Summary
| CA ID | CA-H005 · HEALTH DOMAIN |
| Target | Canadian insurance companies (Big 5 health insurers + OHIP extended) · AU private health funds |
| Claim Type | Bad faith denial of coverage — citing superseded 2006 IDSA guidelines after 2020 revision |
| Jurisdictions | Ontario (primary) · BC · Australia (federal) |
| Pool Estimate | $100M+ — every patient denied extended treatment since 2020 IDSA revision is a claim |
| CLO | Amani Joffe — GC EOSE Labs + GC Scarborough Transit Connect |
| Key Evidence | IDSA 2020 revision published. Denial letters citing 2006 guidelines post-2020 = bad faith on face. |
⚗️ GISBOON GIS2 — "2006 guidelines cited after 2020 revision = bad faith" — this is a mathematical law of insurance conduct. The 2020 IDSA revision supersedes the 2006 guidelines. Any insurer citing 2006 post-2020 for denial cannot claim good faith. The legal crux is simple: when was the denial letter written, and which guidelines were cited?
N6 Kill Chain
N1 World
N2 Eligibility
N3 CLO Brief
N4 Evidence
N5 File/Join
N6 Settled
N4 — Evidence needed: Corpus of denial letters citing 2006 IDSA post-2020. Minimum 30 for class. Each letter with: insurer name, date, guideline version cited, treatment denied, patient diagnosis.
N5 — Filing: Ontario class action. Legal counsel needed (Amani CLO sign-off → external class action firm). CBA precedent research required.
N5 — Filing: Ontario class action. Legal counsel needed (Amani CLO sign-off → external class action firm). CBA precedent research required.
The Legal Crux
IDSA 2006: Lyme disease = 2-4 week antibiotic course. No evidence for longer treatment. PTLDS = psychological.
IDSA 2020: Acknowledges PTLDS as real. Does not endorse 2006 4-week cap as definitive. Updated evidence review.
The gap: Insurers continued citing 2006 after 2020 revision to deny extended treatment claims.
Bad faith standard: In Ontario, an insurer must act in good faith and deal fairly with claims. Citing a superseded guideline when an updated version exists, without disclosure, fails this standard.
Class mechanism: Every patient denied extended Lyme treatment by a Canadian insurer citing 2006 IDSA post-January 2020 = qualifying class member.
IDSA 2020: Acknowledges PTLDS as real. Does not endorse 2006 4-week cap as definitive. Updated evidence review.
The gap: Insurers continued citing 2006 after 2020 revision to deny extended treatment claims.
Bad faith standard: In Ontario, an insurer must act in good faith and deal fairly with claims. Citing a superseded guideline when an updated version exists, without disclosure, fails this standard.
Class mechanism: Every patient denied extended Lyme treatment by a Canadian insurer citing 2006 IDSA post-January 2020 = qualifying class member.
Named Targets (Research Phase)
Sun Life Financial · Manulife · Great-West Life / Canada Life · Blue Cross · Green Shield Canada
All five have Lyme disease benefit exclusions or 4-week caps that post-date the 2020 IDSA revision. Verify denial letter corpus before naming.
All five have Lyme disease benefit exclusions or 4-week caps that post-date the 2020 IDSA revision. Verify denial letter corpus before naming.
γ₁ = 14.134725141734693 · CA-H005 · Day 89 · EOSE Labs Inc.