Foundation: 2024 ONCA 430 Beazley v Johnston — established that Ontario serology reliability is a live question. The Beazley case was dismissed procedurally (self-represented, extension denied) — the serology question was never adjudicated on the merits. That gap is our door.

Duty: Physician has duty to investigate beyond a single negative serology result when clinical symptoms persist + tick exposure history present. Standard of care (2020): clinical diagnosis on symptoms is recognised approach. IDSA 2020 explicitly does not require positive serology for treatment initiation.

Strategy: File individual negligence claims → accumulate → when 30+ share identical fact pattern (negative serology, symptoms, denial) → class action.

Insurer denies long-term antibiotic coverage citing IDSA 2006 guidelines (superseded). IDSA published updated 2020 guidelines. Insurer using outdated evidence to deny evidence-based treatment.

Duty: Insurer has duty to apply current standard of care, not 20-year-old guidelines, when assessing coverage. Anchor: 2022 BCCA 84 Stewart v Lloyd's — insurance duty to cover treatment. BC precedent applicable to ON by analogy.

Strategy: Human Rights complaint (denial of coverage = disability discrimination under Ontario Human Rights Code s.1) + civil claim for denial of insured services under OHIA s.27.

Australian DOH position: "Lyme disease does not exist in Australia." Confirmed fact: Borrelia garinii and Borrelia bavariensis detected in Australian ticks (CSIRO studies). Patients with positive PCR tests denied diagnosis.

This is not negligence. This is institutional fraud: maintaining an official position known to be false while patients accumulate harm. Analogous to tobacco industry denial architecture.

Strategy: (1) Document 30+ AU patients with positive PCR + DOH denial letters → class action for negligent misstatement by government body. (2) Simultaneously: VLA15 vaccine — EU approved 2024, blocked AU/CA. Regulatory capture complaint to TGA (AU) + Health Canada. (3) MEEK: if DOH will not revise position after brief presentation → sovereign enforcement via International Court of Justice or UN Special Rapporteur on Health.

Three distinct diseases conflated as one: Type 1 (persistent infection), Type 2 (autoimmune OspA→LFA-1), Type 3 (neurological). Treatment: Type 1 = antibiotics; Type 2 = LDN + hydroxychloroquine (NOT antibiotics); Type 3 = IV ceftriaxone for BBB crossing.

When a Type 2 patient is treated with antibiotics (wrong treatment for autoimmune mechanism), treating physician has caused iatrogenic harm — harm caused by the treatment itself. This is additional liability on top of the original misdiagnosis.

Strategy: Malpractice class for iatrogenic harm where patients can demonstrate (a) PTLDS Type 2 diagnosis (OspA antibody pattern) AND (b) physician prescribed antibiotics rather than immunomodulatory therapy.