6001 and CARES Act 
§§ 3201–3202, to provide coverage for COVID-19 diagnostic testing.”  Id. ¶ 377. 
    At least as pleaded, this claim doesn’t get past legal problems.  Section 6001 of the 
FFCRA and §§ 3201 and 3202 of the CARES Act do not say their COVID-testing-coverage 
requirements “amend” or are incorporated by reference in non-ERISA health insurance 

policies or plans.  The coverage requirement appears in § 6001(a) of the FFCRA, but § 
6001(b) says that “subsection (a) shall be applied by the” Secretaries of Health and Human 
Services, Labor, and of the Treasury “as if [§6001(a) were] included” in federal statutes 
under the auspices of each agency.  
Pub. L. No. 116-127, §§
 6001(a), (b), 
134 Stat. 178
, 
201–202 (2020).  The statute says nothing about health insurance policies governed by 

state law.  And Minnesota law ordinarily forbids incorporating a statutory duty into an 
insurance policy when the statute creates no private right of action.  Nelson v. Am. Family 
Mut. Ins. Co., 
899 F.3d 475, 480
 (8th Cir. 2018) (citing Palmer, 
666 F.3d at 1086
; 
Burgmeier v. Farm Credit Bank of St. Paul, 
499 N.W.2d 43, 47
 (Minn. Ct. App. 1993)). 
    I’ll grant that the implausibility of this claim may seem somewhat unusual to any 

person familiar with the health-insurance claims process.  Insured patients, their providers, 
and their insurers ordinarily interact just as GS Labs alleges: the insured patient signs an 
assignment-of-benefits form that gives the provider the right to bill the insurer for benefits 
due under the patient’s policy.  If the insurer refuses to pay, the provider (often) sues the 
insurer for the benefits.  Depending on the nature of the plan, that suit will be governed by 
state law or ERISA.  To be clear, GS Labs’ assignment-based contract claim here is 

different.  The claim relies—not on the terms in each of its patient’s insurance contracts or 
plans—but  on  a  theory  that  a  contract  term  essential  to  GS  Labs’  claim  has  been 
incorporated into each patient’s insurance contract.  I think this theory is legally flawed 
(and therefore implausible) because (1) the federal statutes that are the claim’s source do 
not include incorporation language—that is, they do not say that the requirement to cover 
COVID-19 diagnostic testing is incorporated into contracts governed by state law, and (2) 

I’ve already determined that the relevant FFCRA and CARES Act provisions contain no 
private right of action, and Minnesota law doesn’t permit an incorporation theory to 
end-run this problem.                                                     
                              IX                                         
    In Count IX, GS Labs asserts a claim under ERISA’s civil enforcement provision, 

29 U.S.C. § 1132
.  Specifically, it asserts a claim under § 1132(a)(1), which authorizes “a 
participant or beneficiary” to bring a civil action “to recover benefits due to him under the 
terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to 
future benefits under the terms of the plan.”  
29 U.S.C. § 1132
(a)(1)(B).  And it asserts a 
claim under § 1132(a)(3), which authorizes “a participant, beneficiary, or fiduciary (A) to 

enjoin any act or practice which violates any provision of this subchapter or the terms of 
the plan, or (B) to obtain other appropriate equitable relief (i) to redress such violations or 
(ii) to enforce any provisions of this subchapter or the terms of the plan.”  
29 U.S.C. § 1132
(a)(3).                                                               
    GS Labs’ ERISA theories essentially track its assignment-based breach-of-contract 
claim.  It alleges that  “Blue Cross issues or facilitates” ERISA-governed health insurance 

plans.  Am. Countercl. ¶ 384.  It alleges that, when individuals who are insured under these 
plans receive COVID diagnostic testing from GS Labs, “they assign to GS Labs any rights 
they have under their plans of insurance issued or facilitated by Blue Cross.”  
Id. ¶ 387
.  
This assignment “entitles GS Labs to pursue [the insured’s] statutory claims, such as those 
under ERISA § 502, against Blue Cross.”  Id. ¶ 388.  Again, central to this claim, GS Labs 
alleges: “These plans of insurance provide that Blue Cross will provide coverage for the 

full  publicly-posted  cash  price  of  COVID-19  diagnostic  testing  because  all  plans  of 
insurance were amended, by operation of law pursuant to FFCRA § 6001 and CARES Act 
§§ 3201–3202, to provide coverage for COVID-19 diagnostic testing.”  Id. ¶ 386.  GS Labs 
seeks “benefits due” under § 1132(a)(1)(B), and to “to enjoin Blue Cross’[s] act and 
practice of failing to fully reimburse for COVID-19 diagnostic testing” under § 1132(a)(3).  

Id. ¶¶ 390–91.                                                            
    The starting point is determining whether the law might permit a provider like GS 
Labs to assert these claims.  The primary issue is whether § 3202(a)’s requirement that, 
absent a negotiated rate, Blue Cross “shall reimburse” GS Labs at its website-listed cash 
price is enforceable under ERISA’s civil enforcement provision.  Based on a review of the 

relevant, intertwined statutes, I conclude it is.  But this conclusion is neither obvious nor 
inarguable.                                                               
    Begin with § 6001(a) of the FFCRA.  It requires group health plans and health 
insurance issuers to provide coverage for COVID-19 diagnostic testing without imposing 
“any cost sharing (including deductibles, copayments, and coinsurance) requirements or 
prior authorization or other medical management requirements.”  
Pub. L. No. 116-127, § 6001
(a), 
134 Stat. 178
, 201–202 (2020).  Section 6001(a), in other words, imposes a 
coverage requirement; it says Blue Cross had to cover COVID-19 diagnostic services 
without cost-sharing by plan participants.  Section 6001(b) of the FFCRA says, in turn, that 
this  coverage-without-cost-sharing  requirement  “shall  be  applied”  by  the  responsible 
agency heads “as if included” in various federal laws, including by the Secretary of Labor 
as if included in “part 7” of ERISA.   
Id.
 § 6001(b).  If § 6001(a)’s coverage requirement 

is deemed included in part 7 of ERISA as § 6001(b) seems to direct, then there is no 
question a plan or insurer’s failure to comply with this coverage-without-cost-sharing 
requirement is subject to challenge under ERISA’s civil enforcement provision.  Section 
1132(a)(3) allows “a participant, beneficiary, or fiduciary” to bring a civil action “to 
enjoin” or “to obtain other appropriate equitable relief” with respect to violations “of “this 

subchapter.”  
29 U.S.C. § 1132
(a)(3).  ERISA’s civil enforcement provision appears in part 
5 of subchapter I; part 7 and its requirements for group health plans also appears in 
subchapter I.  See 29 U.S.C.A. §§ 1161–1500 (vol.) at 3–5 (table of contents). 
    GS Labs’ ERISA claims in Count IX go beyond seeking just coverage for its 
services; it also seeks payment at the cash price it listed on its website.  GS Labs seeks 

enforcement of the “shall reimburse” requirement in § 3202(a) of the CARES Act: “If the 
health plan or issuer does not have a negotiated rate with such provider, such plan or issuer 
shall reimburse the provider in an amount that equals the cash price for such service as 
listed by the provider on a public internet website.”  
Pub. L. No. 116-136, § 3202
(a)(1), 
134 Stat. 281
, 367 (2020).  For essentially two reasons, I conclude that § 3202(a)’s cash-
price reimbursement requirement may be enforced through ERISA’s civil enforcement 

provision.  The first is textual.  I understand § 3202(a)’s cross-reference to § 6001(a) of the 
FFCRA to incorporate that statute’s directive that its provisions be applied “as if included” 
in part 7 of ERISA.  As explained in the preceding paragraph, the inclusion of § 3202(a)’s 
reimbursement requirement in part 7 of ERISA means the requirement could be the subject 
of an action under 
29 U.S.C. § 1132
(a).  The second reason is practical.  It is difficult to 
understand how § 6001(a)’s requirement that coverage be provided without “any cost 

sharing . . . requirements” could be enforced by a plan participant without considering, and 
likely litigating, the price a health plan or health insurance issuer pays for the diagnostic 
testing.3  It helps that these conclusions are consistent with the result reached by the only 
other court to have considered this particular issue, though that court approached the 
question somewhat differently.  See Open MRI and Imaging of RP Vestibular Diagnostics, 

P.A. v. Cigna Health and Life Ins. Co., Civ. No. 20-10345 (KM) (ESK), 
2022 WL 1567797
, 
at *3–6 (D.N.J. May 18, 2022).                                            



3    Consider a hypothetical: Patient A participates in a Blue Cross-insured ERISA plan.  
Patient A experiences typical COVID symptoms and decides to get tested.  Patient A goes 
to a GS Labs facility for the test.  Rather than assign her benefits to GS Labs, Patient A 
pays cash and then submits the receipt to Blue Cross for coverage.  Blue Cross pays Patient 
A only a portion of what Patient A paid GS Labs, claiming that GS Labs’ charge did not 
equal the cash price for such service as listed by GS Labs on a public internet website.  In 
that  situation,  whether  Blue  Cross  imposed  a  cost-sharing  requirement  would  seem 
inextricably intertwined with the reimbursement/cash-price question.      
    Having determined that the law might permit a provider like GS Labs to assert these 
claims, the next question is whether GS Labs has alleged facts plausibly showing its 

entitlement to the relief it seeks.  Recall that GS Labs alleges that, when it provides testing 
services to ERISA plan participants insured by Blue Cross, the participants “assign to GS 
Labs any rights they have under their plans of insurance issued or facilitated by Blue Cross, 
including any rights these patients have under ERISA.”  Am. Countercl. ¶ 387.  Blue Cross 
argues that, even if legally permissible, GS Labs’ ERISA claims in Count IX are factually 
implausible for three reasons.                                            

    First, Blue Cross argues that its plans uniformly include anti-assignment provisions 
that render GS Labs’ alleged assignments ineffective, and Blue Cross has filed with its 
motion one page from one of its plans that includes “anti-assignment language that is 
standard across [Blue Cross’s] fully insured plans.”  ECF No. 38 ¶ 5; ECF No. 38-4.  This 
argument is not persuasive in this procedural context.  Though no case has been cited 

addressing  this  specific  question,  whether,  and  the  extent  to  which,  anti-assignment 
provisions  might  render  GS  Labs’  alleged  assignments  ineffective  seems  like  an 
affirmative defense that Blue Cross bears the burden to plead and prove.  Defense, Black’s 
Law Dictionary (11th ed. 2019).  For an affirmative defense to justify a Rule 12(b)(6) 
dismissal of a complaint, “the applicability of the defense has to be clearly indicated and 

must appear on the face of the pleading to be used as the basis for the motion.”  5B Charles 
Alan Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure: Civil 
§  1357  (3d  ed.  &  Apr.  2022  Update)  (footnotes  omitted).    GS  Labs’  Amended 
Counterclaim  does  not  include  allegations  establishing  either  the  presence  of  anti-
assignment provisions in the at-issue plans and policies or a showing that those anti-
assignment provisions bar its claims under ERISA’s civil enforcement provision.4 

    Second,  Blue  Cross  argues  that  GS  Labs  failed  to  exhaust  its  administrative 
remedies before bringing suit.  An ERISA plaintiff must exhaust available administrative 
remedies.  Angevine v. Anheuser-Busch Cos. Pension Plan, 
646 F.3d 1034, 1037
 (8th Cir. 
2011).  The exhaustion requirement is excused “only when pursuing an administrative 
remedy would be futile or there is no administrative remedy to pursue.”  
Id.
  The exhaustion 

requirement is not an affirmative defense.  As the Eighth Circuit has explained: “Our case 
law is clear that [an ERISA plaintiff’s] claim can proceed only if he has pled sufficient 
facts to show either futility or lack of administrative remedy.”  
Id. at 1038
; see also J.P. v. 
BCBSM, Inc., No. 18-cv-3472 (MJD/DTS), 
2020 WL 7626655
, at *3 (D. Minn. Feb. 24, 
2020) (recognizing in an ERISA benefits claim that “although Plaintiffs bear no burden of 

production on a motion to dismiss, this Court must still consider whether the Amended 
Complaint—and any documents embraced by it—shows either exhaustion or an exception 

4    To support its anti-assignment argument, Blue Cross filed “a true and correct 
excerpt of a [Blue Cross] fully insured plan . . . setting forth anti-assignment language that 
is standard across [Blue Cross’s] fully insured plans.”  ECF No. 38 ¶ 5; ECF No. 38-4.  In 
a more typical ERISA benefits dispute, it would be appropriate to consider the entire 
at-issue  plan’s  terms,  including  any  anti-assignment  provision,  because  such  terms 
ordinarily are embraced by the pleadings.  See, e.g., Karg v. Transamerica Corp., No. 
18-CV-134-CJW-KEM, 
2019 WL 3938471
, at *1 n.1 (N.D. Iowa Aug. 20, 2019) (“An 
ERISA plan document is necessarily embraced by the pleadings when the complaint 
specifically mentions the plan under which a plaintiff’s ERISA claims arose.”).  This isn’t 
that  kind  of  case.    GS  Labs  does  not  identify  the  at-issue  plans  in  its  Amended 
Counterclaim, and its allegations imply there are many at-issue plans.  And accepting Blue 
Cross’s argument requires, in turn, accepting its factual assertion that the exemplary 
anti-assignment provision it filed (or an equivalent term) is in every at-issue plan.  Going 
that route would not be faithful to Rule 12(b)(6).                        
thereto”), report and recommendation adopted, 
2020 WL 1442683
 (D. Minn. Mar. 24, 
2020).   “The futility exception is narrow—the plan participant must show that it is certain 

that her claim will be denied on appeal, not merely that she doubts that an appeal will result 
in a different decision.”  Brown v. J.B. Hunt Transp. Servs., Inc., 
586 F.3d 1079, 1085
 (8th 
Cir.  2009)  (cleaned  up).    GS  Labs  plausibly  alleges  exhaustion  would  be  futile.  
Specifically, it alleges that Blue Cross’s pre-litigation position, “its refusals to reimburse 
GS Labs in response to GS Labs’ repeated requests for reimbursement, and its pleadings 
and claims in this action,” show that “it is certain that Blue Cross would refuse to fully 

reimburse GS Labs if GS Labs pursued the administrative remedies set out in the plans.”  
Am. Countercl. ¶ 70.  This allegation may be short and plain, see Fed. R. Civ. P. 8(a)(2), 
but is neither speculative nor conclusory.  It relies on Blue Cross’s well-documented view 
of GS Labs’ services and Blue Cross’s allegations and claims in this case to show that, if 
GS Labs had filed administrative claims, they would certainly have been denied.  That 

inference is plausible.                                                   
    Third, Blue Cross argues that GS Labs lacks statutory standing to assert a claim for 
equitable relief under 
29 U.S.C. § 1132
(a)(3).  The gist of Blue Cross’s position is that the 
assignments GS Labs alleges it received from individuals who participated in plans insured 
or administered by Blue Cross gave GS Labs at most the right to sue for benefits.  “[T]o 

have the right to seek equitable relief under ERISA, a party must either be a participant, 
beneficiary, or fiduciary, or the assignee of a participant, beneficiary, or fiduciary.”  Air 
Evac EMS, Inc. v. USAble Mut. Ins. Co., 
931 F.3d 647, 650
 (8th Cir. 2019).  In Air Evac 
EMS, the Eighth Circuit determined that an assignment obtained by the provider (Air Evac 
EMS) did not include ERISA claims for equitable relief, and the court’s analysis of the 
issue is worth repeating here:                                            

         More important than general statements as to liberal or narrow  
         constructions, however, is the fact that our job is to interpret 
         the express language of the assignment in the context in which  
         it was made.  When Arkansas Blue plan members assigned          
         their rights to Air Evac, they did so in the context of facilitating 
         payment for Air Evac’s past provision of services.  Thus, when  
         Arkansas  Blue  plan  members  assigned  “all  rights  to  (and 
         related or associated with) any benefit claims” to Air Evac, its 
         [sic] seems clear, at a minimum, that they assigned Air Evac    
         the right to recover benefits under § 1132(a)(1)(B).  Given the 
         context of the assignment, however, it does not automatically   
         follow that such language also conveyed the right to sue for    
         reformation of plan terms and other equitable relief under §    
         1132(a)(3).    Indeed,  the  assignment  does  not  specifically 
         mention the right to sue for equitable relief; rather it limits the 
         rights conveyed to those “related or associated with . . . benefit 
         claims and/or payments due  from  any  third-party  payor.”     
         (Emphasis added).  Moreover, the rights that are specifically   
         mentioned—“the  rights  to  pursue administrative  claims,      
         request documents, receive payment and pursue litigation in     
         order to obtain payment” (emphasis added)—all suggest that      
         Air  Evac  sought  assignment  of  ERISA  rights  related  to   
         obtaining  payment,  not  equitable  relief.    Accordingly,  we 
         conclude that Air Evac’s assignment does not convey the right   
         to sue for equitable relief under § 1132(a)(3).                 

Id. at 651.  The assignments GS Labs alleges it obtained do not mention the right to sue for 
equitable relief and seem a lot narrower than the assignment at issue in Air Evac EMS.  GS 
Labs alleges: “Patients in Minnesota assign their rights under their respective plans of 
insurance (including those issued by Blue Cross) to GS Labs by agreeing to the following 
terms in scheduling an appointment with GS Labs: ‘I assign to GS Labs all rights and 
claims for the medical benefits to which I am entitled for the services provided.’”  Am. 
Countercl. ¶ 67 (emphasis added).  Under Air Evac EMS, this assignment does not convey 
to GS Labs the right to sue for equitable relief under § 1132(a)(3).      

                               X                                         
    GS Labs asserts a false-advertising claim under the Lanham Act, 
15 U.S.C. § 1125
(a).  Under the Lanham Act:                                           
         Any person who, . . . in connection with any goods or services, 
         . . . uses in commerce any . . . false or misleading description 
         of fact, or false or misleading representation of fact, which . . . 
         in  commercial  advertising  or  promotion,  misrepresents  the 
         nature, characteristics, [or] qualities . . . of his or her . . . goods, 
         services, or commercial activities . . . shall be liable in a civil 
         action by any person who believes that he or she is likely to be 
         damaged by such act.                                            

15 U.S.C. § 1125
(a)(1)(B).  The Act’s purpose is “to protect persons engaged in commerce 
against false advertising and unfair competition.”  Am. Italian Pasta Co. v. New World 
Pasta Co., 
371 F.3d 387, 390
 (8th Cir. 2004) (quoting United Indus. Corp. v. Clorox Co., 
140 F.3d 1175, 1179
 (8th Cir. 1998)).                                     
    The Eighth Circuit has distilled this statutory text into five elements that a plaintiff 
must prove to establish a false-advertising claim:                        
         (1) a false statement of fact by the defendant in a commercial  
         advertisement  about  its  own  or  another’s  product;  (2)  the 
         statement actually deceived or has the tendency to deceive a    
         substantial  segment  of  its  audience;  (3)  the  deception  is 
         material, in that it is likely to influence the purchasing decision; 
         (4) the defendant caused its false statement to enter interstate 
         commerce; and (5) the plaintiff has been or is likely to be     
         injured  as  a  result  of  the  false  statement,  either  by  direct 
         diversion of sales from itself to defendant or by a loss of     
         goodwill associated with its products.                          
United Indus. Corp., 
140 F.3d at 1180
.  A plaintiff’s failure to demonstrate any one of the 
five elements is fatal to its claim.  Allsup, Inc. v. Advantage 2000 Consultants Inc., 
428 F.3d 1135, 1138
 (8th Cir. 2005).                                               
    GS  Labs  alleges  that  Blue  Cross  made  essentially  five  false  or  misleading 
statements.  First, it alleges that “Blue Cross falsely stated that only ‘medically necessary’ 
and ‘appropriate’ COVID-19 diagnostic testing is covered by insurance.”  Am. Countercl. 
¶ 94.  Second, GS Labs alleges that “Blue Cross has falsely stated or implied that there may 
be coverage differences with respect to COVID-19 diagnostic testing provided by ‘in-

network’  or  ‘participating’  providers  versus  ‘out-of-network’  or  ‘non-participating’ 
providers.”  Id. ¶ 97.  Third, GS Labs alleges that “Blue Cross has falsely stated that patients 
may have to share the cost of COVID-19 diagnostic testing, in proximity to statements 
about medical necessity.”  Id. ¶ 100.  Fourth, it alleges that “Blue Cross has falsely implied 
that it may impose prior authorization requirements on coverage for COVID-19 diagnostic 

testing.”  Id. ¶ 103.  Fifth, GS Labs alleges that “Blue Cross omitted information [from] its 
public statements that created the false impression that COVID-19 diagnostic testing 
provided by out-of-network or non-participating providers is not covered.”  Id. ¶ 106. 
    GS Labs says that statements falling in each of these categories are false for 
essentially the same reason: they contradict § 6001(a) of the FFCRA and §§ 3201 and 3202 

of the CARES Act to the extent those statutes require a health insurance issuer to cover 
COVID-19 diagnostic testing without cost-sharing or prior authorization or other medical 
management requirements and regardless of whether the provider is out-of-network.  See 
id. ¶¶ 96, 102, 105, 108.  GS Labs alleges that consumers have relied on these statements 
and  “have  either  avoided  testing  altogether  or  chosen  to  obtain  testing  from  certain 
providers over others, such as those that are ‘in-network’ or ‘participating,’[] to the 

exclusion of GS Labs.”  Id. ¶ 109.  The resulting consumer decisions, GS Labs alleges, 
“have harmed patient choice, risked the public health, and resulted in reduced diagnostic 
testing at GS Labs.”  Id. ¶ 110.                                          
    The parties’ first disagreement concerns whether the Amended Counterclaim’s 
false-advertising allegations comply with Federal Rule of Civil Procedure 9(b).  Blue Cross 
says it does not.  GS Labs says it does.  Assuming Rule 9(b) applies, I conclude the 

Amended Counterclaim satisfies it.5  “In alleging fraud or mistake, a party must state with 
particularity the circumstances constituting fraud or mistake.”  Fed. R. Civ. P. 9(b).  “To 
satisfy the particularity requirement of Rule 9(b), the complaint must plead such facts as 
the time, place, and content of the defendant’s false representations, as well as the details 
of the defendant’s fraudulent acts, including when the acts occurred, who engaged in them, 

and what was obtained as a result.”  U.S. ex rel. Joshi v. St. Luke’s Hosp., Inc., 
441 F.3d 552, 556
 (8th Cir. 2006); see Streambend Props. II, LLC v. Ivy Tower Minneapolis, LLC, 
781 F.3d 1003, 1013
 (8th Cir. 2015) (same).  “The claim must identify who, what, where, 
when, and how.”  U.S. ex rel. Costner v. United States, 
317 F.3d 883, 888
 (8th Cir. 2003). 


