In this case, the Plaintiffs settled personal injury claims against respective tortfeasors. Plaintiffs, who were insured through Medicare Advantage Organizations (“MAOs”), were required to reimburse the MAOs their conditional healthcare payments less procurement costs (i.e., attorneys’ fees and costs). See 42 C.F.R. § 411.37. Plaintiffs allege Defendants have adopted a practice of refusing to offset procurement costs when subrogating MAO liens on behalf of their MAO clients, which caused the Plaintiffs monetary damages.