5    “Courts are divided on the issue of whether Rule 9(b) applies to Lanham Act claims 
that are grounded in fraud.”  N. Bottling Co., Inc. v. Henry’s Foods, Inc., 
474 F. Supp. 3d 1016
, 1028 (D.N.D. 2020) (citing  Nestle Purina PetCare Co. v. Blue Buffalo Co., No. 4:14 
CV 859 RWS, 
2015 WL 1782661
, at *8 (E.D. Mo. Apr. 20, 2015)); see also Wing Enters., 
Inc. v. Tricam Indus., Inc., No. 20-cv-2497 (SRN/ECW), 
2021 WL 3620272
, at *13 (D. 
Minn. Aug. 16, 2021) (citing numerous District of Minnesota cases applying Rule 9(b) to 
Lanham Act and state-law false-advertising claims).                       
While Rule 9(b) requires particularity in pleading, “a complaint need not be filled with 
precise detail.”  Moua v. Jani-King of Minn., Inc., 
613 F. Supp. 2d 1103, 1110
 (D. Minn. 

2009).  Rather, “Rule 9(b) is to be read in the context of the general principles of the Federal 
Rules, the purpose of which is to simplify pleading.  Thus, the particularity required by 
Rule 9(b) is intended to enable the defendant to respond specifically and quickly to the 
potentially damaging allegations.”  Costner, 
317 F.3d at 888
.  “The level of particularity 
required depends on the nature of a case,” E-Shops Corp. v. U.S. Bank Nat’l Ass’n, 
678 F.3d 659, 663
 (8th Cir. 2012), and to determine whether a party has satisfied Rule 9(b), 

courts  look  to  “the  complexity  or  simplicity  of  the  transaction  or  occurrence,  the 
relationship of the parties and the determination of how much circumstantial detail is 
necessary to give notice to the adverse party and enable him to prepare a responsive 
pleading,” Payne v. United States, 
247 F.2d 481, 486
 (8th Cir. 1957) (citation omitted). 
    The  Amended  Counterclaim’s  Lanham  Act  allegations  meet  Rule  9(b)’s 

particularity requirement.  These allegations quote numerous statements allegedly made by 
Blue Cross, easily satisfying the “who” and “what” elements.  The Amended Counterclaim 
is less specific about when, where, and how Blue Cross allegedly made these statements.  
As to when, the pleading provides a series of “no later than” dates.  For example, it alleges 
that “some” statements falling in the first category were made “no later than March 2020.”  

Am. Countercl. ¶ 95.  As to where and how, the pleading provides only examples: “written 
materials such as [Blue Cross’s] website, circulars, and brochures.”  Id. ¶ 92.  The gaps 
these allegations leave might be a problem in another case.  Here, they seem easily fillable 
considering that the statements on which the claim relies are quoted at length.  As a 
practical matter, that should make it feasible for Blue Cross to undertake a relatively 
straightforward, non-burdensome search and fill these gaps.  In other words, in the unique 

circumstances of this case, the Amended Counterclaim’s Lanham Act allegations give Blue 
Cross the notice Rule 9(b) requires.                                      
    Blue Cross next challenges whether the statements GS Labs identifies to support its 
Lanham Act claim are “in a commercial advertisement.”  United Indus. Corp., 
140 F.3d at 1180
.    The  widely  applied  test  for  determining  whether  a  statement  is  commercial 
advertising under the Lanham Act is as follows:                           

         In  order  for  representations  to  constitute  “commercial    
         advertising  or  promotion”  under  Section  43(a)(1)(B),  they 
         must be: (1) commercial speech; (2) by a defendant who is in    
         commercial competition with plaintiff; (3) for the purpose of   
         influencing consumers to buy defendant’s goods or services.     
         While  the  representations  need  not  be  made  in  a  “classic 
         advertising  campaign,”  but  may  consist  instead  of  more   
         informal types of “promotion,” the representations (4) must be  
         disseminated sufficiently to the relevant purchasing public to  
         constitute “advertising” or “promotion” within that industry.   

Gordon & Breach Sci. Publishers S.A. v. Am. Inst. of Physics, 
859 F. Supp. 1521
, 1535–
36 (S.D.N.Y. 1994).6  Other judges in this District have applied the Gordon & Breach test, 
or at least parts of it, often.  See, e.g., Am. Achievement Corp. v. Jostens, Inc., --- F. Supp. 
3d ---, No. 21-cv-2613 (NEB/BRT), 
2022 WL 3566862
, at *13 (D. Minn. Aug. 18, 2022); 
Select Comfort Corp. v. Tempur Sealy Int’l, Inc., 
988 F. Supp. 2d 1047
, 1052–53 (D. Minn. 

6    In Fashion Boutique of Short Hills, Inc. v. Fendi USA, Inc., the Second Circuit 
adopted the first, third, and fourth elements of the Gordon & Breach test.  
314 F.3d 48, 58
 
(2d Cir. 2002).  It did not address the second element, but “note[d] that the requirement 
[that defendant and plaintiff be competitors] is not set forth in the text of Section 43(a).”  
Id.                                                                       
2013); Auto-Chlor Sys. of Minn., Inc. v. JohnsonDiversey, 
328 F. Supp. 2d 980, 1018
 (D. 
Minn.  2004);  Aviation  Charter,  Inc.  v.  Aviation  Rsch.  Grp./US,  No.  03-cv-2439 

(PAM/RLE), 
2004 WL 1638176
, at *5 (D. Minn. July 10, 2004), aff'd sub nom. Aviation 
Charter, Inc. v. Aviation Rsch. Grp./US, 
416 F.3d 864
 (8th Cir. 2005); Grp. Health Plan, 
Inc. v. Philip Morris, Inc., 
68 F. Supp. 2d 1064
, 1069–70 (D. Minn. 1999); and Med. 
Graphics Corp. v. SensorMedics Corp., 
872 F. Supp. 643, 650
 (D. Minn. 1994).  Though 
the Eighth Circuit has neither formally adopted nor explicitly applied the Gordon & Breach 
test in full, it applied the test’s fourth element in Porous Media Corp. v. Pall Corp., 
173 F.3d 1109, 1121
 (8th Cir. 1999), citing as support a Fifth Circuit case, Seven–Up Co. v. 
Coca–Cola Co., that applied all four of the test’s factors and declared the test “to be both 
accurate and sound.”  
86 F.3d 1379, 1384
 (5th Cir. 1996).  The bottom line is that it makes 
good sense to apply the Gordon & Breach test here.                        
    The Amended Counterclaim lacks allegations plausibly meeting this test—or, in 

other words, showing that the at-issue statements were in a commercial advertisement.  No 
allegations address whether Blue Cross is in competition with GS Labs.  It would seem 
strange to say they are.  Blue Cross, as the Amended Counterclaim describes it, is a health 
insurer and administrator of self-funded health insurance plans.  No allegation suggests 
that GS Labs competes in that market.  GS Labs is a clinical lab.  No allegation suggests 

that Blue Cross competes in that market.  The Amended Counterclaim also includes no 
allegation suggesting that the many Blue Cross statements it quotes were made for the 
purpose of influencing customers to purchase Blue Cross’s insurance products or services.  
The absence of such allegations is a problem by itself, but there is more.  A careful review 
of the statements and GS Labs’ related allegations permits at most the plausible inference 
that the statements were intended to inform Blue Cross customers and providers of the 

extent of existing COVID-19 diagnostic testing coverage under health insurance policies 
and plans  issued  or administered  by  Blue  Cross.    Consider,  for  example,  GS  Labs’ 
allegation that “consumers and referring physicians rely upon Blue Cross as a source for 
truthful information about healthcare coverage under both Blue Cross plans of insurance 
and the law generally.”  Am. Countercl. ¶ 93.  This allegation plausibly describes how the 
at-issue statements served informational purposes; it does not plausibly allege that the 

statements were made for the purpose of influencing consumers to buy Blue Cross’s 
insurance  or  services.    Finally,  the  Amended  Counterclaim  includes  no  allegations 
plausibly showing whether the statements, or any of them, were disseminated sufficiently 
to the relevant purchasing public.  It is true that some statements—like those alleged to 
have been available via Blue Cross’s website—may have been widely available.  But 

without knowing more, that inference cannot plausibly be made with respect to many of 
the other at-issue statements.  Regardless, GS Labs alleges no facts concerning the identity 
or  scope  of  the  relevant  purchasing  public.    Because  the  Amended  Counterclaim’s 
allegations do not plausibly show that the identified statements were in a commercial 
advertisement, GS Labs’ Lanham Act claim must be dismissed.               

                              XI                                         
    In  Count  XI,  GS  Labs  asserts  a  claim  under  the  Minnesota  Deceptive  Trade 
Practices Act, Minn. Stat. § 325D.44.  It is settled that the Deceptive Trade Practices Act 
“mirrors” the Lanham Act, and courts therefore “use the same analysis to evaluate false 
advertising claims that are made simultaneously under the federal and state statutes.”  Med. 
Graphics, 
872 F. Supp. at 649
; accord Aviva Sports, Inc. v. Fingerhut Direct Mktg., Inc., 

829 F. Supp. 2d 802
, 809 n.7 (D. Minn. 2011); see Buetow v. A.L.S. Enters., Inc., 
650 F.3d 1178, 1183
 (8th Cir. 2011) (recognizing that “[w]hen a commercial plaintiff asserted 
pendent state law claims under these Minnesota statutes in a Lanham Act” case, the state 
claims “are coextensive with the federal claims.” (quotation omitted)).  There is no question 
here that GS Labs’ Lanham Act and Deceptive Trade Practices Act claims are identical—
or, “simultaneous” to borrow from Med. Graphics Corp.  GS Labs does not quarrel with 

the idea that, as its Lanham Act claim goes, so goes its claim under the Deceptive Trade 
Practices Act.  This claim will therefore be dismissed.                   
                               XII                                       
    In Count XII, GS Labs asserts the same false advertising allegations that supported 
its Lanham Act claim to advance a claim under the Minnesota Consumer Fraud Act, Minn. 

Stat. § 325F.69, subdiv. 1.  See Am. Countercl. ¶¶ 409–413.  As with Count XI, Blue Cross 
says this claim shares the analysis—and falls—with GS Labs’ Lanham Act claim.  See 
Buetow, 
650 F.3d at 1183
; Alternative Pioneering Sys., Inc. v. Direct Innovative Prods., 
Inc., 
822 F. Supp. 1437, 1441
 (D. Minn. 1993).  And as with Count XI, GS Labs does not 
dispute the point.  Count XII will therefore also be dismissed based on the analysis of Count 

X.                                                                        
                              XIII                                       
    GS Labs asserts a series of antitrust claims, beginning with Count XIII.  In this 
Count, it alleges a per se violation of § 1 of the Sherman Act.  Am. Countercl. at 167 (Count 
XIII heading).  Section 1 of the Sherman Act prohibits “[e]very contract, combination in 
the form of trust or otherwise, or conspiracy, in restraint of trade.”  
15 U.S.C. § 1
.  

“Twombly, which also involved a claim under § 1 of the Sherman Act, makes clear that a 
conclusory allegation of conspiracy does not suffice.”  Uhr v. Responsible Hospitality Inst., 
Inc., No. 10-cv-4945 (PJS/TNL), 
2011 WL 4091866
, at *7 (D. Minn. Sept. 14, 2011).  
“[S]tating such a claim requires a complaint with enough factual matter (taken as true) to 
suggest that an agreement was made.”  Twombly, 
550 U.S. at 556
.  “[I]ndependent 
allegation[s] of actual agreement”—in other words, allegations of direct evidence of an 

agreement—suffice  provided  they  are  factually  plausible  and  not  “merely  legal 
conclusions.”  
Id. at 564
.  “[A]n allegation of parallel conduct and a bare assertion of 
conspiracy will not suffice.”  
Id. at 556
.  “[W]hen allegations of parallel conduct are set 
out in order to make a § 1 claim, they must be placed in a context that raises a suggestion 
of  a  preceding  agreement,  not  merely  parallel  conduct  that  could  just  as  well  be 

independent action.”  Id. at 557.  In particular, a § 1 plaintiff who relies on allegations of 
parallel conduct must allege that “certain ‘plus factors’ exist.”  Blomkest Fertilizer, Inc. v. 
Potash Corp. of Sask., Inc., 
203 F.3d 1028
, 1033 (8th Cir. 2000) (en banc).  Examples of 
plus factors “may include: a common motive to conspire, evidence that shows that the 
parallel acts were against the apparent individual economic self-interest of the alleged 

conspirators, and evidence of a high level of interfirm communications.”  Alaska Dep’t of 
Revenue, Treasury Div. v. Manku, No. 20-1759-cv, 
2021 WL 3027170
, at *3 (2d Cir. July 
19, 2021) (citation and quotations omitted).  Conspiracy allegations are implausible when 
there exists an “obvious alternative explanation” for the defendant’s conduct that the 
complaint does not plausibly undermine.  Twombly, 
550 U.S. at 567
; see also McDonough 
v. Anoka Cnty., 
799 F.3d 931, 946
 (8th Cir. 2015).  Conspiracy allegations also do not pass 

Rule 12(b)(6) when they suggest competition at least as plausibly as a conspiracy.  In re 
Elevator Antitrust Litig., 
502 F.3d 47, 51
 (2d Cir. 2007).                
    Begin with a summary of GS Labs’ § 1 theory: GS Labs alleges that Blue Cross 
conspired with other, unnamed BCBS affiliates to “carry[] out a buyer’s cartel to boycott 
GS Labs, depress reimbursement rates, and compromise its viability as a competitor[,]” 
presumably vis-à-vis other clinical labs.  Am. Countercl. ¶ 116.  GS Labs alleges that Blue 

Cross’s concerted activity “artificially depress[es] prices to non-competitive levels in a 
commercial  insurance  market  for  lab-based  COVID-19  testing  services  and  causing 
shortages in the COVID-19 diagnostic testing market.”  Id. ¶ 118.  GS Labs alleges that 
Blue Cross “has a strong incentive to coordinate with other [unnamed] dominant affiliated 
BCBS insurers in their rate negotiations and buying strategies for COVID-19 diagnostic 

testing  services,  and  to  do  so  in  a  manner  that  depresses  output  and  eliminates 
competition.”  Id. ¶ 173.  It alleges that Blue Cross has opportunities to conspire with other 
BCBS affiliates through a national trade association, American Health Insurance Plans (or 
“AHIP”), and through existing commercial relationships with other BCBS affiliates.  See 
id. ¶¶ 172–198.  In particular, it alleges that AHIP’s publication of articles showing price 

gouging  among  COVID-19  diagnostic  testing  businesses  “was  a  call  to  arms  for 
commercial insurers: a signal to collectively go on the offensive against COVID-19 
diagnostic testing providers such as GS Labs in their negotiations over rates and other 
business dealings.”  Id. ¶ 196.  GS Labs alleges five “plus factors” to support its allegations 
of parallel conduct: (1) “Blue Cross and its BCBS affiliates all boycotted GS Labs by 
refusing to pay it around the same time, consistent with AHIP’s signal.”  Id. ¶ 199.  (2) 

“Blue Cross and BCBS affiliates adopted the very same language and positions as one 
another in their dealings with GS Labs, accusing it of ‘price gouging’ and proposing 
payment at levels below GS Labs’ operating costs.”  Id. ¶ 200.  (3) “Blue Cross and 
numerous BCBS affiliates all offered identical pretexts for their refusal to pay, at similar 
times, following similarly timed and virtually identical requests for irrelevant medical 
documentation.”  Id. ¶ 201.  (4) “Blue Cross and numerous BCBS affiliates issued similar 

false, public, and derogatory statements about GS Labs, including that patients will be 
liable for higher out-of-pocket costs for seeking care from GS Labs rather than other 
COVID-19 testing providers.”  Id. ¶ 202.  As support for this allegation, GS Labs compares 
a statement Blue Cross made in connection with the filing of this case with a statement 
made by a separate BCBS affiliate in connection with a similar lawsuit filed against GS 

Labs in another court in July 2021.  Id. ¶ 202 n.69.  (5) “[F]rom as early as December of 
2020 and continuing into 2021, certain BCBS affiliates submitted complaints to, or were 
in close contact with, government regulators and enforcers concerning the affiliates’ 
allegations of ‘price gouging’ and ‘medically unnecessary’ testing by GS Labs.”  Id. ¶ 203. 
    These  allegations  do  not  plausibly  show  a  §  1  conspiracy  that  unreasonably 

restrained trade.  GS Labs doesn’t identify with whom Blue Cross conspired.  It alleges 
generally  that  Blue  Cross  acted  in  parallel  with  “other  BCBS  affiliates”—a  phrase 
appearing  throughout  the  Amended  Counterclaim—but  this  allegation  identifies  no 
particular organization or organizations.  GS Labs cites cases it says hold that it is not 
necessary for a § 1 plaintiff to identify all conspirators.  Mem. in Opp’n [ECF No. 47] at 
49 n.11.  The problem here isn’t that GS Labs has failed to identify all of Blue Cross’s 

alleged co-conspirators.  It hasn’t identified any.  It has at most alleged a group that includes 
potentially  dozens  of  co-conspirators  without  identifying  any  one  of  them  as  a  co-
conspirator.  In this claim’s context, that’s the functional equivalent of identifying none.  
See Twombly, 
550 U.S. at 565
 n.10 (confirming that a § 1 complaint alleging “no specific 
time, place, or person involved in the alleged conspiracies” does not give the notice Rule 
8 requires); Insulate SB, Inc. v. Advanced Finishing Sys., Inc., 
797 F.3d 538, 540
, 545–46 

(8th Cir. 2015) (affirming dismissal of § 1 claim in part because plaintiff failed to “identify 
which of the distributors named as defendants—if any—are among the ‘key Distributors’ 
who were party to the agreements”).                                       
    The Amended Counterclaim identifies an obvious alternative explanation for Blue 
Cross’s conduct but does not address it in the relevant sense.  According to the pleading, 

beginning at least in November 2020, concerns regarding COVID-19 testing price gouging 
were widespread, Am. Countercl. ¶ 191, and in July 2021, Blue Cross and Blue Shield of 
Kansas City sued GS Labs, id. ¶ 209, accusing GS Labs of “intentionally engaging in an 
abusive scheme to exploit the COVID-19 pandemic by duping health insurers into paying 
thousands of COVID-19 diagnostic testing claims at grossly inflated rates,” Blue Cross 

and Blue Shield of Kansas City v. GS Labs LLC, No. 4:21-cv-525-FJG (W.D. Mo.) 
(Compl.,  ECF  No.  1).    Based  on  these  public  allegations,  the  obvious  alternative 
explanation for Blue Cross’s conduct is that it suspected, and later concluded (as this 
lawsuit shows), that GS Labs was charging unreasonably excessive prices for its tests.  GS 
Labs’ allegations do not plausibly show that Blue Cross’s parallel conduct more likely 
resulted from a § 1 “contract, combination, or conspiracy” as from these obvious and 

ordinarily reasonable business concerns.                                  
    And GS Labs’ collusion theory is economically irrational and therefore implausible.  
The majority of GS Labs’ allegations concern only GS Labs; it identifies no other clinical 
lab that suffered injury resulting from the alleged conspiracy.  But in places, GS Labs goes 
further and alleges broader market consequences to support its § 1 claim.  These include, 
for example, allegations that Blue Cross’s concerted activity “artificially depress[es] prices 

to non-competitive levels in a commercial insurance market for lab-based COVID-19 
testing services[,] and caus[es] shortages in the COVID-19 diagnostic testing market.”  
Am.  Countercl.  ¶  118.    This  allegation  seems  economically  irrational  and  therefore 
implausible.7  Blue Cross should have an interest in the market presence of more clinical 
labs, not fewer.  More clinical labs would create more competition, resulting in greater 

price pressure on clinical lab participants, and yielding lower prices to retail customers and 
their insurers.  And leaving the allegation’s indefiniteness aside, GS Labs alleges elsewhere 
that the diagnostic testing services GS Labs and other clinical labs provide “improved 
health outcomes, which have dramatically reduced Blue Cross’[s] health care spend and 
the spending it would have outlaid in the absence of GS Labs’ testing.”  Am. Countercl. 


7    If not relied on very often, economic irrationality is a recognized ground to find a 
complaint’s allegations implausible.  See, e.g., Green Star Energy Sols., LLC v. Edison 
Props., LLC, No. 21-cv-2682 (LJL), 
2022 WL 16540835
, at *8 (S.D.N.Y. Oct. 28, 2022) 
(finding  economically  irrational  allegations  to  be  implausible  under  Rule  12(b)(6) 
standard).                                                                
¶ 338.  In GS Labs’ theory, the absence of Blue Cross’s prohibited § 1 conduct would 
enable more clinical labs to participate in the market, eliminate testing shortages, and 

enable those labs to increase their prices.  As Blue Cross points out, accepting this assertion 
would “invert basic economic principles.”  Mem. in Supp. [ECF No. 37] at 48.  I am 
persuaded that there is a fundamental disconnect between economic theory and GS Labs’ 
§ 1 theory and that this disconnect renders GS Labs’ § 1 claim implausible. 
                              XIV                                        
    In Count XIV, GS Labs asserts a rule-of-reason violation under § 1 of the Sherman 

Act.  Am. Countercl. at 168 (Count XIV heading).  Without allegations plausibly showing 
concerted action, a § 1 claim fails whether based on a per se or rule-of-reason analysis.  See 
Five Smiths, Inc. v. Nat’l Football League Players Ass’n, 
788 F. Supp. 1042, 1048
 (D. 
Minn. 1992).  Therefore, Count XIV will be dismissed on the same grounds that justified 
dismissal of Count XIII.                                                  

                              XV                                         
    In Count XV, GS Labs asserts a monopolization claim under § 2 of the Sherman 
Act.  Am. Countercl. ¶¶ 426–31.  Section 2 makes it unlawful to “monopolize, or attempt 
to monopolize . . . any part of the trade or commerce among the several States, or with 
foreign nations.”  
15 U.S.C. § 2
.  To state a monopolization claim under Section 2 of the 

Sherman Act, a plaintiff must allege facts plausibly showing that the defendant “(1) 
possessed monopoly power in the relevant market and (2) willfully acquired or maintained 
that power as opposed to gaining that power as a result ‘of a superior product, business 
acumen, or historical accident.’”  Amerinet, Inc. v. Xerox Corp., 
972 F.2d 1483, 1490
 (8th 
Cir. 1992) (quoting United States v. Grinnell Corp., 
384 U.S. 563, 571
 (1966)); Moldex 
Metric, Inc. v. 3M Co., No. 14-cv-1821 (JNE/FLN), 
2015 WL 520722
, at *6 (D. Minn. 

Feb. 9, 2015).                                                            
    “A relevant market breaks down into (1) a product market and (2) a geographic 
market.”  Trone Health Servs., Inc. v. Express Scripts Holding Co., 
974 F.3d 845, 857
 (8th 
Cir.  2020)  (cleaned  up).    “‘The  relevant  product  market  includes  all  reasonably 
interchangeable products.’”  Park Irmat Drug Corp. v. Express Scripts Holding Co., 
911 F.3d 505, 517
 (8th Cir. 2018) (quoting Double D Spotting Serv., Inc. v. Supervalu, Inc., 

136 F.3d 554, 560
 (8th Cir. 1998)).  “The geographic market is defined by considering the 
commercial realities faced by consumers.”  Double D Spotting Serv., 
136 F.3d at 560
.  “It 
includes the geographic area in which consumers can practically seek alternative sources 
of the product, and it can be defined as ‘the market area in which the seller operates.’”  
Id.
 
(quoting Tampa Elec. Co. v. Nashville Coal Co., 
365 U.S. 320, 327
 (1961)).   

    GS Labs alleges the relevant product market is the “Commercial Insurance Market 
for the Purchase of COVID-19 Diagnostic Testing Services.”  Am. Countercl. ¶ 144.  In 
this market, GS Labs alleges, “the insurer is the buyer and GS Labs is the seller.”  Id. ¶ 157.  
GS Labs alleges that “Blue Cross and other commercial (private) insurers . . . compete in 
this market by offering health plan products that reimburse a full suite of medical services, 

including lab-based COVID-19 diagnostics testing (as required by law), on behalf of their 
subscribers.”  Id. ¶ 145.  GS Labs also alleges that “[p]roducts offered by HMO and other 
similar managed care insurance providers may be excluded due to their vertical integration, 
which causes their networks to be unavailable to third party providers and/or their providers 
to be unavailable to third party insurance carriers.”  Id. ¶ 166.  GS Labs does not allege that 
it cannot or refuses to accept payment from sources other than private commercial insurers.  

It alleges, however, that “public insurance programs (such as Medicare, Medicaid, and 
Tricare)  pay  for  COVID-19  testing  at  rates  that  are  significantly  lower  than  what 
commercial insurance plans pay.”  Id. ¶ 140.  GS Labs alleges essentially that it could not 
operate its “scalable business model” if it were limited to payments from public insurance 
programs.  Id.; see also id. ¶¶ 141–42.                                   
    This alleged product market is implausible under Eighth Circuit precedent.  In Little 

Rock Cardiology Clinic PA v. Baptist Health, a cardiology clinic (“LRCC”) asserted, as 
relevant here, a § 1 rule-of-reason claim and a § 2 monopolization claim.  
591 F.3d 591, 596
 (8th Cir. 2009).  LRCC’s basic allegation was “that Baptist Health conspired with Blue 
Cross [& Blue Shield of Arkansas] to restrain trade in, and monopolize the market for, 
cardiology services for privately insured patients” through a series of arrangements that 

shut LRCC out from the Blue Cross network.  
Id. at 594
.  LRCC alleged a product market 
“limited to patients covered by private insurance.”  
Id. at 596
.  The Eighth Circuit affirmed 
the district court’s Rule 12(b)(6) dismissal of the suit based on its determination that this 
product market is implausible.  The court explained:                      
         LRCC proposes a market limited by how consumers pay for         
         cardiology procedures.  This theory lacks support in both logic 
         and law. . . . [T]he general issue when determining the relevant 
         product  market  concerns  the  choices  available  to          
         consumers.  Craftsmen Limousine, 491 F.3d at 388.  In this      
         case—an  exclusive-dealing  case  involving  shut-out           
         cardiologists—the  relevant  inquiry  is  whether  there  are   
         alternative  patients  available  to  the  cardiologists.  See  
         Campfield v. State Farm Mut. Auto. Ins. Co., 
532 F.3d 1111, 1119
 (10th Cir. 2008) (“When there are numerous sources of       
         interchangeable demand, the plaintiff cannot circumscribe the   
         market to a few buyers in an effort to manipulate those buyers' 
         market share.”); Stop & Shop Supermarket Co. v. Blue Cross      
         & Blue Shield of R. I., 
373 F.3d 57, 67
 (1st Cir. 2004) (“[T]he  
         concern in an ordinary exclusive dealing claim by a shut-out    
         supplier  is  with  the  available  market  for  the  supplier.”); 
         Brokerage Concepts, Inc. v. U.S. Healthcare, Inc., 
140 F.3d 494, 514
 (3d Cir. 1998) (stating the “logical assumption that [a 
         pharmacy] considers members of other prescription plans, or     
         uninsured persons, completely interchangeable with [privately   
         insured] members.”).  Thus, LRCC must look to alternative       
         patients who are able to pay the required fees, not just those  
         who pay using private insurance.                                

         LRCC argues that the product market should be limited to        
         patients using private insurance because private insurance and  
         government  insurance—the  other  primary  method  of           
         payment—are not reasonably interchangeable.  The trouble        
         with this theory is that it analyzes the issue from the wrong side 
         of the transaction.  It may be true that, from the patient’s    
         perspective, private insurance and Medicare/Medicaid are not    
         reasonably interchangeable.  For a variety of reasons, including 
         age  and  financial  considerations,  a  person  with  private  
         insurance may not qualify for these government programs.  But   
         this lawsuit is not about the options available to patients, it is 
         about the options available to shut-out cardiologists.  LRCC’s  
         claims boil down to the allegation that, due to Baptist Health’s 
         allegedly unlawful actions, LRCC has access to fewer patients.  
         The relevant question, then, is to whom might the cardiologists 
         at  LRCC  potentially  provide  medical  service?    LRCC’s     
         complaint provides the answer: LRCC can provide service to      
         “patients  .  .  .  from  either  a  government  program  such  as 
         Medicare or Medicaid, or from a private insurer.” (emphasis     
         added).  Patients able to pay their medical bill, regardless of 
         the method of payment, are reasonably interchangeable from      
         the cardiologist’s perspective—the correct perspective from     
         which to analyze the issue in this case.                        

Id. at 597
.  Based on this analysis, the court announced a seemingly clear rule: “We 
conclude that, as a matter of law, in an antitrust claim brought by a seller, a product market 
cannot be limited to a single method of payment when there are other methods of payment 
that are acceptable to the seller.”  
Id. at 598
.                          

    Like Little Rock Cardiology Clinic, this is an antitrust claim brought by a shut-out 
seller who alleges that the product market is limited to a single method of payment when 
there are other methods of payment acceptable to it.  GS Labs addresses Little Rock 
Cardiology Clinic in a footnote.  Mem. in Opp’n at 54 n.17.  There, it says “the inclusion 
of all buyers was deemed necessary [in Little Rock Cardiology Clinic] only when there are 
other methods of payment that are acceptable to the seller.”  
Id.
 (quotation omitted).  True, 

but GS Labs does not allege anywhere in its Amended Counterclaim that other methods of 
payment are unacceptable to it.  It alleges that it could not operate its “scalable business 
model” if it were limited to payments from public insurance programs.  Am. Countercl. 
¶ 140; see also 
id.
 ¶¶ 141–42.  But a health care provider saying it could not survive on 
public-insurance reimbursement alone is not the same thing as saying the provider won’t 

accept public-insurance reimbursement.  The bottom line is that GS Labs does not allege 
it cannot or refuses to accept payment from sources other than private commercial insurers.  
That seems dispositive under Little Rock Cardiology Clinic.  GS Labs cites district court 
cases from outside the Eighth Circuit accepting health-insurance product markets that 
exclude public programs.  Mem. in Opp’n at 53–54.  But these cases cannot trump 

controlling precedent.  GS Labs also argues that a Rule 12(b)(6) dismissal based on the 
implausibility of an alleged product market is disfavored.  Id. at 53.  In the Eighth Circuit 
case supporting this assertion, Double D Spotting Serv., the panel “note[d] that courts are 
hesitant  to  dismiss  antitrust  actions  before  the  parties  have  had  an  opportunity  for 
discovery, because the proof of illegal conduct lies largely in the hands of the alleged 
antitrust conspirators.”  
136 F.3d at 560
.  Post-Twombly, this expressed hesitancy cannot 

mean that there is some lesser-than-plausibility standard that applies to allegations of a 
product market.                                                           
    GS Labs’ geographic-market allegations focus first on where patients go to obtain 
“lab-based COVID-19 diagnostic testing.”  Am. Countercl. ¶ 159.  Patients, alleges GS 
Labs, “prefer local providers of COVID-19 diagnostic testing services at locations that are 
convenient to their home or workplace.”  Id. ¶ 160.  This is “for convenience, to obtain a 

result faster, to lower the chances that they will expose others (or themselves) to the virus 
in the course of testing, and to more quickly return home to quarantine or recover from 
their illness in the event they are symptomatic.”  Id. ¶ 159.  GS Labs identifies five 
Minnesota metropolitan areas in which lab-based providers have established operations.  
Id. ¶ 160.  On the commercial insurance side, GS Labs alleges: “Health insurers competing 

in the Commercial Insurance Market . . . seek to build networks of COVID-19 diagnostic 
testing providers nationwide, statewide, and in localized geographic markets in populated 
areas where patients live and work.”  Id. ¶ 162.  GS Labs alleges that “[t]he geographic 
market  for  the  Commercial  Insurance  Market,  therefore,  is  based  on  the  geographic 
footprint of employers, individually insured people, and other subscribers of commercial 

insurance products.”  Id.  In sum, GS Labs alleges: “The relevant geographic markets are: 
Minnesota; certain counties, cities, or other localities within Minnesota; and/or a territory 
broader than Minnesota but within the United States.”  Id. ¶ 158.         
    These allegations do not plausibly identify a geographic market.  If the relevant 
product market is the “Commercial Insurance Market for the Purchase of COVID-19 

Diagnostic Testing Services[,]” id. ¶ 144, then the geographic market should be defined by 
allegations showing where Blue Cross purchases COVID-19 diagnostic testing services.  
That is where Blue Cross “draws a sufficiently large percentage of its business” in the 
relevant  sense.    Little  Rock  Cardiology  Clinic,  
591 F.3d at 598
.    The  Amended 
Counterclaim doesn’t allege the geographic market this way.  It relies instead on allegations 
showing why patients who obtain COVID-19 testing stay close to home or work (or where 

they are at the moment they decide to get tested) and where Blue Cross sells insurance, 
including the allegation that it sells insurance in similarly local markets.  At the hearing on 
this motion, GS Labs argued that this approach nonetheless works because Blue Cross’s 
market  power  comes  from  its  subscriber  base.    Tr.  [ECF  No.  56]  at  67.    It  seems 
conceivable that the geographic area in which Blue Cross purchases COVID-19 diagnostic 

testing services may overlap with the territory in which it issues or administers health 
insurance plans.  But that possibility—or even likelihood—doesn’t address the absence of 
allegations plausibly showing a geographic market in which Blue Cross purchases a 
sufficiently large percentage of its COVID-19 diagnostic testing services.8 


8    Though not decided here, it is worth expressing doubt regarding whether GS Labs 
has plausibly alleged anticompetitive conduct.  “‘Anticompetitive conduct is conduct 
without  legitimate  business  purpose  that  makes  sense  only  because  it  eliminates 
competition.’”  HDC Med., Inc. v. Minntech Corp., 
474 F.3d 543, 549
 (8th Cir. 2007) 
(quoting Morgan v. Ponder, 
892 F.2d 1355, 1358
 (8th Cir. 1989)).  “‘When a valid business 
reason exists for the conduct alleged to be predatory or anti-competitive, that conduct 
cannot support the inference of a [Sherman Act] violation.’”  
Id.
 at 549–50 (quoting 
Midwest Radio Co., Inc. v. Forum Pub. Co., 
942 F.2d 1294
, 1297–98 (8th Cir. 1991)).  
                              XVI                                        
    GS Labs asserts a § 2 Sherman Act attempted monopolization claim in Count XVI.  

The parties do not separately address this claim.  Regardless, it seems settled that the failure 
to allege a plausible product or geographic market dooms this claim.  Par v. Wolfe Clinic, 
P.C., No. 4:21-cv-00290-RGE-SBJ, 
2022 WL 2187858
, at *8 (S.D. Iowa May 10, 2022); 
Physician  Specialty  Pharmacy,  LLC  v.  Prime  Therapeutics,  LLC,  No.  18-cv-1044 
(MJD/TNL),  
2019 WL 5149866
,  at  *8  (D.  Minn.  Aug.  8,  2019),  report  and 
recommendation adopted, 
2019 WL 4463442
 (D. Minn. Sept. 18, 2019).  This conclusion 

makes sense.  GS Labs neither alleges nor argues that it can show that Blue Cross has a 
“dangerous  probability  of  success”  in  its  alleged  monopolization  efforts  without 
referencing Blue Cross’s share of a plausible “relevant market.”  See HDC Medical, 474 
F.3d at 549–50 (quoting  Gen. Indus. Corp. v. Hartz Mountain Corp., 
810 F.2d 795
, 806–
07 (8th Cir. 1987) and Alexander v. Nat’l Farmers Org., 
687 F.2d 1173, 1181
 (8th Cir. 

1982)).                                                                   




“[A]s a general matter, the Sherman Act ‘does not restrict the long recognized right of [a] 
trader or manufacturer engaged in an entirely private business, freely to exercise his own 
independent discretion as to parties with whom he will deal.’”  Verizon Commc’ns Inc. v. 
Law Offices of Curtis V. Trinko, LLP, 
540 U.S. 398, 408
 (2004) (quoting United States v. 
Colgate & Co., 
250 U.S. 300, 307
 (1919)).  GS Labs’ theory is essentially that Blue Cross 
made statements to its members that steered them away from GS Labs because, as GS Labs 
seems to acknowledge, its services were more expensive.  See Mem. in Opp’n at 61–62.  
GS Labs identifies no other affected provider.  Under these circumstances, it is difficult to 
understand why Blue Cross’s conduct was anticompetitive or how it caused antitrust injury.     
                         XVII and XVIII                                  
    In these Counts, GS Labs alleges antitrust claims under Minnesota law that are 

parallel to its federal claims.  Minn. Stat. §§ 325D.51–.53.  The parties agree that these 
claims stand or fall with the federal claims, and there is no reason here to second-guess that 
judgment.  See Inline Packaging, LLC v. Graphic Packaging Int’l, LLC, 
962 F.3d 1015, 1024
 (8th Cir. 2020) (quoting Lorix v. Crompton Corp., 
736 N.W.2d 619, 626
 (Minn. 
2007)).  These claims will therefore be dismissed for the same reasons as the federal claims 
will be dismissed.                                                        

                              XIX                                        
    GS Labs asserts a claim for tortious interference with contract in Count XIX.  Am. 
Countercl. at 174.  To state a claim for tortious interference with contract under Minnesota 
law, GS Labs must allege facts plausibly showing: “(1) the existence of a contract; (2) the 
alleged wrongdoer’s knowledge of the contract; (3) intentional procurement of its breach; 

(4) without justification; and (5) damages.”  Kjesbo v. Ricks, 
517 N.W.2d 585, 588
 (Minn. 
1994) (citation omitted).  Showing the absence of justification in turn requires showing an 
improper  means,  which  “are  those  that  are  independently  wrongful  such  as  threats, 
violence, trespass, defamation, misrepresentation of fact, restraint of trade or any other 
wrongful act recognized by statute or common law.”  Inline Packaging, LLC v. Graphic 

Packaging Int'l, Inc., 
164 F. Supp. 3d 1117, 1137
 (D. Minn. 2016) (quoting Harman v. 
Heartland Food Co., 
614 N.W.2d 236, 241
 (Minn. Ct. App. 2000)) (emphasis added). 
    GS Labs’ tortious-interference allegations attempt to track these elements: (1) GS 
Labs alleges it has contracts with BCBS affiliates (other than Blue Cross in Minnesota) 
“regarding the rates of reimbursement for COVID-19 diagnostic testing provided to those 
BCBS affiliates’ members.”  Am. Countercl. ¶ 458.  (2) It alleges that Blue Cross knows 

of these contracts “by virtue of its participation in the BlueCard program.”  Id. ¶ 459.  (3) 
GS  Labs  alleges  that  Blue  Cross’s  failure  to  comply  with  its  obligations  under  the 
BlueCard-program contract or contracts (as described above in connection with GS Labs’ 
intended-beneficiary theory) “caused a breach of the reimbursement provisions” in GS 
Labs’ contracts with other BCBS affiliates.  Id. ¶ 460; see also id. ¶ 463.  (4) GS Labs 
alleges that “Blue Cross had and has no lawful basis or justification to not reimburse GS 

Labs at the rates agreed to by certain BCBS affiliates.”  Id. ¶ 462.  (5) And GS Labs alleges 
it sustained damages resulting from Blue Cross’s alleged tortious interference.  Id. ¶ 465. 
    This claim is implausible.  GS Labs does not allege facts showing that Blue Cross 
acted  without  justification.    As  noted,  interference  is  without  justification  if  it  is 
accomplished  through  improper  means,  and  improper  means  are  those  that  are 

independently wrongful.  Inline Packaging, 
164 F. Supp. 3d at 1137
.  GS Labs alleges no 
independently wrongful conduct, like threats, violence, or defamation.  It alleges only that 
Blue Cross breached a contract with other BCBS affiliates and that this breach of contract 
resulted in other contractual breaches affecting GS Labs.  A contractual breach is not 
tortious—that is, it is not independently wrongful.  To put it another way, I understand 

Minnesota law to say that a mere contract breach cannot put the “tort” in a tortious 
interference claim.  There is another problem.  GS Labs’ allegations regarding breach of 
its contracts with the BCBS affiliates are quite general.  GS Labs does not allege facts 
plausibly identifying either which BCBS-affiliate contracts were breached or how. 
                              XX                                         
    In Count XX, GS Labs asserts a breach-of-contract claim on the theory that it is an 

intended third-party beneficiary of contracts between Blue Cross and “BCBS affiliates” in 
other states.  Am. Countercl. ¶ 467.  GS Labs alleges “on information and belief” that these 
contracts “require Blue Cross to forward all claims from a provider related to services 
provided to a member of a BCBS affiliate’s plan, to that plan.”  Id. ¶¶ 266, 468.  In other 
words, GS Labs alleges that if it (or any other provider) submits a claim to Blue Cross in 
Minnesota for a patient who is in fact covered under a plan insured or administered by a 

BCBS affiliate in another state, then Blue Cross is contractually required to transmit the 
claim to that affiliate for a benefits determination by that affiliate.  See id. ¶ 180.  GS Labs 
alleges that Blue Cross assented to these arrangements “through its participation in the 
BlueCard program.”  Id. ¶ 266; see also id. ¶¶ 176–78 (alleging that the BlueCard program 
is a claims routing system that “obligates each BCBS affiliate to treat other affiliates’ 

members at the reimbursement level that they have negotiated with providers” and that 
“‘links participating health care providers and independent Blue Cross plans through a 
single electronic network’”).  GS Labs alleges that, if Blue Cross had complied with its 
obligations under these contracts, it would have been paid “millions” more by the affiliates 
than Blue Cross has paid (or not paid).  Id. ¶ 473.  Central to its claim to be a third-party 

beneficiary  of  these  contracts,  Blue  Cross  alleges:  “On  information  and  belief,  the 
BlueCard program contract(s) between Blue Cross and other BCBS affiliates clearly 
manifest an intent to benefit providers like GS Labs by establishing a means for these 
providers to obtain reimbursement and the benefits of its contracts with an out-of-state 
BCBS plan.”  Id. ¶ 468.                                                   

    “Generally, a stranger to a contract does not have rights under the contract, but an 
exception exists if a third party is an intended beneficiary of the contract.”  Hickman v. 
Safeco Ins. Co. of Am., 
695 N.W.2d 365, 369
 (Minn. 2005).  To determine whether a third 
party is an intended beneficiary of a contract, Minnesota follows the Restatement (Second) 
of Contracts § 302.  Cretex Cos., Inc. v. Constr. Leaders, Inc., 
342 N.W.2d 135, 139
 (Minn. 
1984).  The Restatement provides:                                         

         (1) Unless otherwise agreed between promisor and promisee,      
         a  beneficiary  of  a  promise  is  an  intended  beneficiary  if 
         recognition of a right to performance in the beneficiary is     
         appropriate to effectuate the intention of the parties and either 

              (a)  the  performance  of  the  promise  will  satisfy  an 
              obligation  of  the  promisee  to  pay  money  to  the     
              beneficiary; or                                            

              (b) the circumstances indicate that the promisee intends   
              to  give  the  beneficiary  the  benefit  of  the  promised 
              performance.                                               

         (2) An incidental beneficiary is a beneficiary who is not an    
         intended beneficiary.                                           

Restatement (Second) of Contracts § 302; see also Caldas v. Affordable Granite & Stone, 
Inc., 
820 N.W.2d 826
, 832–33 (Minn. 2012).  “In determining the parties’ intent, we look 
to the language of the contract.”  Caldas, 
820 N.W.2d at 833
.  This contract examination 
seems essential applying the intent-to-benefit rule of § 302(1)(b), and courts applying the 
test engage in a close review of the relevant contract.  See, e.g., id. at 833–35; Kruger v. 
Lely N. Am., Inc., 
518 F. Supp. 3d 1281
, 1289 (D. Minn. 2021).  “In most cases, ‘when 
there is no reference to the third party in the contract, there is no intent to benefit the third 
party.’”  Dayton Dev. Co. v. Gilman Fin. Servs., Inc., 
419 F.3d 852, 856
 (8th Cir. 2005) 

(quoting 614 Co. v. Minneapolis Cmty. Dev. Agency, 
547 N.W.2d 400, 410
 (Minn. Ct. App. 
1996)).                                                                   
    GS Labs alleges that Blue Cross’s contracts with other BCBS affiliates indicate an 
intent to benefit GS Labs (and presumably every other provider), but this allegation is 
implausible.9  GS Labs’ description of these contracts omits mention of any particular 
contract term or terms indicating an intent to benefit providers.  GS Labs does not allege 

that it or providers generally are referenced in the contracts (or any of them).  It is true that 
GS Labs alleges that these contracts “clearly manifest an intent to benefit providers[,]” Am. 
Countercl. ¶ 468, but this allegation is not sufficient.  It pleads a legal conclusion because 
the allegation merely repeats Minnesota’s intent-to-benefit rule.  Courts “are not bound to 
accept as true a legal conclusion couched as a factual allegation.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (citation and internal quotation marks omitted).  It is made “[o]n 
information and belief” because GS Labs does not have the contracts.  Am. Countercl. 
¶ 468.  In other words, it is not possible to examine the contracts to determine whether any 
or all of them express an intent to benefit providers.  (GS Labs faults Blue Cross for 
declining to file the contracts, but GS Labs identifies no authority that might have required 

Blue Cross to do that.)  Regardless, this claim’s supporting allegations show at most that 

9    GS Labs does not attempt to meet the duty-owed test in § 302(1)(a).  Its allegation 
that Blue Cross’s transmission of the claim to the appropriate BCBS affiliate results only 
in a “benefits determination[]” and not necessarily payment, Am. Countercl. ¶ 180, would 
undermine that contention.                                                
providers might benefit incidentally from the presence of these contracts in the same way 
providers  might  benefit  from  any  contract  facilitating  the  efficient  adjudication  of  a 

benefits claim.  That is not enough to plausibly allege a breach-of-contract claim via an 
intended-beneficiary theory under Minnesota law.                          
                              XXI                                        
    In Count XXI, GS Labs alleges facts supporting a claim for punitive damages under 
Minnesota law.  Am. Countercl. at 176.  Whether this Count should be dismissed depends 
on the resolution of two issues.  The first concerns the procedural propriety of the claim.  

Minnesota  law,  specifically  
Minn. Stat. § 549.191
,  prohibits  plaintiffs  from  seeking 
punitive damages in an initial complaint.  Blue Cross argues that GS Labs’ punitive 
damages claim should be dismissed under the Minnesota statute.  Though older cases in 
this District applied the statute in diversity cases, the recent intra-District trend has been 
not to apply the statute in favor of Rules 8 and 15 of the Federal Rules of Civil Procedure.  

See  Am.  Achievement  Corp.  v.  Jostens,  Inc.,  ---  F.  Supp.  3d  ---,  No.  21-cv-2613 
(NEB/BRT), 
2022 WL 3566862
, at *9–10 (D. Minn. Aug. 18, 2022) (reviewing issue and 
citing  cases);  cf.  Shank  v.  Carleton  Coll.,  
329 F.R.D. 610
,  615  (D.  Minn.  2019) 
(recognizing that the state of the law on this question has been “in flux”).  The case on 
which Blue Cross relies, Bergman v. Johnson & Johnson, No. 20-cv-2693 (JRT/HB), 
2021 WL 3604305
 (D. Minn. Aug. 13, 2021), doesn’t support Blue Cross’s position.  There, the 
court declined to resolve the question because it was “irrelevant.”  
Id. at *6
 (“As there is 
no motion to amend or proposed amended complaint at issue in the present matter, the issue 
of which standard the Court would apply to determine whether a plaintiff may seek punitive 
damages is irrelevant.”).                                                 

    Assuming GS Labs’ claim is procedurally proper under the more recent intra-
District trend, there is another problem.  GS Labs’ remaining claims are for benefits under 
ERISA, 
29 U.S.C. § 1132
(a)(1)(B), and for promissory estoppel under Minnesota law.  
Punitive damages are not recoverable in an ERISA benefits claim under § 1132(a)(1)(B).  
See Massachusetts Mut. Life Ins. Co. v. Russell, 
473 U.S. 134, 148
 (1985) (determining 
that ERISA does not provide a cause of action for extracontractual compensatory or 

punitive damages in the context of a benefits claim).  And though I’ve found no case 
answering  the  question  under  Minnesota  law,  other  jurisdictions  hold  that  punitive 
damages are not recoverable under a promissory estoppel claim.  See, e.g., Beluca Ventures 
LLC v. Einride Aktiebolag, No. 21-cv-06992-WHO, 
2022 WL 17252589
, at *5 (N.D. Cal. 
Nov. 28, 2022) (holding that punitive damages are not recoverable for promissory estoppel 

or other quasi-contract claims under California law); LPD New York, LLC v. Adidas Am., 
Inc., No. 15-CV-6360 (MKB), 
2022 WL 4450999
, at *18 n.11 (E.D.N.Y. Sept. 24, 2022) 
(“Punitive damages are not available under New York law for Plaintiff’s promissory 
estoppel or quasi-contract claims.”); Dugdale, Inc. v. Alcatel-Lucent USA, Inc., No. 1:09-
cv-0960-JMS-TAB, 
2011 WL 2261318
, at *4 (S.D. Ind. June 7, 2011) (applying Indiana 

law).  In view of these authorities, I think the wiser course is to dismiss GS Labs’ punitive 
damages claim.  Of course, if GS Labs is able to cite Minnesota authority permitting a 
recovery of punitive damages for promissory estoppel, it may re-assert the claim.  

ORDER

    Based on the foregoing, and on all the files, records, and proceedings herein, IT IS 

ORDERED THAT:                                                             
    1.   Blue Cross’s motion to dismiss [ECF No. 35] is GRANTED IN PART and 
DENIED IN PART.                                                           
    2.   Counts I, II, VI, and IX insofar as it asserts a claim under 
29 U.S.C. § 1132
(a)(3) are DISMISSED WITH PREJUDICE.                                  
    3.   Counts III, V, VII, VIII, X, XI, XII, XIII, XIV, XV, XVI, XVII, XVIII, XIX, 

XX, and XXI are DISMISSED WITHOUT PREJUDICE.                              
    4.   The motion is DENIED with respect to Counts IV and IX insofar as it asserts 
a claim under 
29 U.S.C. § 1132
(a)(1).                                     

Date:  January 30, 2022            s/ Eric C. Tostrud                     
                                  Eric C. Tostrud                        
                                  United States District Court           

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF MINNESOTA                                


BCBSM, Inc., a Minnesota nonprofit          File No. 22-cv-513 (ECT/DJF) 
corporation, on behalf of itself and its self-                            
insured groups d/b/a Blue Cross and Blue                                  
Shield of Minnesota,                                                      

         Plaintiff and Counter-                                          
         Defendant,                     OPINION AND ORDER                

v.                                                                        

GS Labs, LLC,                                                             

         Defendant and                                                   
         Counterclaimant.                                                
________________________________________________________________________  
Charles Gokey, Geoffrey H. Kozen, Jeffrey Sullivan Gleason and Stephanie Alicia Chen, 
Robins Kaplan LLP, Minneapolis, MN for Plaintiff and Counter-Defendant BCBSM, Inc. 
Kyle R. Kroll, Thomas H. Boyd, David M. Aafedt and Christianna L. Finnern, Winthrop 
& Weinstine, PA, Minneapolis, MN, and Kajetan Rozga, Yonaton M. Rosenzweig and 
Adam  Sieff,  Davis  Wright  Tremaine,  LLP,  Los  Angeles,  CA  for  Defendant  and 
Counterclaimant GS Labs, LLC.                                             
________________________________________________________________________  
    This case began with a dispute over payment for COVID-19 diagnostic testing.  
Defendant and Counterclaimant GS Labs claims to have provided COVID diagnostic tests 
to over 300,000 Minnesotans, more than 70,000 of whom were insured, or had insurance 
administered by, Plaintiff and Counter-Defendant BCBSM (“Blue Cross”).  GS Labs says 
that the tests it provided were necessary, high-quality, and contributed positively to the 
nation’s pandemic response.  Blue Cross, on the other hand, says GS Labs is a pandemic 
profiteer that charged unreasonably high prices for unnecessary, faulty tests. 
    Blue Cross brought the case.  It asserts one claim under federal law and four claims 
under Minnesota law.  It seeks damages comprised of the millions of dollars it has paid GS 

Labs and additional sums it has incurred to address GS Labs’ alleged misconduct.  Blue 
Cross also seeks a declaration that it is not legally obligated to pay GS Labs for outstanding 
claims, an injunction essentially forbidding GS Labs from seeking payment from Blue 
Cross members and plans, and attorneys’ fees and costs.                   
    GS Labs responded to Blue Cross’s Complaint with an Answer and Counterclaim, 
and it has since amended the Counterclaim.  The Amended Counterclaim has twenty-one 

counts.  In seven of these, GS Labs asserts claims arising under federal law, including the 
CARES Act, ERISA, the Lanham Act, and the Sherman Act.  In twelve counts, GS Labs 
asserts claims under Minnesota law.1  The remaining two counts describe requested 
remedies:  a declaratory judgment and punitive damages.  For relief, GS Labs seeks 
reimbursement for diagnostic testing services it provided to individuals covered under 

benefit plans insured or administered by Blue Cross, millions in additional damages it 
claims to have incurred as a result of Blue Cross’s conduct, treble antitrust damages, 
punitive damages, declaratory relief, and attorneys’ fees and costs.      
    Blue  Cross  has  filed  a  motion  seeking  dismissal  of  GS  Labs’  Amended 
Counterclaim in its entirety under Federal Rule of Civil Procedure 12(b)(6).  The short 

version of a longer story is that most of GS Labs claims will be dismissed.  Left to proceed 

1    The Amended Counterclaim references Minnesota law specifically for statutory 
claims, but not claims under the common law.  Though GS Labs’ allegations imply that 
the case may have connections to other states, GS Labs made clear at the hearing on this 
motion that it asserts all of its state claims under Minnesota law.       
will be GS Labs’ claims for promissory estoppel and for benefits due under ERISA’s civil 
enforcement provision, 
29 U.S.C. § 1132
(a)(1)(B).                         

                               *                                         
    This order’s structure.  This order addresses GS Labs’ 21 claims in the order they 
appear in the Amended Counterclaim.  Though some claims might reasonably have been 
grouped together—that is how the parties approached the problem—each claim is analyzed 
separately.  The Roman numeral appearing at the beginning of each section corresponds to 
the Count being analyzed.  Rather than provide a detailed facts section up front, the relevant 

factual allegations will be described as each Count is analyzed.  Regardless, a few basic 
background facts deserve mention up front to provide context.             
    Basic background facts.  GS Labs was formed in January 2020.  Am. Countercl. 
[ECF No. 22] ¶ 16.  When the COVID pandemic began, GS Labs entered the diagnostic 
testing market, developing infrastructure and opening and staffing over fifty COVID 

testing sites across the country, including eleven in Minnesota.  
Id.
 ¶¶ 17–22, 24.   Blue 
Cross is a health insurer and an administrative services provider to self-funded health plans.  
Id. ¶ 72
.  Under these third-party health plans, also known as Administrative Services Only 
or “ASO” plans, the plan funder assumes the risk of the plan and contracts with an 
insurance company (here, Blue Cross) to provide administrative services and manage the 

plan’s day-to-day operations.  
Id. ¶ 73
.  GS Labs, without requiring prepayment, performed 
thousands of COVID-19 tests for Blue Cross insureds or for persons whose plans Blue 
Cross administered.  
Id. ¶¶ 40, 78
.  GS Labs submitted its first request for reimbursement 
to Blue Cross on December 22, 2020.  
Id. ¶ 41
.  Blue Cross reimbursed GS Labs for a time, 
but eventually stopped paying because of the allegations it makes in this case.  See 
id.
 ¶¶ 
43–48; 58; 61–62.                                                         

    The familiar Rule 12(b)(6) standards.  In reviewing a motion to dismiss for failure 
to state a claim under Rule 12(b)(6), a court must accept as true all of the factual allegations 
in the complaint and draw all reasonable inferences in the plaintiff's favor.  Gorog v. Best 
Buy Co., 
760 F.3d 787, 792
 (8th Cir. 2014).  Although the factual allegations need not be 
detailed, they must be sufficient to “raise a right to relief above the speculative level.”  Bell 
Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).  The complaint must “state a claim to 

relief that is plausible on its face.”  
Id. at 570
.  “A claim has facial plausibility when the 
plaintiff pleads factual content that allows the court to draw the reasonable inference that 
the defendant is liable for the misconduct alleged.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 
(2009).  A court need not, however, accept as true wholly conclusory allegations or legal 
conclusions couched as factual allegations.  Hager v. Ark. Dep’t of Health, 
735 F.3d 1009, 1013
 (8th Cir. 2013).  Matters outside the pleadings are also not ordinarily considered on 
a motion to dismiss.  See Fed. R. Civ. P. 12(d).  This includes “any written or oral evidence 
in support of or in opposition to the pleading that provides some substantiation for and does 
not merely reiterate what is said in the pleadings.”  Hamm v. Rhone-Poulenc Rorer Pharm., 
Inc., 
187 F.3d 941, 948
 (8th Cir. 1999).  A court may, however, consider exhibits attached 

to the pleadings, materials embraced by the pleadings, and matters of public record.  Illig 
v. Union Elec. Co., 
652 F.3d 971, 976
 (8th Cir. 2011).                    
     In Count I, GS Labs asserts a claim under § 3202 of the Coronavirus Aid, Relief, 
and Economic  Security (or “CARES”) Act.  Am.  Countercl. 4] 273-308.  The issue is 
whether § 3202 creates a private right of action.  Section 3202 reads: 
     SEC. 3202. PRICING OF DIAGNOSTIC TESTING. 
         (a) REIMBURSEMENT RATES.—A  group  health  plan  or  a health 
     insurance issuer providing coverage  of items and services described 
     in  section  6001(a)  of division  F  of the  Families  First  Coronavirus 
     Response  Act  (
Public Law 116-127
)  with  respect  to  an  enrollee 
     shall  reimburse  the  provider  of the  diagnostic  testing  as  follows: 
             (1)  If the health 1 Plan  or issuer has  a  negotiated  rate  with 
         such  provider  in  effect  before  the  public   health  emergency 
         declared  under  section  319  of  the  Public  Health  Service  Act 
         (42  U.S.C.  247d),  such  negotiated  rate  shall  apply  throughout 
         the period of such declaration. 
             (2)  If the health plan or issuer does not have a negotiated 
         rate  with  such  provider,  such  plan  or  issuer  shall  reimburse 
         the  provider in  an amount that equals the cash  price  for  such 
         service  as  listed  by the  provider  on  a  public  internet  website, 
         or such plan or issuer may negotiate a rate with such  provider 
         for less   than such cash price. 
         (b)  REQUIREMENT  TO  PUBLICIZE  CASH  PRICE  FOR  DIAGNOSTIC 
     TESTING FOR COVID-19.— 
             (1)  IN  GENERAL.—During  the  emergency  period  declared 
         under  section  319 of the Public  Health  Service Act (42  U.S.C. 
         247d),  each  provider  of a  diagnostic  test  for  COVID-19  shall 
         make  public the  cash  price  for  such  test  on  a  public  internet 
         website of such provider. 
             (2)  CIVIL MONETARY PENALTIES.—The  Secretary  of Health 
         and  Human  Services  may  impose  a  civil  monetary  penalty 
         on  any  provider  of  a  diagnostic  test  for  COVID-19  that  is 
         not  in  compliance  with  paragraph  (1)  and  has  not  completed 
         a  corrective  action  plan  to  comply  with  the  requirements  of 
         such  paragraph,  in  an  amount  not  to  exceed  $300  per  day 
         that the violation is ongoing. 
Pub. L. No. 116-136, § 3202
, 
134 Stat. 281
, 367 (2020).  The section of the Families First 
Coronavirus Response Act (or “FFCRA”) referenced in § 3202(a) requires group health 
plans  and their insurers  to  “provide  coverage,”  and forbids them  from imposing  “cost 
sharing” or “prior authorization or other medical management requirements,” for FDA-

approved “diagnostic products . . . for the detection of SARS-CoV-2 or the diagnosis of 
the virus that causes COVID-19.”  
Pub. L. No. 116-127, § 6001
(a), 
134 Stat. 178
, 201–02 

(2020).                                                                   
    As  factual  support  for  this  claim,  GS  Labs  alleges  that  it  has  no  negotiated 
reimbursement rate with Blue Cross.  Am. Countercl. ¶ 305.  It contends that § 3202 entitles 
it to receive reimbursement at whatever price it published on its website and gives it a cause 
of action to obtain amounts due from group health plans or their insurers.  See id. ¶ 303. 
    “Like substantive federal law itself, private rights of action to enforce federal law 

must be created by Congress.”  Alexander v. Sandoval, 
532 U.S. 275, 286
 (2001).  “The 
judicial task is to interpret the statute Congress has passed to determine whether it displays 
an intent to create not just a private right but also a private remedy.”  Id.; see also 
Transamerica Mortg. Advisors, Inc. v. Lewis, 
444 U.S. 11, 15
 (1979) (“The question 
whether a statute creates a cause of action, either expressly or by implication, is basically 

a  matter  of  statutory  construction.”).    “It  is  now  clear  that  the  proper  focus  is  on 
congressional intent, and nothing short of an unambiguously conferred right will support 
an implied right of action.”  Osher v. City of St. Louis, 
903 F.3d 698, 702
 (8th Cir. 2018) 
(cleaned up).  “It is insufficient to show merely that a particular statute intended to benefit 
the putative plaintiff.”  
Id.
 (cleaned up).                               

    The better answer is that § 3202 does not create a private remedy.  This is so for 
several reasons: (1) The statute authorizes no judicial proceeding.  (2) Neither does it define 
a class that may bring suit.  (3) That part of the statute concerning reimbursement (on which 
GS Labs chiefly relies) focuses on health plans and health insurance issuers, not on 
providers like GS Labs.  The statute, in other words, “does not contain rights-creating 
language that is phrased in terms of the persons benefitted.”  Id. at 702 (cleaned up).  (4) 

The statute’s only identified enforcement mechanism empowers the Secretary of Health 
and Human Services to impose a specified civil monetary penalty on providers who do not 
comply with the requirement that they publicize the cash price for testing “on a public 
internet website of such provider.”  This seems significant because “[t]he express provision 
of one method of enforcing a substantive rule suggests that Congress intended to preclude 
others[,]” Alexander, 
532 U.S. at 290
, and because the enforcement method Congress 

created runs the opposite direction of the remedy GS Labs seeks to imply. 
    This determination falls in line with the majority of courts that have addressed the 
issue.  Though neither the Supreme Court nor the Eighth Circuit have addressed this 
question, at least five district courts have, and four of those have determined that § 3202 
does not create a private right of action for providers.  Compare GS Labs, Inc. v. Medica 

Ins. Co., No. 21-cv-2400 (SRN/TNL), 
2022 WL 4357542
, at *3–12 (D. Minn. Sept. 20, 
2022); Saloojas Inc. v. Blue Shield of Cal. Life & Health Ins. Co., No. 22-cv-3267-MMC, 
2022 WL 4843071
, at *1 (N.D. Cal. Oct. 3, 2022); Saloojas, Inc. v. Aetna Health of Cal., 
Inc., No. 22-cv-01696-JSC, 
2022 WL 2267786
, at *2–5 (N.D. Cal. June 23, 2022); and 
Murphy Med. Assocs., LLC v. Cigna Health & Life Ins. Co., No. 3:20cv1675, 
2022 WL 743088
, at *2–6 (D. Conn. Mar. 11, 2022), with Diagnostic Affiliates of Ne. Hou, LLC v. 
United Healthcare Servs., Inc., No. 2:21-cv-00131, 
2022 WL 214101
, at *3–9 (S.D. Tex. 
Jan. 18, 2022).                                                           
    GS Labs advances several arguments to show that § 3202 creates a private right of 
action.  Most of these are addressed in the analysis above and in the cases cited in the 

preceding paragraph holding that § 3202 does not create a private right of action.  Two 
contentions deserve additional attention.                                 
    First, GS Labs argues that § 3202(a)’s lack of an enforcement mechanism is an 
implicit indication of Congressional intent to create a private right of action.  Mem. in 
Opp’n [ECF No. 47] at 13–18.  As support for this argument, GS Labs relies on Steele v. 
Louisville & N.R. Co., 
323 U.S. 192
 (1944).  There, the Supreme Court held that when 

Congress issues a statutory command with no enforcement mechanism “other than resort 
to the courts,” courts have the “jurisdiction and duty to afford a remedy for a breach of 
statutory duty.”  
Id. at 207
.  Steele, however, is emblematic of an era during which courts 
held and applied a considerably broader view of implied causes of action.  See Ziglar v. 
Abbasi, 
137 S. Ct. 1843, 1855
 (2017).  Binding precedent today counsels caution in 

implying causes of action and directs that the focus be on statutory intent.  See id.; Syngenta 
Seeds, Inc. v. Bunge N. Am., Inc., 
773 F.3d 58, 63
 (8th Cir. 2014).  The determination that 
§ 3202 creates no private right off action is more faithful to the modern, controlling 
approach.                                                                 
    Second, GS Labs refers to parts of the CARES Act’s legislative history that it alleges 

support implying a private right of action.  Am. Countercl. ¶¶ 282–88.  The history on 
which  GS  Labs  relies  consists  largely  of  legislators’  statements  emphasizing  the 
importance of testing to address the COVID-19 pandemic.  See id.  The “ordinary problems 
with relying on legislative history—no bicameralism and presentment, focus on ‘intent’ 
rather than meaning, unfamiliarity of legislators with the material, and so forth” are widely 
recognized.  United States v. Mast, 
938 F.3d 973
, 979–80 (8th Cir. 2019) (Colloton, J., 

dissenting) (citing Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of 
Legal Texts 369–90 (2012)).  These ordinary problems aside, the legislative history GS 
Labs identifies addresses the wisdom of testing from many perspectives, but none of this 
history is specific to § 3202, much more the question whether § 3202 creates the private 
right of action GS Labs seeks to assert here.  GS Labs’ claim under the CARES Act (Count 
I) will be dismissed because § 3202 creates no private right of action for the recovery of 

unpaid or underpaid diagnostic-testing charges.                           
                               II                                        
    The declaratory judgment GS Labs seeks in Count II is derived from and concerns 
the same issue as Count I—whether § 3202 creates a private right of action.  See Am. 
Countercl. ¶¶ 309–14.  Therefore, this claim also will be dismissed.  See Doe v. Univ. of 

St. Thomas, 
240 F. Supp. 3d 984, 989
 (D. Minn. 2017) (recognizing that the Declaratory 
Judgment Act, 
28 U.S.C. § 2201
, “cannot be used as an independent cause of action” when 
the underlying statute contains no private right of action).              
                              III                                        
    GS Labs asserts a typical breach-of-contract claim in Count III.  Under Minnesota 

law, the elements of a breach-of-contract claim are “(1) formation of a contract, (2) 
performance by plaintiff of any conditions precedent to his right to demand performance 
by the defendant, and (3) breach of the contract by defendant.”  Park Nicollet Clinic v. 
Hamann, 
808 N.W.2d 828, 833
 (Minn. 2011).  “The formation of a contract requires 
communication of a specific and definite offer, acceptance, and consideration.”  E. Coast 
Test Prep LLC v. Allnurses.com, Inc., 
307 F. Supp. 3d 952, 970
 (D. Minn. 2018).   

    GS Labs alleges that it had a contract with Blue Cross under which Blue Cross 
“agreed to pay GS Labs at the cash prices publicly posted on GS Labs’ website.”  Am. 
Countercl. ¶ 317.  To show formation of this contract, GS Labs alleges that a Blue Cross 
employee, Senior Provider Contract Manager Kevin L. Jones, emailed GS Labs on March 
31, 2021, stating that Blue Cross “declines to negotiate rates for these services and will 
reimburse eligible services per your pricing as listed on the GS Labs website as required 

by section 3202 of the CARES Act.”  See id.; ECF No. 38-2.  “Mr. Jones also asked GS 
Labs to register as an ‘out-of-network provider’. . . by completing a registration form.”  
Am. Countercl. ¶ 317.  GS Labs alleges that it accepted this “offer” when it “filled out the 
registration form requested by Blue Cross.”  Id. ¶ 318.  GS Labs alleges that Blue Cross 
breached this contract when it “abruptly backtracked on its agreement to pay the cash prices 

posted on GS Labs’ website in August 2021.”  Id. ¶ 322.                   
    The email on which the claim depends cannot plausibly be understood as an offer 
by Blue Cross to contract with GS Labs.  The email’s author explicitly disclaimed an intent 
to contract when he wrote that Blue Cross “declines to negotiate rates for these services.”  
The author’s statement that Blue Cross would pay “as required by section 3202 of the 

CARES Act” expressed an “at-this-time” intention to comply with the law as Blue Cross 
understood it.  The email neither required nor invited formation of a contract to follow 
through on that intention.  Instead, the email invited GS Labs to register as an “out-of-
network” provider.  But the registration form implies, ECF No. 38-3, and cases confirm, 
that non-participating, out-of-network providers generally do not have contracts with 
insurers.  See, e.g., N. Cypress Med. Ctr. Operating Co., Ltd. v. Aetna Life Ins. Co., 
898 F.3d 461, 469
 (5th Cir. 2018) (“In-network providers contract with Aetna to provide 
services at pre-arranged reimbursement rates in exchange for access to Aetna’s members 
as patients.  Out-of-network providers do not; they have no contract with Aetna and instead 
set their own fees for services.”); Weight Loss Healthcare Ctrs. of Am., Inc. v. Off. of Pers. 
Mgmt., 
655 F.3d 1202, 1208
 (10th Cir. 2011) (“Non-participating providers have no 
contract with Blue Cross.”).  GS Labs’ allegations confirm—and plainly do not refute—

the presence of this non-contractual out-of-network relationship here.    
                              IV                                         
    To state a promissory estoppel claim, GS Labs must allege facts plausibly showing 
that (1) a clear and definite promise was made; (2) the promisor intended to induce reliance 
and the promisee in fact relied to its detriment; and (3) the promise must be enforced to 

prevent injustice.  Martens v. Minn. Mining & Mfg. Co., 
616 N.W.2d 732, 746
 (Minn. 
2000).  Promissory estoppel “impl[ies] a contract in law where none exists in fact.”  Grouse 
v. Grp. Health Plan, Inc., 
306 N.W.2d 114, 116
 (Minn. 1981).  “The second element of 
promissory estoppel is satisfied when the promisor should reasonably have expected to 
induce the promisee’s reliance, and the promisee reasonably relies to its detriment.”  

Heffron v. Burlington N. & Santa Fe. Ry. Co., No. A11-2039, 
2012 WL 3262968
, at *4 
(Minn. Ct. App. Aug. 6, 2012); accord Myrlie v. Countrywide Bank, 
775 F. Supp. 2d 1100, 1107
 (D. Minn. 2011).                                                     
    GS Labs’ promissory-estoppel theory is straightforward.  It alleges that Blue Cross 
promised “to pay GS Labs at the cash prices publicly posted on GS Labs’ website, as 

required by the CARES Act, in its email dated March 31, 2021.”  Am. Countercl. ¶ 327.  
GS Labs alleges that it relied on this promise to its detriment when it “filled out the 
registration form requested by Blue Cross[,]” and when it “provided COVID-19 diagnostic 
testing to Blue Cross[] insureds” and billed Blue Cross for those services.  Id. ¶ 329.  And 
GS Labs alleges that “[t]he injustice of Blue Cross’[s] conduct, and that conduct’s unjust 
effects, can be avoided by enforcement of Blue Cross’[s] promise.”  Id. ¶ 332. 

    Though it is a close call, I conclude this claim is plausible.  Whether the statement 
on which GS Labs relies is a “clear and definite promise” seems fairly debatable.  In Blue 
Cross’s favor, the statement includes no mention of the promise’s duration and the author’s 
use of the phrase “at this time” implies obvious hedging.  In GS Labs’ favor, the “at this 
time” phrase might reasonably be understood to apply only to Blue Cross’s unwillingness 

“to negotiate rates” and not to Blue Cross’s commitment to reimburse per GS Labs’ 
website-listed pricing.  The promise to pay “as required by section 3202 of the CARES 
Act” begs the question of what precisely § 3202 required.  But the email thread preceding 
the promise included a link to GS Labs’ website pricing and CPT coding, see ECF No. 38-
2 at 2–3, and the plausible inference is that the promise’s author reviewed that pricing and 

related information on GS Labs’ website before committing to pay “per your pricing as 
listed on GS Labs website[,]” id. at 2.  Regarding the reliance element, Blue Cross has a 
point: GS Labs hasn’t alleged what, if anything, it did differently after receiving Blue 
Cross’s promise.  GS Labs’ theory seems to be that it continued business-as-usual to 
provide diagnostic testing services to Blue Cross insureds.  GS Labs does not allege 
explicitly that it would have stopped providing these services but for Blue Cross’s promise, 

but that seems to be the point.  It makes practical sense that continuing a business 
relationship  based  on  a  promise  plausibly  may  count  as  reliance  for  purposes  of  a 
promissory  estoppel  claim.    No  authority  has  been  cited  that  might  undermine  this 
commonsense notion, and some Minnesota authorities support the understanding that both 
an affirmative change of position and forbearance may show reliance for purposes of a 
promissory estoppel claim.  See Meriwether Minn. Land & Timber, LLC v. State, 
818 N.W.2d 557, 567
 (Minn. Ct. App. 2012) (“The promise must be such that it ‘might 
reasonably induce the promisee’s action or inaction.’”) (emphasis added) (quoting Faimon 
v. Winona State Univ., 
540 N.W.2d 879, 882
 (Minn. Ct. App. 1995), review denied (Minn. 
Feb. 9, 1996)); see also Restatement (Second) of Contracts § 90(1) (Am. L. Inst. 1981).  
Therefore, the promissory estoppel claim survives.                        

                               V                                         
    GS Labs asserts an unjust enrichment claim in Count V.  The Minnesota Supreme 
Court has described the elements of an unjust enrichment claim as follows: 
         To establish an unjust enrichment claim, the claimant must      
         show that the defendant has knowingly received or obtained      
         something of value for which the defendant in equity and good   
         conscience should pay.  [U]njust enrichment claims do not lie   
         simply  because  one  party  benefits  from  the  efforts  or   
         obligations of others, but instead it must be shown that a party 
         was unjustly enriched in the sense that the term unjustly could 
         mean illegally or unlawfully.                                   
Caldas v. Affordable Granite & Stone, Inc., 
820 N.W.2d 826, 838
 (Minn. 2012) (quoting 
ServiceMaster of St. Cloud v. GAB Bus. Servs., Inc., 
544 N.W.2d 302, 306
 (Minn. 1996)); 

see also Klass v. Twin City Fed. Sav. & Loan Ass’n, 
190 N.W.2d 493
, 494–95 (Minn. 
1971) (“Very broadly defined, the [unjust-enrichment] cause of action was described by 
Mr. Justice Mitchell in Brand v. Williams, 
29 Minn. 238, 239
, 
13 N.W. 42
, as one which 
‘can be maintained whenever one man has received or obtained the possession of the 
money of another, which he ought in equity and good conscience to pay over.’”); Cady v. 
Bush, 
166 N.W.2d 358, 361
 (Minn. 1969) (“[T]he theory of unjust enrichment . . . ‘is 

founded on the principle that no one ought unjustly to enrich himself at the expense of 
another, and the gist of the action is that the defendant has received money which in equity 
and good conscience should have been paid to the plaintiff, and under such circumstance 
that he ought, by the ties of natural justice, to pay over.’”) (citation omitted). 
    GS Labs alleges that Blue Cross received value in two ways.  First, GS Labs says 

that it provided diagnostic testing services to Blue Cross members “without prepayment” 
from Blue Cross and that this lack of prepayment “enabled Blue Cross to use its money for 
other purposes, which corresponded to avoidance of the cost of capital for those purposes.”  
Am. Countercl.  ¶ 337.  Second, GS Labs alleges that its services “improved health 
outcomes, which have dramatically reduced Blue Cross’[s] health care spend and the 

spending it would have outlaid in the absence of GS Labs’ testing.”  Id. ¶ 338.  GS Labs 
alleges that “studies have shown that increased availability of rapid COVID-19 testing, 
which is facilitated and made readily accessible by providers like GS Labs, dramatically 
improves patient health outcomes, reduces the spread of the virus, saves lives, and prevents 
and (consequently) reduces Blue Cross’[s] spend.”  Id.  GS Labs’ assertion that Blue 
Cross’s receipt of value was unjust seems derived entirely from its contention that § 3202 

of the CARES Act required Blue Cross to pay.  See id. ¶¶ 343, 348.        
    These allegations do not plausibly show that Blue Cross received something of 
value or, if it did, that the receipt was unjust.  A vendor’s provision of services to an insured 
ordinarily does not enrich the insured’s insurer.  The patient—not the insurer—receives the 
services’ benefits.  See Air Evac EMS Inc. v. USAble Mut. Ins. Co., No. 4:16-CV-00266 
BSM, 
2018 WL 2422314
, at *9 (E.D. Ark. May 29, 2018) (noting that “a number of courts 

have found that medical providers cannot bring unjust enrichment claims against insurers 
because patient-subscribers, and not insurers, are the ones receiving benefits from the 
provider’s services[]” and citing cases), aff’d, 
931 F.3d 647
 (8th Cir. 2019).  And for an 
insurer, claims are expenses, not something of value.  See Travelers Indem. Co. of Conn. 
v. Losco Grp., Inc., 
150 F. Supp. 2d 556, 563
 (S.D.N.Y. 2001) (“The insurance company 

derives no benefit from those services; indeed, what the insurer gets is a ripened obligation 
to pay money on the insured—which hardly can be called a benefit.”).  GS Labs’ second 
theory—that COVID testing prevented the contraction and wider spread of more and more 
serious illness, which in turn saved costs—doesn’t show that Blue Cross was enriched in 
the relevant sense.  According to this theory, those higher costs would have been incurred 

by  countless  individuals,  governmental  units,  health  insurers,  and  non-health-related 
businesses—really, just about everyone.  In other words, in GS Labs’ view, just about 
everyone benefitted from diagnostic testing for COVID.  The problem is that it is difficult 
to understand how a society-wide benefit may be the “something of value” to support an 
unjust-enrichment claim.  The Minnesota Supreme Court’s descriptions of the cause of 
action quoted above seem at least to assume the presence of a more specific benefit, like 

“the money of another” described in Brand, 
29 Minn. at 239
, 
13 N.W. at 42
.  And no 
authority has been cited or identified in our research that might support the idea that 
something as indeterminate as widespread cost reduction might plausibly support an 
unjust-enrichment claim.  Enrichment aside, GS Labs does not allege what made the 
absence of prepayment unjust.  It cannot be § 3202 of the CARES Act.  That would enable 
GS Labs to turn a private-right-of-actionless statute into a common-law claim, something 

Minnesota generally forbids.  See Palmer v. Ill. Farmers Ins. Co., 
666 F.3d 1081, 1087
 
(8th Cir. 2012).  Regardless, § 3202 says nothing about the prepayment of insurance 
benefits.                                                                 
                              VI                                         
    Turn next to GS Labs’ negligence per se claim in Count VI.  “Negligence per se is 

a form of ordinary negligence that results from violation of a statute.”  Anderson v. State, 
Dep’t of Nat. Res., 
693 N.W.2d 181, 189
 (Minn. 2005) (quoting Seim v. Garavalia, 
306 N.W.2d 806, 810
 (Minn. 1981)).  “The only difference [between negligence and negligence 
per se] is that the measure of legal duty for actual negligence is determined upon common-
law principles[,] while the measure of duty for negligence per se is fixed by the statute, so 

that its violation constitutes conclusive evidence of negligence.”  Kronzer v. First Nat’l 
Bank of Minneapolis, 
235 N.W.2d 187, 192
 (Minn. 1975).  Not all statutes or ordinances 
create a tort duty of care.  “‘[T]he negligence per se doctrine . . . is not a magic transforming 
formula that automatically creates a private right of action for the civil enforcement, in tort 
law, of every statute.’”  In re Medtronic, Inc. Sprint Fidelis Leads Prods. Liab. Litig., 
592 F. Supp. 2d 1147, 1163
 (D. Minn. 2009) (quoting Talley v. Danek Med., Inc., 
179 F.3d 154
, 158 (4th Cir. 1999)).  “In other words, the doctrine simply sets the standard of care 
‘where an underlying common law cause of action [already] exists.’”  Id. (quoting Elder v. 
Allstate Ins. Co., 
341 F. Supp. 2d 1095, 1100
 (D. Minn. 2004)).  And Minnesota “ha[s] 
long followed the criteria set forth by the American Law Institute in Restatement, Torts 2d, 
in determining which statutes give rise to a civil duty” such that a violation of the statute 
or ordinance will constitute negligence per se.  Kronzer, 
235 N.W.2d at 193
.  Section 286 

of the Second Restatement of Torts provides:                              
         The court may adopt as the standard of conduct of a reasonable  
         man  the  requirements  of  a  legislative  enactment  or  an   
         administrative  regulation  whose  purpose  is  found  to  be   
         exclusively or in part                                          

         (a) to protect a class of persons which includes the one whose  
           interest is invaded, and                                      

         (b) to protect the particular interest which is invaded, and    

         (c) to protect that interest against the kind of harm which has 
           resulted, and                                                 

         (d) to protect that interest against the particular hazard from 
           which the harm results.                                       

Restatement (Second) of Torts § 286 (Am. L. Inst. 1975).                  
    GS Labs’ negligence per se theory is that Blue Cross “has always owed” providers 
(including GS Labs) “a duty of care of that of an ordinary prudent insurer acting in similar 
circumstances during a public health emergency and viral pandemic.”  Am. Countercl. ¶ 
352.  It alleges that “[t]he CARES Act merely codified this duty owed by an ordinary 
prudent insurer into a statutory standard of care, specifically in the current COVID-19 
pandemic.”  Id. ¶ 354.  And GS Labs alleges that “[t]he CARES Act’s standard of care 

establishes that an ordinary prudent insurer in these circumstances would fully reimburse 
a provider at the publicly-posted cash rate for diagnostic testing in the event there is no 
separately-negotiated rate.”  Id. ¶ 355.                                  
    These allegations do not plausibly show negligence per se.  This is so for purely 
legal reasons.  No authority has been identified supporting the conclusion that a health 
insurer  “has  always  owed”  a  tort-law-created  duty  of  care  in  connection  with  its 

commercial claim reimbursement activities.  GS Labs cites no case creating or identifying 
this duty, whether during a public-health emergency or not.  The case on which it chiefly 
relies, Osborne v. McMasters, concerned a personal injury claim against a drugstore owner 
whose employee “sold to plaintiff’s intestate a deadly poison without labeling it ‘Poison,’ 
as required by statute.”  
41 N.W. 543
 (Minn. 1889).  We don’t have anything like that here.  

Regardless,  if  §  3202  may  be  described  as  addressing  reimbursement  for  COVID 
diagnostic  testing,  it  cannot  possibly  be  described  as  addressing  tort-like  or  extra-
reimbursement harm a provider might incur if it is not reimbursed.  In other words, the 
statute does not protect the particular interest or against the kind of harm that GS Labs 
seeks to vindicate through its negligence per se claim.                   

                              VII                                        
    GS Labs asserts a claim for tortious interference with prospective business relations 
in Count VII.  For this claim to survive a Rule 12(b)(6) motion, GS Labs must allege facts 
plausibly showing five elements:                                          
         (1) The existence of a reasonable expectation of economic       
         advantage; (2) Defendant’s knowledge of that expectation of     
         economic  advantage;  (3)  That  defendant  intentionally       
         interfered with plaintiff’s reasonable expectation of economic  
         advantage,  and  the  intentional  interference  is  either     
         independently tortious or in violation of a state or federal    
         statute or regulation; (4) That in the absence of the wrongful  
         act of defendant, it is reasonably probable that plaintiff would 
         have realized his economic advantage or benefit; and (5) That   
         plaintiff sustained damages.                                    

Gieseke ex rel. Diversified Water Diversion, Inc. v. IDCA, Inc., 
844 N.W.2d 210, 219
 
(Minn. 2014).  To show that an expectation of economic advantage is “reasonable,” a 
plaintiff must “specifically identify a third party with whom the plaintiff had a reasonable 
probability of a future economic relationship.”  
Id. at 221
; see also CH Bus Sales, Inc. v. 
Geiger, No. 18-cv-2444 (SRN/KMM), 
2019 WL 1282110
, at *12 (D. Minn. Mar. 20, 
2019) (dismissing a tortious-interference claim because the plaintiff did not “identify any 
specific customers or business relations it has lost, or may lose, due to [the defendants’] 
conduct”).                                                                
    In support of this claim, GS Labs alleges that it “had a valid and reasonable business 
expectancy and relationship with the ASO plans administered by Blue Cross.”  Am. 
Countercl. ¶ 363.  GS Labs alleges, albeit “[o]n information and belief,” that “Blue Cross 
intentionally interfered with the ASO plans’ reimbursement of claims” GS Labs submitted 
when it “caused the ASO plans to refuse to reimburse” these claims.  
Id.
 ¶¶ 367–68; see 
also 
id. ¶ 370
.  To support the element that the alleged interference be “independently 
tortious or in violation of a state or federal statute or regulation,” Gieseke, 
844 N.W.2d at 219
, GS Labs alleges only that “Blue Cross’[s] interference violated the CARES Act (or, 
alternatively, state law), as set forth herein.”  Id. ¶ 369.              

    These allegations are not sufficient.  GS Labs’ reliance on the CARES Act presents 
a problem with respect to the requirement that “the intentional interference [be] either 
independently tortious or in violation of a state or federal statute or regulation.”  Id.  I’ve 
concluded that § 3202 of that Act creates no private right of action, and in Minnesota, “the 
law is settled that a litigant cannot directly . . . use an alleged violation of [a] statute [lacking 
a private right of action] to prove elements of a common law claim.”  Schermer v. State 

Farm Fire & Cas. Co., 
702 N.W.2d 898, 905
 (Minn. Ct. App. 2005).  GS Labs does not 
identify the alternative state law to support this element.  Therefore, GS Labs has not 
plausibly alleged facts showing that Blue Cross’s alleged interference was tortious in the 
relevant sense.                                                           
                              VIII                                       

    GS Labs asserts a second breach-of-contract theory in Count VIII, this one based on 
an assignment of contract rights.  It alleges that Blue Cross “issue or facilitates” non-
ERISA health insurance plans.  Am. Countercl. ¶ 375.2  GS Labs alleges that, when 
individuals who are insured under these plans receive COVID diagnostic testing from GS 
Labs, “they assign to GS Labs any rights they have under their plans of insurance issued 

or facilitated by Blue Cross.”  Id. ¶ 378.  This assignment “entitles GS Labs to pursue [the 

2    ERISA does not apply to some employee benefit plans, including plans sponsored 
by certain organizations (e.g., governmental plans).  
29 U.S.C. § 1003
(b).  Such plans 
ordinarily are governed by state law.  See, e.g., Hampton v. Standard Ins. Co., 815 Fed. 
App’x 100 (8th Cir. 2020) (Mem.).                                         
insured’s] contractual claims against Blue Cross.”  
Id. ¶ 379
.  Central to this claim, GS 
Labs alleges: “These plans of insurance provide that Blue Cross will provide coverage for 

the full publicly-posted cash price of COVID-19 diagnostic testing because all plans of 
insurance were amended, by operation of law pursuant to FFCRA § 6001 and CARES Act 
§§ 3201–3202, to provide coverage for COVID-19 diagnostic testing.”  Id. ¶ 377. 
    At least as pleaded, this claim doesn’t get past legal problems.  Section 6001 of the 
FFCRA and §§ 3201 and 3202 of the CARES Act do not say their COVID-testing-coverage 
requirements “amend” or are incorporated by reference in non-ERISA health insurance 

policies or plans.  The coverage requirement appears in § 6001(a) of the FFCRA, but § 
6001(b) says that “subsection (a) shall be applied by the” Secretaries of Health and Human 
Services, Labor, and of the Treasury “as if [§6001(a) were] included” in federal statutes 
under the auspices of each agency.  
Pub. L. No. 116-127, §§
 6001(a), (b), 
134 Stat. 178
, 
201–202 (2020).  The statute says nothing about health insurance policies governed by 

state law.  And Minnesota law ordinarily forbids incorporating a statutory duty into an 
insurance policy when the statute creates no private right of action.  Nelson v. Am. Family 
Mut. Ins. Co., 
899 F.3d 475, 480
 (8th Cir. 2018) (citing Palmer, 
666 F.3d at 1086
; 
Burgmeier v. Farm Credit Bank of St. Paul, 
499 N.W.2d 43, 47
 (Minn. Ct. App. 1993)). 
    I’ll grant that the implausibility of this claim may seem somewhat unusual to any 

person familiar with the health-insurance claims process.  Insured patients, their providers, 
and their insurers ordinarily interact just as GS Labs alleges: the insured patient signs an 
assignment-of-benefits form that gives the provider the right to bill the insurer for benefits 
due under the patient’s policy.  If the insurer refuses to pay, the provider (often) sues the 
insurer for the benefits.  Depending on the nature of the plan, that suit will be governed by 
state law or ERISA.  To be clear, GS Labs’ assignment-based contract claim here is 

different.  The claim relies—not on the terms in each of its patient’s insurance contracts or 
plans—but  on  a  theory  that  a  contract  term  essential  to  GS  Labs’  claim  has  been 
incorporated into each patient’s insurance contract.  I think this theory is legally flawed 
(and therefore implausible) because (1) the federal statutes that are the claim’s source do 
not include incorporation language—that is, they do not say that the requirement to cover 
COVID-19 diagnostic testing is incorporated into contracts governed by state law, and (2) 

I’ve already determined that the relevant FFCRA and CARES Act provisions contain no 
private right of action, and Minnesota law doesn’t permit an incorporation theory to 
end-run this problem.                                                     
                              IX                                         
    In Count IX, GS Labs asserts a claim under ERISA’s civil enforcement provision, 

29 U.S.C. § 1132
.  Specifically, it asserts a claim under § 1132(a)(1), which authorizes “a 
participant or beneficiary” to bring a civil action “to recover benefits due to him under the 
terms of his plan, to enforce his rights under the terms of the plan, or to clarify his rights to 
future benefits under the terms of the plan.”  
29 U.S.C. § 1132
(a)(1)(B).  And it asserts a 
claim under § 1132(a)(3), which authorizes “a participant, beneficiary, or fiduciary (A) to 

enjoin any act or practice which violates any provision of this subchapter or the terms of 
the plan, or (B) to obtain other appropriate equitable relief (i) to redress such violations or 
(ii) to enforce any provisions of this subchapter or the terms of the plan.”  
29 U.S.C. § 1132
(a)(3).                                                               
    GS Labs’ ERISA theories essentially track its assignment-based breach-of-contract 
claim.  It alleges that  “Blue Cross issues or facilitates” ERISA-governed health insurance 

plans.  Am. Countercl. ¶ 384.  It alleges that, when individuals who are insured under these 
plans receive COVID diagnostic testing from GS Labs, “they assign to GS Labs any rights 
they have under their plans of insurance issued or facilitated by Blue Cross.”  
Id. ¶ 387
.  
This assignment “entitles GS Labs to pursue [the insured’s] statutory claims, such as those 
under ERISA § 502, against Blue Cross.”  Id. ¶ 388.  Again, central to this claim, GS Labs 
alleges: “These plans of insurance provide that Blue Cross will provide coverage for the 

full  publicly-posted  cash  price  of  COVID-19  diagnostic  testing  because  all  plans  of 
insurance were amended, by operation of law pursuant to FFCRA § 6001 and CARES Act 
§§ 3201–3202, to provide coverage for COVID-19 diagnostic testing.”  Id. ¶ 386.  GS Labs 
seeks “benefits due” under § 1132(a)(1)(B), and to “to enjoin Blue Cross’[s] act and 
practice of failing to fully reimburse for COVID-19 diagnostic testing” under § 1132(a)(3).  

Id. ¶¶ 390–91.                                                            
    The starting point is determining whether the law might permit a provider like GS 
Labs to assert these claims.  The primary issue is whether § 3202(a)’s requirement that, 
absent a negotiated rate, Blue Cross “shall reimburse” GS Labs at its website-listed cash 
price is enforceable under ERISA’s civil enforcement provision.  Based on a review of the 

relevant, intertwined statutes, I conclude it is.  But this conclusion is neither obvious nor 
inarguable.                                                               
    Begin with § 6001(a) of the FFCRA.  It requires group health plans and health 
insurance issuers to provide coverage for COVID-19 diagnostic testing without imposing 
“any cost sharing (including deductibles, copayments, and coinsurance) requirements or 
prior authorization or other medical management requirements.”  
Pub. L. No. 116-127, § 6001
(a), 
134 Stat. 178
, 201–202 (2020).  Section 6001(a), in other words, imposes a 
coverage requirement; it says Blue Cross had to cover COVID-19 diagnostic services 
without cost-sharing by plan participants.  Section 6001(b) of the FFCRA says, in turn, that 
this  coverage-without-cost-sharing  requirement  “shall  be  applied”  by  the  responsible 
agency heads “as if included” in various federal laws, including by the Secretary of Labor 
as if included in “part 7” of ERISA.   
Id.
 § 6001(b).  If § 6001(a)’s coverage requirement 

is deemed included in part 7 of ERISA as § 6001(b) seems to direct, then there is no 
question a plan or insurer’s failure to comply with this coverage-without-cost-sharing 
requirement is subject to challenge under ERISA’s civil enforcement provision.  Section 
1132(a)(3) allows “a participant, beneficiary, or fiduciary” to bring a civil action “to 
enjoin” or “to obtain other appropriate equitable relief” with respect to violations “of “this 

subchapter.”  
29 U.S.C. § 1132
(a)(3).  ERISA’s civil enforcement provision appears in part 
5 of subchapter I; part 7 and its requirements for group health plans also appears in 
subchapter I.  See 29 U.S.C.A. §§ 1161–1500 (vol.) at 3–5 (table of contents). 
    GS Labs’ ERISA claims in Count IX go beyond seeking just coverage for its 
services; it also seeks payment at the cash price it listed on its website.  GS Labs seeks 

enforcement of the “shall reimburse” requirement in § 3202(a) of the CARES Act: “If the 
health plan or issuer does not have a negotiated rate with such provider, such plan or issuer 
shall reimburse the provider in an amount that equals the cash price for such service as 
listed by the provider on a public internet website.”  
Pub. L. No. 116-136, § 3202
(a)(1), 
134 Stat. 281
, 367 (2020).  For essentially two reasons, I conclude that § 3202(a)’s cash-
price reimbursement requirement may be enforced through ERISA’s civil enforcement 

provision.  The first is textual.  I understand § 3202(a)’s cross-reference to § 6001(a) of the 
FFCRA to incorporate that statute’s directive that its provisions be applied “as if included” 
in part 7 of ERISA.  As explained in the preceding paragraph, the inclusion of § 3202(a)’s 
reimbursement requirement in part 7 of ERISA means the requirement could be the subject 
of an action under 
29 U.S.C. § 1132
(a).  The second reason is practical.  It is difficult to 
understand how § 6001(a)’s requirement that coverage be provided without “any cost 

sharing . . . requirements” could be enforced by a plan participant without considering, and 
likely litigating, the price a health plan or health insurance issuer pays for the diagnostic 
testing.3  It helps that these conclusions are consistent with the result reached by the only 
other court to have considered this particular issue, though that court approached the 
question somewhat differently.  See Open MRI and Imaging of RP Vestibular Diagnostics, 

P.A. v. Cigna Health and Life Ins. Co., Civ. No. 20-10345 (KM) (ESK), 
2022 WL 1567797
, 
at *3–6 (D.N.J. May 18, 2022).                                            



3    Consider a hypothetical: Patient A participates in a Blue Cross-insured ERISA plan.  
Patient A experiences typical COVID symptoms and decides to get tested.  Patient A goes 
to a GS Labs facility for the test.  Rather than assign her benefits to GS Labs, Patient A 
pays cash and then submits the receipt to Blue Cross for coverage.  Blue Cross pays Patient 
A only a portion of what Patient A paid GS Labs, claiming that GS Labs’ charge did not 
equal the cash price for such service as listed by GS Labs on a public internet website.  In 
that  situation,  whether  Blue  Cross  imposed  a  cost-sharing  requirement  would  seem 
inextricably intertwined with the reimbursement/cash-price question.      
    Having determined that the law might permit a provider like GS Labs to assert these 
claims, the next question is whether GS Labs has alleged facts plausibly showing its 

entitlement to the relief it seeks.  Recall that GS Labs alleges that, when it provides testing 
services to ERISA plan participants insured by Blue Cross, the participants “assign to GS 
Labs any rights they have under their plans of insurance issued or facilitated by Blue Cross, 
including any rights these patients have under ERISA.”  Am. Countercl. ¶ 387.  Blue Cross 
argues that, even if legally permissible, GS Labs’ ERISA claims in Count IX are factually 
implausible for three reasons.                                            

    First, Blue Cross argues that its plans uniformly include anti-assignment provisions 
that render GS Labs’ alleged assignments ineffective, and Blue Cross has filed with its 
motion one page from one of its plans that includes “anti-assignment language that is 
standard across [Blue Cross’s] fully insured plans.”  ECF No. 38 ¶ 5; ECF No. 38-4.  This 
argument is not persuasive in this procedural context.  Though no case has been cited 

addressing  this  specific  question,  whether,  and  the  extent  to  which,  anti-assignment 
provisions  might  render  GS  Labs’  alleged  assignments  ineffective  seems  like  an 
affirmative defense that Blue Cross bears the burden to plead and prove.  Defense, Black’s 
Law Dictionary (11th ed. 2019).  For an affirmative defense to justify a Rule 12(b)(6) 
dismissal of a complaint, “the applicability of the defense has to be clearly indicated and 

must appear on the face of the pleading to be used as the basis for the motion.”  5B Charles 
Alan Wright, Arthur R. Miller & Mary Kay Kane, Federal Practice and Procedure: Civil 
§  1357  (3d  ed.  &  Apr.  2022  Update)  (footnotes  omitted).    GS  Labs’  Amended 
Counterclaim  does  not  include  allegations  establishing  either  the  presence  of  anti-
assignment provisions in the at-issue plans and policies or a showing that those anti-
assignment provisions bar its claims under ERISA’s civil enforcement provision.4 

    Second,  Blue  Cross  argues  that  GS  Labs  failed  to  exhaust  its  administrative 
remedies before bringing suit.  An ERISA plaintiff must exhaust available administrative 
remedies.  Angevine v. Anheuser-Busch Cos. Pension Plan, 
646 F.3d 1034, 1037
 (8th Cir. 
2011).  The exhaustion requirement is excused “only when pursuing an administrative 
remedy would be futile or there is no administrative remedy to pursue.”  
Id.
  The exhaustion 

requirement is not an affirmative defense.  As the Eighth Circuit has explained: “Our case 
law is clear that [an ERISA plaintiff’s] claim can proceed only if he has pled sufficient 
facts to show either futility or lack of administrative remedy.”  
Id. at 1038
; see also J.P. v. 
BCBSM, Inc., No. 18-cv-3472 (MJD/DTS), 
2020 WL 7626655
, at *3 (D. Minn. Feb. 24, 
2020) (recognizing in an ERISA benefits claim that “although Plaintiffs bear no burden of 

production on a motion to dismiss, this Court must still consider whether the Amended 
Complaint—and any documents embraced by it—shows either exhaustion or an exception 

4    To support its anti-assignment argument, Blue Cross filed “a true and correct 
excerpt of a [Blue Cross] fully insured plan . . . setting forth anti-assignment language that 
is standard across [Blue Cross’s] fully insured plans.”  ECF No. 38 ¶ 5; ECF No. 38-4.  In 
a more typical ERISA benefits dispute, it would be appropriate to consider the entire 
at-issue  plan’s  terms,  including  any  anti-assignment  provision,  because  such  terms 
ordinarily are embraced by the pleadings.  See, e.g., Karg v. Transamerica Corp., No. 
18-CV-134-CJW-KEM, 
2019 WL 3938471
, at *1 n.1 (N.D. Iowa Aug. 20, 2019) (“An 
ERISA plan document is necessarily embraced by the pleadings when the complaint 
specifically mentions the plan under which a plaintiff’s ERISA claims arose.”).  This isn’t 
that  kind  of  case.    GS  Labs  does  not  identify  the  at-issue  plans  in  its  Amended 
Counterclaim, and its allegations imply there are many at-issue plans.  And accepting Blue 
Cross’s argument requires, in turn, accepting its factual assertion that the exemplary 
anti-assignment provision it filed (or an equivalent term) is in every at-issue plan.  Going 
that route would not be faithful to Rule 12(b)(6).                        
thereto”), report and recommendation adopted, 
2020 WL 1442683
 (D. Minn. Mar. 24, 
2020).   “The futility exception is narrow—the plan participant must show that it is certain 

that her claim will be denied on appeal, not merely that she doubts that an appeal will result 
in a different decision.”  Brown v. J.B. Hunt Transp. Servs., Inc., 
586 F.3d 1079, 1085
 (8th 
Cir.  2009)  (cleaned  up).    GS  Labs  plausibly  alleges  exhaustion  would  be  futile.  
Specifically, it alleges that Blue Cross’s pre-litigation position, “its refusals to reimburse 
GS Labs in response to GS Labs’ repeated requests for reimbursement, and its pleadings 
and claims in this action,” show that “it is certain that Blue Cross would refuse to fully 

reimburse GS Labs if GS Labs pursued the administrative remedies set out in the plans.”  
Am. Countercl. ¶ 70.  This allegation may be short and plain, see Fed. R. Civ. P. 8(a)(2), 
but is neither speculative nor conclusory.  It relies on Blue Cross’s well-documented view 
of GS Labs’ services and Blue Cross’s allegations and claims in this case to show that, if 
GS Labs had filed administrative claims, they would certainly have been denied.  That 

inference is plausible.                                                   
    Third, Blue Cross argues that GS Labs lacks statutory standing to assert a claim for 
equitable relief under 
29 U.S.C. § 1132
(a)(3).  The gist of Blue Cross’s position is that the 
assignments GS Labs alleges it received from individuals who participated in plans insured 
or administered by Blue Cross gave GS Labs at most the right to sue for benefits.  “[T]o 

have the right to seek equitable relief under ERISA, a party must either be a participant, 
beneficiary, or fiduciary, or the assignee of a participant, beneficiary, or fiduciary.”  Air 
Evac EMS, Inc. v. USAble Mut. Ins. Co., 
931 F.3d 647, 650
 (8th Cir. 2019).  In Air Evac 
EMS, the Eighth Circuit determined that an assignment obtained by the provider (Air Evac 
EMS) did not include ERISA claims for equitable relief, and the court’s analysis of the 
issue is worth repeating here:                                            

         More important than general statements as to liberal or narrow  
         constructions, however, is the fact that our job is to interpret 
         the express language of the assignment in the context in which  
         it was made.  When Arkansas Blue plan members assigned          
         their rights to Air Evac, they did so in the context of facilitating 
         payment for Air Evac’s past provision of services.  Thus, when  
         Arkansas  Blue  plan  members  assigned  “all  rights  to  (and 
         related or associated with) any benefit claims” to Air Evac, its 
         [sic] seems clear, at a minimum, that they assigned Air Evac    
         the right to recover benefits under § 1132(a)(1)(B).  Given the 
         context of the assignment, however, it does not automatically   
         follow that such language also conveyed the right to sue for    
         reformation of plan terms and other equitable relief under §    
         1132(a)(3).    Indeed,  the  assignment  does  not  specifically 
         mention the right to sue for equitable relief; rather it limits the 
         rights conveyed to those “related or associated with . . . benefit 
         claims and/or payments due  from  any  third-party  payor.”     
         (Emphasis added).  Moreover, the rights that are specifically   
         mentioned—“the  rights  to  pursue administrative  claims,      
         request documents, receive payment and pursue litigation in     
         order to obtain payment” (emphasis added)—all suggest that      
         Air  Evac  sought  assignment  of  ERISA  rights  related  to   
         obtaining  payment,  not  equitable  relief.    Accordingly,  we 
         conclude that Air Evac’s assignment does not convey the right   
         to sue for equitable relief under § 1132(a)(3).                 

Id. at 651.  The assignments GS Labs alleges it obtained do not mention the right to sue for 
equitable relief and seem a lot narrower than the assignment at issue in Air Evac EMS.  GS 
Labs alleges: “Patients in Minnesota assign their rights under their respective plans of 
insurance (including those issued by Blue Cross) to GS Labs by agreeing to the following 
terms in scheduling an appointment with GS Labs: ‘I assign to GS Labs all rights and 
claims for the medical benefits to which I am entitled for the services provided.’”  Am. 
Countercl. ¶ 67 (emphasis added).  Under Air Evac EMS, this assignment does not convey 
to GS Labs the right to sue for equitable relief under § 1132(a)(3).      

                               X                                         
    GS Labs asserts a false-advertising claim under the Lanham Act, 
15 U.S.C. § 1125
(a).  Under the Lanham Act:                                           
         Any person who, . . . in connection with any goods or services, 
         . . . uses in commerce any . . . false or misleading description 
         of fact, or false or misleading representation of fact, which . . . 
         in  commercial  advertising  or  promotion,  misrepresents  the 
         nature, characteristics, [or] qualities . . . of his or her . . . goods, 
         services, or commercial activities . . . shall be liable in a civil 
         action by any person who believes that he or she is likely to be 
         damaged by such act.                                            

15 U.S.C. § 1125
(a)(1)(B).  The Act’s purpose is “to protect persons engaged in commerce 
against false advertising and unfair competition.”  Am. Italian Pasta Co. v. New World 
Pasta Co., 
371 F.3d 387, 390
 (8th Cir. 2004) (quoting United Indus. Corp. v. Clorox Co., 
140 F.3d 1175, 1179
 (8th Cir. 1998)).                                     
    The Eighth Circuit has distilled this statutory text into five elements that a plaintiff 
must prove to establish a false-advertising claim:                        
         (1) a false statement of fact by the defendant in a commercial  
         advertisement  about  its  own  or  another’s  product;  (2)  the 
         statement actually deceived or has the tendency to deceive a    
         substantial  segment  of  its  audience;  (3)  the  deception  is 
         material, in that it is likely to influence the purchasing decision; 
         (4) the defendant caused its false statement to enter interstate 
         commerce; and (5) the plaintiff has been or is likely to be     
         injured  as  a  result  of  the  false  statement,  either  by  direct 
         diversion of sales from itself to defendant or by a loss of     
         goodwill associated with its products.                          
United Indus. Corp., 
140 F.3d at 1180
.  A plaintiff’s failure to demonstrate any one of the 
five elements is fatal to its claim.  Allsup, Inc. v. Advantage 2000 Consultants Inc., 
428 F.3d 1135, 1138
 (8th Cir. 2005).                                               
    GS  Labs  alleges  that  Blue  Cross  made  essentially  five  false  or  misleading 
statements.  First, it alleges that “Blue Cross falsely stated that only ‘medically necessary’ 
and ‘appropriate’ COVID-19 diagnostic testing is covered by insurance.”  Am. Countercl. 
¶ 94.  Second, GS Labs alleges that “Blue Cross has falsely stated or implied that there may 
be coverage differences with respect to COVID-19 diagnostic testing provided by ‘in-

network’  or  ‘participating’  providers  versus  ‘out-of-network’  or  ‘non-participating’ 
providers.”  Id. ¶ 97.  Third, GS Labs alleges that “Blue Cross has falsely stated that patients 
may have to share the cost of COVID-19 diagnostic testing, in proximity to statements 
about medical necessity.”  Id. ¶ 100.  Fourth, it alleges that “Blue Cross has falsely implied 
that it may impose prior authorization requirements on coverage for COVID-19 diagnostic 

testing.”  Id. ¶ 103.  Fifth, GS Labs alleges that “Blue Cross omitted information [from] its 
public statements that created the false impression that COVID-19 diagnostic testing 
provided by out-of-network or non-participating providers is not covered.”  Id. ¶ 106. 
    GS Labs says that statements falling in each of these categories are false for 
essentially the same reason: they contradict § 6001(a) of the FFCRA and §§ 3201 and 3202 

of the CARES Act to the extent those statutes require a health insurance issuer to cover 
COVID-19 diagnostic testing without cost-sharing or prior authorization or other medical 
management requirements and regardless of whether the provider is out-of-network.  See 
id. ¶¶ 96, 102, 105, 108.  GS Labs alleges that consumers have relied on these statements 
and  “have  either  avoided  testing  altogether  or  chosen  to  obtain  testing  from  certain 
providers over others, such as those that are ‘in-network’ or ‘participating,’[] to the 

exclusion of GS Labs.”  Id. ¶ 109.  The resulting consumer decisions, GS Labs alleges, 
“have harmed patient choice, risked the public health, and resulted in reduced diagnostic 
testing at GS Labs.”  Id. ¶ 110.                                          
    The parties’ first disagreement concerns whether the Amended Counterclaim’s 
false-advertising allegations comply with Federal Rule of Civil Procedure 9(b).  Blue Cross 
says it does not.  GS Labs says it does.  Assuming Rule 9(b) applies, I conclude the 

Amended Counterclaim satisfies it.5  “In alleging fraud or mistake, a party must state with 
particularity the circumstances constituting fraud or mistake.”  Fed. R. Civ. P. 9(b).  “To 
satisfy the particularity requirement of Rule 9(b), the complaint must plead such facts as 
the time, place, and content of the defendant’s false representations, as well as the details 
of the defendant’s fraudulent acts, including when the acts occurred, who engaged in them, 

and what was obtained as a result.”  U.S. ex rel. Joshi v. St. Luke’s Hosp., Inc., 
441 F.3d 552, 556
 (8th Cir. 2006); see Streambend Props. II, LLC v. Ivy Tower Minneapolis, LLC, 
781 F.3d 1003, 1013
 (8th Cir. 2015) (same).  “The claim must identify who, what, where, 
when, and how.”  U.S. ex rel. Costner v. United States, 
317 F.3d 883, 888
 (8th Cir. 2003). 


5    “Courts are divided on the issue of whether Rule 9(b) applies to Lanham Act claims 
that are grounded in fraud.”  N. Bottling Co., Inc. v. Henry’s Foods, Inc., 
474 F. Supp. 3d 1016
, 1028 (D.N.D. 2020) (citing  Nestle Purina PetCare Co. v. Blue Buffalo Co., No. 4:14 
CV 859 RWS, 
2015 WL 1782661
, at *8 (E.D. Mo. Apr. 20, 2015)); see also Wing Enters., 
Inc. v. Tricam Indus., Inc., No. 20-cv-2497 (SRN/ECW), 
2021 WL 3620272
, at *13 (D. 
Minn. Aug. 16, 2021) (citing numerous District of Minnesota cases applying Rule 9(b) to 
Lanham Act and state-law false-advertising claims).                       
While Rule 9(b) requires particularity in pleading, “a complaint need not be filled with 
precise detail.”  Moua v. Jani-King of Minn., Inc., 
613 F. Supp. 2d 1103, 1110
 (D. Minn. 

2009).  Rather, “Rule 9(b) is to be read in the context of the general principles of the Federal 
Rules, the purpose of which is to simplify pleading.  Thus, the particularity required by 
Rule 9(b) is intended to enable the defendant to respond specifically and quickly to the 
potentially damaging allegations.”  Costner, 
317 F.3d at 888
.  “The level of particularity 
required depends on the nature of a case,” E-Shops Corp. v. U.S. Bank Nat’l Ass’n, 
678 F.3d 659, 663
 (8th Cir. 2012), and to determine whether a party has satisfied Rule 9(b), 

courts  look  to  “the  complexity  or  simplicity  of  the  transaction  or  occurrence,  the 
relationship of the parties and the determination of how much circumstantial detail is 
necessary to give notice to the adverse party and enable him to prepare a responsive 
pleading,” Payne v. United States, 
247 F.2d 481, 486
 (8th Cir. 1957) (citation omitted). 
    The  Amended  Counterclaim’s  Lanham  Act  allegations  meet  Rule  9(b)’s 

particularity requirement.  These allegations quote numerous statements allegedly made by 
Blue Cross, easily satisfying the “who” and “what” elements.  The Amended Counterclaim 
is less specific about when, where, and how Blue Cross allegedly made these statements.  
As to when, the pleading provides a series of “no later than” dates.  For example, it alleges 
that “some” statements falling in the first category were made “no later than March 2020.”  

Am. Countercl. ¶ 95.  As to where and how, the pleading provides only examples: “written 
materials such as [Blue Cross’s] website, circulars, and brochures.”  Id. ¶ 92.  The gaps 
these allegations leave might be a problem in another case.  Here, they seem easily fillable 
considering that the statements on which the claim relies are quoted at length.  As a 
practical matter, that should make it feasible for Blue Cross to undertake a relatively 
straightforward, non-burdensome search and fill these gaps.  In other words, in the unique 

circumstances of this case, the Amended Counterclaim’s Lanham Act allegations give Blue 
Cross the notice Rule 9(b) requires.                                      
    Blue Cross next challenges whether the statements GS Labs identifies to support its 
Lanham Act claim are “in a commercial advertisement.”  United Indus. Corp., 
140 F.3d at 1180
.    The  widely  applied  test  for  determining  whether  a  statement  is  commercial 
advertising under the Lanham Act is as follows:                           

         In  order  for  representations  to  constitute  “commercial    
         advertising  or  promotion”  under  Section  43(a)(1)(B),  they 
         must be: (1) commercial speech; (2) by a defendant who is in    
         commercial competition with plaintiff; (3) for the purpose of   
         influencing consumers to buy defendant’s goods or services.     
         While  the  representations  need  not  be  made  in  a  “classic 
         advertising  campaign,”  but  may  consist  instead  of  more   
         informal types of “promotion,” the representations (4) must be  
         disseminated sufficiently to the relevant purchasing public to  
         constitute “advertising” or “promotion” within that industry.   

Gordon & Breach Sci. Publishers S.A. v. Am. Inst. of Physics, 
859 F. Supp. 1521
, 1535–
36 (S.D.N.Y. 1994).6  Other judges in this District have applied the Gordon & Breach test, 
or at least parts of it, often.  See, e.g., Am. Achievement Corp. v. Jostens, Inc., --- F. Supp. 
3d ---, No. 21-cv-2613 (NEB/BRT), 
2022 WL 3566862
, at *13 (D. Minn. Aug. 18, 2022); 
Select Comfort Corp. v. Tempur Sealy Int’l, Inc., 
988 F. Supp. 2d 1047
, 1052–53 (D. Minn. 

6    In Fashion Boutique of Short Hills, Inc. v. Fendi USA, Inc., the Second Circuit 
adopted the first, third, and fourth elements of the Gordon & Breach test.  
314 F.3d 48, 58
 
(2d Cir. 2002).  It did not address the second element, but “note[d] that the requirement 
[that defendant and plaintiff be competitors] is not set forth in the text of Section 43(a).”  
Id.                                                                       
2013); Auto-Chlor Sys. of Minn., Inc. v. JohnsonDiversey, 
328 F. Supp. 2d 980, 1018
 (D. 
Minn.  2004);  Aviation  Charter,  Inc.  v.  Aviation  Rsch.  Grp./US,  No.  03-cv-2439 

(PAM/RLE), 
2004 WL 1638176
, at *5 (D. Minn. July 10, 2004), aff'd sub nom. Aviation 
Charter, Inc. v. Aviation Rsch. Grp./US, 
416 F.3d 864
 (8th Cir. 2005); Grp. Health Plan, 
Inc. v. Philip Morris, Inc., 
68 F. Supp. 2d 1064
, 1069–70 (D. Minn. 1999); and Med. 
Graphics Corp. v. SensorMedics Corp., 
872 F. Supp. 643, 650
 (D. Minn. 1994).  Though 
the Eighth Circuit has neither formally adopted nor explicitly applied the Gordon & Breach 
test in full, it applied the test’s fourth element in Porous Media Corp. v. Pall Corp., 
173 F.3d 1109, 1121
 (8th Cir. 1999), citing as support a Fifth Circuit case, Seven–Up Co. v. 
Coca–Cola Co., that applied all four of the test’s factors and declared the test “to be both 
accurate and sound.”  
86 F.3d 1379, 1384
 (5th Cir. 1996).  The bottom line is that it makes 
good sense to apply the Gordon & Breach test here.                        
    The Amended Counterclaim lacks allegations plausibly meeting this test—or, in 

other words, showing that the at-issue statements were in a commercial advertisement.  No 
allegations address whether Blue Cross is in competition with GS Labs.  It would seem 
strange to say they are.  Blue Cross, as the Amended Counterclaim describes it, is a health 
insurer and administrator of self-funded health insurance plans.  No allegation suggests 
that GS Labs competes in that market.  GS Labs is a clinical lab.  No allegation suggests 

that Blue Cross competes in that market.  The Amended Counterclaim also includes no 
allegation suggesting that the many Blue Cross statements it quotes were made for the 
purpose of influencing customers to purchase Blue Cross’s insurance products or services.  
The absence of such allegations is a problem by itself, but there is more.  A careful review 
of the statements and GS Labs’ related allegations permits at most the plausible inference 
that the statements were intended to inform Blue Cross customers and providers of the 

extent of existing COVID-19 diagnostic testing coverage under health insurance policies 
and plans  issued  or administered  by  Blue  Cross.    Consider,  for  example,  GS  Labs’ 
allegation that “consumers and referring physicians rely upon Blue Cross as a source for 
truthful information about healthcare coverage under both Blue Cross plans of insurance 
and the law generally.”  Am. Countercl. ¶ 93.  This allegation plausibly describes how the 
at-issue statements served informational purposes; it does not plausibly allege that the 

statements were made for the purpose of influencing consumers to buy Blue Cross’s 
insurance  or  services.    Finally,  the  Amended  Counterclaim  includes  no  allegations 
plausibly showing whether the statements, or any of them, were disseminated sufficiently 
to the relevant purchasing public.  It is true that some statements—like those alleged to 
have been available via Blue Cross’s website—may have been widely available.  But 

without knowing more, that inference cannot plausibly be made with respect to many of 
the other at-issue statements.  Regardless, GS Labs alleges no facts concerning the identity 
or  scope  of  the  relevant  purchasing  public.    Because  the  Amended  Counterclaim’s 
allegations do not plausibly show that the identified statements were in a commercial 
advertisement, GS Labs’ Lanham Act claim must be dismissed.               

                              XI                                         
    In  Count  XI,  GS  Labs  asserts  a  claim  under  the  Minnesota  Deceptive  Trade 
Practices Act, Minn. Stat. § 325D.44.  It is settled that the Deceptive Trade Practices Act 
“mirrors” the Lanham Act, and courts therefore “use the same analysis to evaluate false 
advertising claims that are made simultaneously under the federal and state statutes.”  Med. 
Graphics, 
872 F. Supp. at 649
; accord Aviva Sports, Inc. v. Fingerhut Direct Mktg., Inc., 

829 F. Supp. 2d 802
, 809 n.7 (D. Minn. 2011); see Buetow v. A.L.S. Enters., Inc., 
650 F.3d 1178, 1183
 (8th Cir. 2011) (recognizing that “[w]hen a commercial plaintiff asserted 
pendent state law claims under these Minnesota statutes in a Lanham Act” case, the state 
claims “are coextensive with the federal claims.” (quotation omitted)).  There is no question 
here that GS Labs’ Lanham Act and Deceptive Trade Practices Act claims are identical—
or, “simultaneous” to borrow from Med. Graphics Corp.  GS Labs does not quarrel with 

the idea that, as its Lanham Act claim goes, so goes its claim under the Deceptive Trade 
Practices Act.  This claim will therefore be dismissed.                   
                               XII                                       
    In Count XII, GS Labs asserts the same false advertising allegations that supported 
its Lanham Act claim to advance a claim under the Minnesota Consumer Fraud Act, Minn. 

Stat. § 325F.69, subdiv. 1.  See Am. Countercl. ¶¶ 409–413.  As with Count XI, Blue Cross 
says this claim shares the analysis—and falls—with GS Labs’ Lanham Act claim.  See 
Buetow, 
650 F.3d at 1183
; Alternative Pioneering Sys., Inc. v. Direct Innovative Prods., 
Inc., 
822 F. Supp. 1437, 1441
 (D. Minn. 1993).  And as with Count XI, GS Labs does not 
dispute the point.  Count XII will therefore also be dismissed based on the analysis of Count 

X.                                                                        
                              XIII                                       
    GS Labs asserts a series of antitrust claims, beginning with Count XIII.  In this 
Count, it alleges a per se violation of § 1 of the Sherman Act.  Am. Countercl. at 167 (Count 
XIII heading).  Section 1 of the Sherman Act prohibits “[e]very contract, combination in 
the form of trust or otherwise, or conspiracy, in restraint of trade.”  
15 U.S.C. § 1
.  

“Twombly, which also involved a claim under § 1 of the Sherman Act, makes clear that a 
conclusory allegation of conspiracy does not suffice.”  Uhr v. Responsible Hospitality Inst., 
Inc., No. 10-cv-4945 (PJS/TNL), 
2011 WL 4091866
, at *7 (D. Minn. Sept. 14, 2011).  
“[S]tating such a claim requires a complaint with enough factual matter (taken as true) to 
suggest that an agreement was made.”  Twombly, 
550 U.S. at 556
.  “[I]ndependent 
allegation[s] of actual agreement”—in other words, allegations of direct evidence of an 

agreement—suffice  provided  they  are  factually  plausible  and  not  “merely  legal 
conclusions.”  
Id. at 564
.  “[A]n allegation of parallel conduct and a bare assertion of 
conspiracy will not suffice.”  
Id. at 556
.  “[W]hen allegations of parallel conduct are set 
out in order to make a § 1 claim, they must be placed in a context that raises a suggestion 
of  a  preceding  agreement,  not  merely  parallel  conduct  that  could  just  as  well  be 

independent action.”  Id. at 557.  In particular, a § 1 plaintiff who relies on allegations of 
parallel conduct must allege that “certain ‘plus factors’ exist.”  Blomkest Fertilizer, Inc. v. 
Potash Corp. of Sask., Inc., 
203 F.3d 1028
, 1033 (8th Cir. 2000) (en banc).  Examples of 
plus factors “may include: a common motive to conspire, evidence that shows that the 
parallel acts were against the apparent individual economic self-interest of the alleged 

conspirators, and evidence of a high level of interfirm communications.”  Alaska Dep’t of 
Revenue, Treasury Div. v. Manku, No. 20-1759-cv, 
2021 WL 3027170
, at *3 (2d Cir. July 
19, 2021) (citation and quotations omitted).  Conspiracy allegations are implausible when 
there exists an “obvious alternative explanation” for the defendant’s conduct that the 
complaint does not plausibly undermine.  Twombly, 
550 U.S. at 567
; see also McDonough 
v. Anoka Cnty., 
799 F.3d 931, 946
 (8th Cir. 2015).  Conspiracy allegations also do not pass 

Rule 12(b)(6) when they suggest competition at least as plausibly as a conspiracy.  In re 
Elevator Antitrust Litig., 
502 F.3d 47, 51
 (2d Cir. 2007).                
    Begin with a summary of GS Labs’ § 1 theory: GS Labs alleges that Blue Cross 
conspired with other, unnamed BCBS affiliates to “carry[] out a buyer’s cartel to boycott 
GS Labs, depress reimbursement rates, and compromise its viability as a competitor[,]” 
presumably vis-à-vis other clinical labs.  Am. Countercl. ¶ 116.  GS Labs alleges that Blue 

Cross’s concerted activity “artificially depress[es] prices to non-competitive levels in a 
commercial  insurance  market  for  lab-based  COVID-19  testing  services  and  causing 
shortages in the COVID-19 diagnostic testing market.”  Id. ¶ 118.  GS Labs alleges that 
Blue Cross “has a strong incentive to coordinate with other [unnamed] dominant affiliated 
BCBS insurers in their rate negotiations and buying strategies for COVID-19 diagnostic 

testing  services,  and  to  do  so  in  a  manner  that  depresses  output  and  eliminates 
competition.”  Id. ¶ 173.  It alleges that Blue Cross has opportunities to conspire with other 
BCBS affiliates through a national trade association, American Health Insurance Plans (or 
“AHIP”), and through existing commercial relationships with other BCBS affiliates.  See 
id. ¶¶ 172–198.  In particular, it alleges that AHIP’s publication of articles showing price 

gouging  among  COVID-19  diagnostic  testing  businesses  “was  a  call  to  arms  for 
commercial insurers: a signal to collectively go on the offensive against COVID-19 
diagnostic testing providers such as GS Labs in their negotiations over rates and other 
business dealings.”  Id. ¶ 196.  GS Labs alleges five “plus factors” to support its allegations 
of parallel conduct: (1) “Blue Cross and its BCBS affiliates all boycotted GS Labs by 
refusing to pay it around the same time, consistent with AHIP’s signal.”  Id. ¶ 199.  (2) 

“Blue Cross and BCBS affiliates adopted the very same language and positions as one 
another in their dealings with GS Labs, accusing it of ‘price gouging’ and proposing 
payment at levels below GS Labs’ operating costs.”  Id. ¶ 200.  (3) “Blue Cross and 
numerous BCBS affiliates all offered identical pretexts for their refusal to pay, at similar 
times, following similarly timed and virtually identical requests for irrelevant medical 
documentation.”  Id. ¶ 201.  (4) “Blue Cross and numerous BCBS affiliates issued similar 

false, public, and derogatory statements about GS Labs, including that patients will be 
liable for higher out-of-pocket costs for seeking care from GS Labs rather than other 
COVID-19 testing providers.”  Id. ¶ 202.  As support for this allegation, GS Labs compares 
a statement Blue Cross made in connection with the filing of this case with a statement 
made by a separate BCBS affiliate in connection with a similar lawsuit filed against GS 

Labs in another court in July 2021.  Id. ¶ 202 n.69.  (5) “[F]rom as early as December of 
2020 and continuing into 2021, certain BCBS affiliates submitted complaints to, or were 
in close contact with, government regulators and enforcers concerning the affiliates’ 
allegations of ‘price gouging’ and ‘medically unnecessary’ testing by GS Labs.”  Id. ¶ 203. 
    These  allegations  do  not  plausibly  show  a  §  1  conspiracy  that  unreasonably 

restrained trade.  GS Labs doesn’t identify with whom Blue Cross conspired.  It alleges 
generally  that  Blue  Cross  acted  in  parallel  with  “other  BCBS  affiliates”—a  phrase 
appearing  throughout  the  Amended  Counterclaim—but  this  allegation  identifies  no 
particular organization or organizations.  GS Labs cites cases it says hold that it is not 
necessary for a § 1 plaintiff to identify all conspirators.  Mem. in Opp’n [ECF No. 47] at 
49 n.11.  The problem here isn’t that GS Labs has failed to identify all of Blue Cross’s 

alleged co-conspirators.  It hasn’t identified any.  It has at most alleged a group that includes 
potentially  dozens  of  co-conspirators  without  identifying  any  one  of  them  as  a  co-
conspirator.  In this claim’s context, that’s the functional equivalent of identifying none.  
See Twombly, 
550 U.S. at 565
 n.10 (confirming that a § 1 complaint alleging “no specific 
time, place, or person involved in the alleged conspiracies” does not give the notice Rule 
8 requires); Insulate SB, Inc. v. Advanced Finishing Sys., Inc., 
797 F.3d 538, 540
, 545–46 

(8th Cir. 2015) (affirming dismissal of § 1 claim in part because plaintiff failed to “identify 
which of the distributors named as defendants—if any—are among the ‘key Distributors’ 
who were party to the agreements”).                                       
    The Amended Counterclaim identifies an obvious alternative explanation for Blue 
Cross’s conduct but does not address it in the relevant sense.  According to the pleading, 

beginning at least in November 2020, concerns regarding COVID-19 testing price gouging 
were widespread, Am. Countercl. ¶ 191, and in July 2021, Blue Cross and Blue Shield of 
Kansas City sued GS Labs, id. ¶ 209, accusing GS Labs of “intentionally engaging in an 
abusive scheme to exploit the COVID-19 pandemic by duping health insurers into paying 
thousands of COVID-19 diagnostic testing claims at grossly inflated rates,” Blue Cross 

and Blue Shield of Kansas City v. GS Labs LLC, No. 4:21-cv-525-FJG (W.D. Mo.) 
(Compl.,  ECF  No.  1).    Based  on  these  public  allegations,  the  obvious  alternative 
explanation for Blue Cross’s conduct is that it suspected, and later concluded (as this 
lawsuit shows), that GS Labs was charging unreasonably excessive prices for its tests.  GS 
Labs’ allegations do not plausibly show that Blue Cross’s parallel conduct more likely 
resulted from a § 1 “contract, combination, or conspiracy” as from these obvious and 

ordinarily reasonable business concerns.                                  
    And GS Labs’ collusion theory is economically irrational and therefore implausible.  
The majority of GS Labs’ allegations concern only GS Labs; it identifies no other clinical 
lab that suffered injury resulting from the alleged conspiracy.  But in places, GS Labs goes 
further and alleges broader market consequences to support its § 1 claim.  These include, 
for example, allegations that Blue Cross’s concerted activity “artificially depress[es] prices 

to non-competitive levels in a commercial insurance market for lab-based COVID-19 
testing services[,] and caus[es] shortages in the COVID-19 diagnostic testing market.”  
Am.  Countercl.  ¶  118.    This  allegation  seems  economically  irrational  and  therefore 
implausible.7  Blue Cross should have an interest in the market presence of more clinical 
labs, not fewer.  More clinical labs would create more competition, resulting in greater 

price pressure on clinical lab participants, and yielding lower prices to retail customers and 
their insurers.  And leaving the allegation’s indefiniteness aside, GS Labs alleges elsewhere 
that the diagnostic testing services GS Labs and other clinical labs provide “improved 
health outcomes, which have dramatically reduced Blue Cross’[s] health care spend and 
the spending it would have outlaid in the absence of GS Labs’ testing.”  Am. Countercl. 


7    If not relied on very often, economic irrationality is a recognized ground to find a 
complaint’s allegations implausible.  See, e.g., Green Star Energy Sols., LLC v. Edison 
Props., LLC, No. 21-cv-2682 (LJL), 
2022 WL 16540835
, at *8 (S.D.N.Y. Oct. 28, 2022) 
(finding  economically  irrational  allegations  to  be  implausible  under  Rule  12(b)(6) 
standard).                                                                
¶ 338.  In GS Labs’ theory, the absence of Blue Cross’s prohibited § 1 conduct would 
enable more clinical labs to participate in the market, eliminate testing shortages, and 

enable those labs to increase their prices.  As Blue Cross points out, accepting this assertion 
would “invert basic economic principles.”  Mem. in Supp. [ECF No. 37] at 48.  I am 
persuaded that there is a fundamental disconnect between economic theory and GS Labs’ 
§ 1 theory and that this disconnect renders GS Labs’ § 1 claim implausible. 
                              XIV                                        
    In Count XIV, GS Labs asserts a rule-of-reason violation under § 1 of the Sherman 

Act.  Am. Countercl. at 168 (Count XIV heading).  Without allegations plausibly showing 
concerted action, a § 1 claim fails whether based on a per se or rule-of-reason analysis.  See 
Five Smiths, Inc. v. Nat’l Football League Players Ass’n, 
788 F. Supp. 1042, 1048
 (D. 
Minn. 1992).  Therefore, Count XIV will be dismissed on the same grounds that justified 
dismissal of Count XIII.                                                  

                              XV                                         
    In Count XV, GS Labs asserts a monopolization claim under § 2 of the Sherman 
Act.  Am. Countercl. ¶¶ 426–31.  Section 2 makes it unlawful to “monopolize, or attempt 
to monopolize . . . any part of the trade or commerce among the several States, or with 
foreign nations.”  
15 U.S.C. § 2
.  To state a monopolization claim under Section 2 of the 

Sherman Act, a plaintiff must allege facts plausibly showing that the defendant “(1) 
possessed monopoly power in the relevant market and (2) willfully acquired or maintained 
that power as opposed to gaining that power as a result ‘of a superior product, business 
acumen, or historical accident.’”  Amerinet, Inc. v. Xerox Corp., 
972 F.2d 1483, 1490
 (8th 
Cir. 1992) (quoting United States v. Grinnell Corp., 
384 U.S. 563, 571
 (1966)); Moldex 
Metric, Inc. v. 3M Co., No. 14-cv-1821 (JNE/FLN), 
2015 WL 520722
, at *6 (D. Minn. 

Feb. 9, 2015).                                                            
    “A relevant market breaks down into (1) a product market and (2) a geographic 
market.”  Trone Health Servs., Inc. v. Express Scripts Holding Co., 
974 F.3d 845, 857
 (8th 
Cir.  2020)  (cleaned  up).    “‘The  relevant  product  market  includes  all  reasonably 
interchangeable products.’”  Park Irmat Drug Corp. v. Express Scripts Holding Co., 
911 F.3d 505, 517
 (8th Cir. 2018) (quoting Double D Spotting Serv., Inc. v. Supervalu, Inc., 

136 F.3d 554, 560
 (8th Cir. 1998)).  “The geographic market is defined by considering the 
commercial realities faced by consumers.”  Double D Spotting Serv., 
136 F.3d at 560
.  “It 
includes the geographic area in which consumers can practically seek alternative sources 
of the product, and it can be defined as ‘the market area in which the seller operates.’”  
Id.
 
(quoting Tampa Elec. Co. v. Nashville Coal Co., 
365 U.S. 320, 327
 (1961)).   

    GS Labs alleges the relevant product market is the “Commercial Insurance Market 
for the Purchase of COVID-19 Diagnostic Testing Services.”  Am. Countercl. ¶ 144.  In 
this market, GS Labs alleges, “the insurer is the buyer and GS Labs is the seller.”  Id. ¶ 157.  
GS Labs alleges that “Blue Cross and other commercial (private) insurers . . . compete in 
this market by offering health plan products that reimburse a full suite of medical services, 

including lab-based COVID-19 diagnostics testing (as required by law), on behalf of their 
subscribers.”  Id. ¶ 145.  GS Labs also alleges that “[p]roducts offered by HMO and other 
similar managed care insurance providers may be excluded due to their vertical integration, 
which causes their networks to be unavailable to third party providers and/or their providers 
to be unavailable to third party insurance carriers.”  Id. ¶ 166.  GS Labs does not allege that 
it cannot or refuses to accept payment from sources other than private commercial insurers.  

It alleges, however, that “public insurance programs (such as Medicare, Medicaid, and 
Tricare)  pay  for  COVID-19  testing  at  rates  that  are  significantly  lower  than  what 
commercial insurance plans pay.”  Id. ¶ 140.  GS Labs alleges essentially that it could not 
operate its “scalable business model” if it were limited to payments from public insurance 
programs.  Id.; see also id. ¶¶ 141–42.                                   
    This alleged product market is implausible under Eighth Circuit precedent.  In Little 

Rock Cardiology Clinic PA v. Baptist Health, a cardiology clinic (“LRCC”) asserted, as 
relevant here, a § 1 rule-of-reason claim and a § 2 monopolization claim.  
591 F.3d 591, 596
 (8th Cir. 2009).  LRCC’s basic allegation was “that Baptist Health conspired with Blue 
Cross [& Blue Shield of Arkansas] to restrain trade in, and monopolize the market for, 
cardiology services for privately insured patients” through a series of arrangements that 

shut LRCC out from the Blue Cross network.  
Id. at 594
.  LRCC alleged a product market 
“limited to patients covered by private insurance.”  
Id. at 596
.  The Eighth Circuit affirmed 
the district court’s Rule 12(b)(6) dismissal of the suit based on its determination that this 
product market is implausible.  The court explained:                      
         LRCC proposes a market limited by how consumers pay for         
         cardiology procedures.  This theory lacks support in both logic 
         and law. . . . [T]he general issue when determining the relevant 
         product  market  concerns  the  choices  available  to          
         consumers.  Craftsmen Limousine, 491 F.3d at 388.  In this      
         case—an  exclusive-dealing  case  involving  shut-out           
         cardiologists—the  relevant  inquiry  is  whether  there  are   
         alternative  patients  available  to  the  cardiologists.  See  
         Campfield v. State Farm Mut. Auto. Ins. Co., 
532 F.3d 1111, 1119
 (10th Cir. 2008) (“When there are numerous sources of       
         interchangeable demand, the plaintiff cannot circumscribe the   
         market to a few buyers in an effort to manipulate those buyers' 
         market share.”); Stop & Shop Supermarket Co. v. Blue Cross      
         & Blue Shield of R. I., 
373 F.3d 57, 67
 (1st Cir. 2004) (“[T]he  
         concern in an ordinary exclusive dealing claim by a shut-out    
         supplier  is  with  the  available  market  for  the  supplier.”); 
         Brokerage Concepts, Inc. v. U.S. Healthcare, Inc., 
140 F.3d 494, 514
 (3d Cir. 1998) (stating the “logical assumption that [a 
         pharmacy] considers members of other prescription plans, or     
         uninsured persons, completely interchangeable with [privately   
         insured] members.”).  Thus, LRCC must look to alternative       
         patients who are able to pay the required fees, not just those  
         who pay using private insurance.                                

         LRCC argues that the product market should be limited to        
         patients using private insurance because private insurance and  
         government  insurance—the  other  primary  method  of           
         payment—are not reasonably interchangeable.  The trouble        
         with this theory is that it analyzes the issue from the wrong side 
         of the transaction.  It may be true that, from the patient’s    
         perspective, private insurance and Medicare/Medicaid are not    
         reasonably interchangeable.  For a variety of reasons, including 
         age  and  financial  considerations,  a  person  with  private  
         insurance may not qualify for these government programs.  But   
         this lawsuit is not about the options available to patients, it is 
         about the options available to shut-out cardiologists.  LRCC’s  
         claims boil down to the allegation that, due to Baptist Health’s 
         allegedly unlawful actions, LRCC has access to fewer patients.  
         The relevant question, then, is to whom might the cardiologists 
         at  LRCC  potentially  provide  medical  service?    LRCC’s     
         complaint provides the answer: LRCC can provide service to      
         “patients  .  .  .  from  either  a  government  program  such  as 
         Medicare or Medicaid, or from a private insurer.” (emphasis     
         added).  Patients able to pay their medical bill, regardless of 
         the method of payment, are reasonably interchangeable from      
         the cardiologist’s perspective—the correct perspective from     
         which to analyze the issue in this case.                        

Id. at 597
.  Based on this analysis, the court announced a seemingly clear rule: “We 
conclude that, as a matter of law, in an antitrust claim brought by a seller, a product market 
cannot be limited to a single method of payment when there are other methods of payment 
that are acceptable to the seller.”  
Id. at 598
.                          

    Like Little Rock Cardiology Clinic, this is an antitrust claim brought by a shut-out 
seller who alleges that the product market is limited to a single method of payment when 
there are other methods of payment acceptable to it.  GS Labs addresses Little Rock 
Cardiology Clinic in a footnote.  Mem. in Opp’n at 54 n.17.  There, it says “the inclusion 
of all buyers was deemed necessary [in Little Rock Cardiology Clinic] only when there are 
other methods of payment that are acceptable to the seller.”  
Id.
 (quotation omitted).  True, 

but GS Labs does not allege anywhere in its Amended Counterclaim that other methods of 
payment are unacceptable to it.  It alleges that it could not operate its “scalable business 
model” if it were limited to payments from public insurance programs.  Am. Countercl. 
¶ 140; see also 
id.
 ¶¶ 141–42.  But a health care provider saying it could not survive on 
public-insurance reimbursement alone is not the same thing as saying the provider won’t 

accept public-insurance reimbursement.  The bottom line is that GS Labs does not allege 
it cannot or refuses to accept payment from sources other than private commercial insurers.  
That seems dispositive under Little Rock Cardiology Clinic.  GS Labs cites district court 
cases from outside the Eighth Circuit accepting health-insurance product markets that 
exclude public programs.  Mem. in Opp’n at 53–54.  But these cases cannot trump 

controlling precedent.  GS Labs also argues that a Rule 12(b)(6) dismissal based on the 
implausibility of an alleged product market is disfavored.  Id. at 53.  In the Eighth Circuit 
case supporting this assertion, Double D Spotting Serv., the panel “note[d] that courts are 
hesitant  to  dismiss  antitrust  actions  before  the  parties  have  had  an  opportunity  for 
discovery, because the proof of illegal conduct lies largely in the hands of the alleged 
antitrust conspirators.”  
136 F.3d at 560
.  Post-Twombly, this expressed hesitancy cannot 

mean that there is some lesser-than-plausibility standard that applies to allegations of a 
product market.                                                           
    GS Labs’ geographic-market allegations focus first on where patients go to obtain 
“lab-based COVID-19 diagnostic testing.”  Am. Countercl. ¶ 159.  Patients, alleges GS 
Labs, “prefer local providers of COVID-19 diagnostic testing services at locations that are 
convenient to their home or workplace.”  Id. ¶ 160.  This is “for convenience, to obtain a 

result faster, to lower the chances that they will expose others (or themselves) to the virus 
in the course of testing, and to more quickly return home to quarantine or recover from 
their illness in the event they are symptomatic.”  Id. ¶ 159.  GS Labs identifies five 
Minnesota metropolitan areas in which lab-based providers have established operations.  
Id. ¶ 160.  On the commercial insurance side, GS Labs alleges: “Health insurers competing 

in the Commercial Insurance Market . . . seek to build networks of COVID-19 diagnostic 
testing providers nationwide, statewide, and in localized geographic markets in populated 
areas where patients live and work.”  Id. ¶ 162.  GS Labs alleges that “[t]he geographic 
market  for  the  Commercial  Insurance  Market,  therefore,  is  based  on  the  geographic 
footprint of employers, individually insured people, and other subscribers of commercial 

insurance products.”  Id.  In sum, GS Labs alleges: “The relevant geographic markets are: 
Minnesota; certain counties, cities, or other localities within Minnesota; and/or a territory 
broader than Minnesota but within the United States.”  Id. ¶ 158.         
    These allegations do not plausibly identify a geographic market.  If the relevant 
product market is the “Commercial Insurance Market for the Purchase of COVID-19 

Diagnostic Testing Services[,]” id. ¶ 144, then the geographic market should be defined by 
allegations showing where Blue Cross purchases COVID-19 diagnostic testing services.  
That is where Blue Cross “draws a sufficiently large percentage of its business” in the 
relevant  sense.    Little  Rock  Cardiology  Clinic,  
591 F.3d at 598
.    The  Amended 
Counterclaim doesn’t allege the geographic market this way.  It relies instead on allegations 
showing why patients who obtain COVID-19 testing stay close to home or work (or where 

they are at the moment they decide to get tested) and where Blue Cross sells insurance, 
including the allegation that it sells insurance in similarly local markets.  At the hearing on 
this motion, GS Labs argued that this approach nonetheless works because Blue Cross’s 
market  power  comes  from  its  subscriber  base.    Tr.  [ECF  No.  56]  at  67.    It  seems 
conceivable that the geographic area in which Blue Cross purchases COVID-19 diagnostic 

testing services may overlap with the territory in which it issues or administers health 
insurance plans.  But that possibility—or even likelihood—doesn’t address the absence of 
allegations plausibly showing a geographic market in which Blue Cross purchases a 
sufficiently large percentage of its COVID-19 diagnostic testing services.8 


8    Though not decided here, it is worth expressing doubt regarding whether GS Labs 
has plausibly alleged anticompetitive conduct.  “‘Anticompetitive conduct is conduct 
without  legitimate  business  purpose  that  makes  sense  only  because  it  eliminates 
competition.’”  HDC Med., Inc. v. Minntech Corp., 
474 F.3d 543, 549
 (8th Cir. 2007) 
(quoting Morgan v. Ponder, 
892 F.2d 1355, 1358
 (8th Cir. 1989)).  “‘When a valid business 
reason exists for the conduct alleged to be predatory or anti-competitive, that conduct 
cannot support the inference of a [Sherman Act] violation.’”  
Id.
 at 549–50 (quoting 
Midwest Radio Co., Inc. v. Forum Pub. Co., 
942 F.2d 1294
, 1297–98 (8th Cir. 1991)).  
                              XVI                                        
    GS Labs asserts a § 2 Sherman Act attempted monopolization claim in Count XVI.  

The parties do not separately address this claim.  Regardless, it seems settled that the failure 
to allege a plausible product or geographic market dooms this claim.  Par v. Wolfe Clinic, 
P.C., No. 4:21-cv-00290-RGE-SBJ, 
2022 WL 2187858
, at *8 (S.D. Iowa May 10, 2022); 
Physician  Specialty  Pharmacy,  LLC  v.  Prime  Therapeutics,  LLC,  No.  18-cv-1044 
(MJD/TNL),  
2019 WL 5149866
,  at  *8  (D.  Minn.  Aug.  8,  2019),  report  and 
recommendation adopted, 
2019 WL 4463442
 (D. Minn. Sept. 18, 2019).  This conclusion 

makes sense.  GS Labs neither alleges nor argues that it can show that Blue Cross has a 
“dangerous  probability  of  success”  in  its  alleged  monopolization  efforts  without 
referencing Blue Cross’s share of a plausible “relevant market.”  See HDC Medical, 474 
F.3d at 549–50 (quoting  Gen. Indus. Corp. v. Hartz Mountain Corp., 
810 F.2d 795
, 806–
07 (8th Cir. 1987) and Alexander v. Nat’l Farmers Org., 
687 F.2d 1173, 1181
 (8th Cir. 

1982)).                                                                   




“[A]s a general matter, the Sherman Act ‘does not restrict the long recognized right of [a] 
trader or manufacturer engaged in an entirely private business, freely to exercise his own 
independent discretion as to parties with whom he will deal.’”  Verizon Commc’ns Inc. v. 
Law Offices of Curtis V. Trinko, LLP, 
540 U.S. 398, 408
 (2004) (quoting United States v. 
Colgate & Co., 
250 U.S. 300, 307
 (1919)).  GS Labs’ theory is essentially that Blue Cross 
made statements to its members that steered them away from GS Labs because, as GS Labs 
seems to acknowledge, its services were more expensive.  See Mem. in Opp’n at 61–62.  
GS Labs identifies no other affected provider.  Under these circumstances, it is difficult to 
understand why Blue Cross’s conduct was anticompetitive or how it caused antitrust injury.     
                         XVII and XVIII                                  
    In these Counts, GS Labs alleges antitrust claims under Minnesota law that are 

parallel to its federal claims.  Minn. Stat. §§ 325D.51–.53.  The parties agree that these 
claims stand or fall with the federal claims, and there is no reason here to second-guess that 
judgment.  See Inline Packaging, LLC v. Graphic Packaging Int’l, LLC, 
962 F.3d 1015, 1024
 (8th Cir. 2020) (quoting Lorix v. Crompton Corp., 
736 N.W.2d 619, 626
 (Minn. 
2007)).  These claims will therefore be dismissed for the same reasons as the federal claims 
will be dismissed.                                                        

                              XIX                                        
    GS Labs asserts a claim for tortious interference with contract in Count XIX.  Am. 
Countercl. at 174.  To state a claim for tortious interference with contract under Minnesota 
law, GS Labs must allege facts plausibly showing: “(1) the existence of a contract; (2) the 
alleged wrongdoer’s knowledge of the contract; (3) intentional procurement of its breach; 

(4) without justification; and (5) damages.”  Kjesbo v. Ricks, 
517 N.W.2d 585, 588
 (Minn. 
1994) (citation omitted).  Showing the absence of justification in turn requires showing an 
improper  means,  which  “are  those  that  are  independently  wrongful  such  as  threats, 
violence, trespass, defamation, misrepresentation of fact, restraint of trade or any other 
wrongful act recognized by statute or common law.”  Inline Packaging, LLC v. Graphic 

Packaging Int'l, Inc., 
164 F. Supp. 3d 1117, 1137
 (D. Minn. 2016) (quoting Harman v. 
Heartland Food Co., 
614 N.W.2d 236, 241
 (Minn. Ct. App. 2000)) (emphasis added). 
    GS Labs’ tortious-interference allegations attempt to track these elements: (1) GS 
Labs alleges it has contracts with BCBS affiliates (other than Blue Cross in Minnesota) 
“regarding the rates of reimbursement for COVID-19 diagnostic testing provided to those 
BCBS affiliates’ members.”  Am. Countercl. ¶ 458.  (2) It alleges that Blue Cross knows 

of these contracts “by virtue of its participation in the BlueCard program.”  Id. ¶ 459.  (3) 
GS  Labs  alleges  that  Blue  Cross’s  failure  to  comply  with  its  obligations  under  the 
BlueCard-program contract or contracts (as described above in connection with GS Labs’ 
intended-beneficiary theory) “caused a breach of the reimbursement provisions” in GS 
Labs’ contracts with other BCBS affiliates.  Id. ¶ 460; see also id. ¶ 463.  (4) GS Labs 
alleges that “Blue Cross had and has no lawful basis or justification to not reimburse GS 

Labs at the rates agreed to by certain BCBS affiliates.”  Id. ¶ 462.  (5) And GS Labs alleges 
it sustained damages resulting from Blue Cross’s alleged tortious interference.  Id. ¶ 465. 
    This claim is implausible.  GS Labs does not allege facts showing that Blue Cross 
acted  without  justification.    As  noted,  interference  is  without  justification  if  it  is 
accomplished  through  improper  means,  and  improper  means  are  those  that  are 

independently wrongful.  Inline Packaging, 
164 F. Supp. 3d at 1137
.  GS Labs alleges no 
independently wrongful conduct, like threats, violence, or defamation.  It alleges only that 
Blue Cross breached a contract with other BCBS affiliates and that this breach of contract 
resulted in other contractual breaches affecting GS Labs.  A contractual breach is not 
tortious—that is, it is not independently wrongful.  To put it another way, I understand 

Minnesota law to say that a mere contract breach cannot put the “tort” in a tortious 
interference claim.  There is another problem.  GS Labs’ allegations regarding breach of 
its contracts with the BCBS affiliates are quite general.  GS Labs does not allege facts 
plausibly identifying either which BCBS-affiliate contracts were breached or how. 
                              XX                                         
    In Count XX, GS Labs asserts a breach-of-contract claim on the theory that it is an 

intended third-party beneficiary of contracts between Blue Cross and “BCBS affiliates” in 
other states.  Am. Countercl. ¶ 467.  GS Labs alleges “on information and belief” that these 
contracts “require Blue Cross to forward all claims from a provider related to services 
provided to a member of a BCBS affiliate’s plan, to that plan.”  Id. ¶¶ 266, 468.  In other 
words, GS Labs alleges that if it (or any other provider) submits a claim to Blue Cross in 
Minnesota for a patient who is in fact covered under a plan insured or administered by a 

BCBS affiliate in another state, then Blue Cross is contractually required to transmit the 
claim to that affiliate for a benefits determination by that affiliate.  See id. ¶ 180.  GS Labs 
alleges that Blue Cross assented to these arrangements “through its participation in the 
BlueCard program.”  Id. ¶ 266; see also id. ¶¶ 176–78 (alleging that the BlueCard program 
is a claims routing system that “obligates each BCBS affiliate to treat other affiliates’ 

members at the reimbursement level that they have negotiated with providers” and that 
“‘links participating health care providers and independent Blue Cross plans through a 
single electronic network’”).  GS Labs alleges that, if Blue Cross had complied with its 
obligations under these contracts, it would have been paid “millions” more by the affiliates 
than Blue Cross has paid (or not paid).  Id. ¶ 473.  Central to its claim to be a third-party 

beneficiary  of  these  contracts,  Blue  Cross  alleges:  “On  information  and  belief,  the 
BlueCard program contract(s) between Blue Cross and other BCBS affiliates clearly 
manifest an intent to benefit providers like GS Labs by establishing a means for these 
providers to obtain reimbursement and the benefits of its contracts with an out-of-state 
BCBS plan.”  Id. ¶ 468.                                                   

    “Generally, a stranger to a contract does not have rights under the contract, but an 
exception exists if a third party is an intended beneficiary of the contract.”  Hickman v. 
Safeco Ins. Co. of Am., 
695 N.W.2d 365, 369
 (Minn. 2005).  To determine whether a third 
party is an intended beneficiary of a contract, Minnesota follows the Restatement (Second) 
of Contracts § 302.  Cretex Cos., Inc. v. Constr. Leaders, Inc., 
342 N.W.2d 135, 139
 (Minn. 
1984).  The Restatement provides:                                         

         (1) Unless otherwise agreed between promisor and promisee,      
         a  beneficiary  of  a  promise  is  an  intended  beneficiary  if 
         recognition of a right to performance in the beneficiary is     
         appropriate to effectuate the intention of the parties and either 

              (a)  the  performance  of  the  promise  will  satisfy  an 
              obligation  of  the  promisee  to  pay  money  to  the     
              beneficiary; or                                            

              (b) the circumstances indicate that the promisee intends   
              to  give  the  beneficiary  the  benefit  of  the  promised 
              performance.                                               

         (2) An incidental beneficiary is a beneficiary who is not an    
         intended beneficiary.                                           

Restatement (Second) of Contracts § 302; see also Caldas v. Affordable Granite & Stone, 
Inc., 
820 N.W.2d 826
, 832–33 (Minn. 2012).  “In determining the parties’ intent, we look 
to the language of the contract.”  Caldas, 
820 N.W.2d at 833
.  This contract examination 
seems essential applying the intent-to-benefit rule of § 302(1)(b), and courts applying the 
test engage in a close review of the relevant contract.  See, e.g., id. at 833–35; Kruger v. 
Lely N. Am., Inc., 
518 F. Supp. 3d 1281
, 1289 (D. Minn. 2021).  “In most cases, ‘when 
there is no reference to the third party in the contract, there is no intent to benefit the third 
party.’”  Dayton Dev. Co. v. Gilman Fin. Servs., Inc., 
419 F.3d 852, 856
 (8th Cir. 2005) 

(quoting 614 Co. v. Minneapolis Cmty. Dev. Agency, 
547 N.W.2d 400, 410
 (Minn. Ct. App. 
1996)).                                                                   
    GS Labs alleges that Blue Cross’s contracts with other BCBS affiliates indicate an 
intent to benefit GS Labs (and presumably every other provider), but this allegation is 
implausible.9  GS Labs’ description of these contracts omits mention of any particular 
contract term or terms indicating an intent to benefit providers.  GS Labs does not allege 

that it or providers generally are referenced in the contracts (or any of them).  It is true that 
GS Labs alleges that these contracts “clearly manifest an intent to benefit providers[,]” Am. 
Countercl. ¶ 468, but this allegation is not sufficient.  It pleads a legal conclusion because 
the allegation merely repeats Minnesota’s intent-to-benefit rule.  Courts “are not bound to 
accept as true a legal conclusion couched as a factual allegation.”  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009) (citation and internal quotation marks omitted).  It is made “[o]n 
information and belief” because GS Labs does not have the contracts.  Am. Countercl. 
¶ 468.  In other words, it is not possible to examine the contracts to determine whether any 
or all of them express an intent to benefit providers.  (GS Labs faults Blue Cross for 
declining to file the contracts, but GS Labs identifies no authority that might have required 

Blue Cross to do that.)  Regardless, this claim’s supporting allegations show at most that 

9    GS Labs does not attempt to meet the duty-owed test in § 302(1)(a).  Its allegation 
that Blue Cross’s transmission of the claim to the appropriate BCBS affiliate results only 
in a “benefits determination[]” and not necessarily payment, Am. Countercl. ¶ 180, would 
undermine that contention.                                                
providers might benefit incidentally from the presence of these contracts in the same way 
providers  might  benefit  from  any  contract  facilitating  the  efficient  adjudication  of  a 

benefits claim.  That is not enough to plausibly allege a breach-of-contract claim via an 
intended-beneficiary theory under Minnesota law.                          
                              XXI                                        
    In Count XXI, GS Labs alleges facts supporting a claim for punitive damages under 
Minnesota law.  Am. Countercl. at 176.  Whether this Count should be dismissed depends 
on the resolution of two issues.  The first concerns the procedural propriety of the claim.  

Minnesota  law,  specifically  
Minn. Stat. § 549.191
,  prohibits  plaintiffs  from  seeking 
punitive damages in an initial complaint.  Blue Cross argues that GS Labs’ punitive 
damages claim should be dismissed under the Minnesota statute.  Though older cases in 
this District applied the statute in diversity cases, the recent intra-District trend has been 
not to apply the statute in favor of Rules 8 and 15 of the Federal Rules of Civil Procedure.  

See  Am.  Achievement  Corp.  v.  Jostens,  Inc.,  ---  F.  Supp.  3d  ---,  No.  21-cv-2613 
(NEB/BRT), 
2022 WL 3566862
, at *9–10 (D. Minn. Aug. 18, 2022) (reviewing issue and 
citing  cases);  cf.  Shank  v.  Carleton  Coll.,  
329 F.R.D. 610
,  615  (D.  Minn.  2019) 
(recognizing that the state of the law on this question has been “in flux”).  The case on 
which Blue Cross relies, Bergman v. Johnson & Johnson, No. 20-cv-2693 (JRT/HB), 
2021 WL 3604305
 (D. Minn. Aug. 13, 2021), doesn’t support Blue Cross’s position.  There, the 
court declined to resolve the question because it was “irrelevant.”  
Id. at *6
 (“As there is 
no motion to amend or proposed amended complaint at issue in the present matter, the issue 
of which standard the Court would apply to determine whether a plaintiff may seek punitive 
damages is irrelevant.”).                                                 

    Assuming GS Labs’ claim is procedurally proper under the more recent intra-
District trend, there is another problem.  GS Labs’ remaining claims are for benefits under 
ERISA, 
29 U.S.C. § 1132
(a)(1)(B), and for promissory estoppel under Minnesota law.  
Punitive damages are not recoverable in an ERISA benefits claim under § 1132(a)(1)(B).  
See Massachusetts Mut. Life Ins. Co. v. Russell, 
473 U.S. 134, 148
 (1985) (determining 
that ERISA does not provide a cause of action for extracontractual compensatory or 

punitive damages in the context of a benefits claim).  And though I’ve found no case 
answering  the  question  under  Minnesota  law,  other  jurisdictions  hold  that  punitive 
damages are not recoverable under a promissory estoppel claim.  See, e.g., Beluca Ventures 
LLC v. Einride Aktiebolag, No. 21-cv-06992-WHO, 
2022 WL 17252589
, at *5 (N.D. Cal. 
Nov. 28, 2022) (holding that punitive damages are not recoverable for promissory estoppel 

or other quasi-contract claims under California law); LPD New York, LLC v. Adidas Am., 
Inc., No. 15-CV-6360 (MKB), 
2022 WL 4450999
, at *18 n.11 (E.D.N.Y. Sept. 24, 2022) 
(“Punitive damages are not available under New York law for Plaintiff’s promissory 
estoppel or quasi-contract claims.”); Dugdale, Inc. v. Alcatel-Lucent USA, Inc., No. 1:09-
cv-0960-JMS-TAB, 
2011 WL 2261318
, at *4 (S.D. Ind. June 7, 2011) (applying Indiana 

law).  In view of these authorities, I think the wiser course is to dismiss GS Labs’ punitive 
damages claim.  Of course, if GS Labs is able to cite Minnesota authority permitting a 
recovery of punitive damages for promissory estoppel, it may re-assert the claim.  

ORDER

    Based on the foregoing, and on all the files, records, and proceedings herein, IT IS 

ORDERED THAT:                                                             
    1.   Blue Cross’s motion to dismiss [ECF No. 35] is GRANTED IN PART and 
DENIED IN PART.                                                           
    2.   Counts I, II, VI, and IX insofar as it asserts a claim under 
29 U.S.C. § 1132
(a)(3) are DISMISSED WITH PREJUDICE.                                  
    3.   Counts III, V, VII, VIII, X, XI, XII, XIII, XIV, XV, XVI, XVII, XVIII, XIX, 

XX, and XXI are DISMISSED WITHOUT PREJUDICE.                              
    4.   The motion is DENIED with respect to Counts IV and IX insofar as it asserts 
a claim under 
29 U.S.C. § 1132
(a)(1).                                     

Date:  January 30, 2022            s/ Eric C. Tostrud                     
                                  Eric C. Tostrud                        
                                  United States District Court           

Reference

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