In addition, as previously discussed, the Complaint also violates Rule 9(b) by not including any factual allegations establishing the nature of the RIC Partners' "significant beneficial interest" in the SG-ASC center or that the brochure advising patients to call the center to obtain ownership information did not serve to fully disclose such interest. C. RELATOR'S COMPLAINT FAILS TO STATE A CA-IFPA CLAIM BASED ON WAIVER OF CO-PAYS AND DEDUCTIBLES The Complaint also alleges that RIC, the RIC Partners, CEES and SG-ASC submitted false and fraudulent claims for patients covered by commercial health plans ( e.g., Empire BlueCross/ Blue Shield, Cigna and United Healthcare) in violation of California Penal Code § 550 because defendants routinely waived the deductible and co-payments amounts that they were obligated to charge patients pursuant to the terms of their provider agreements and failed to disclose their usual significant beneficial interest, unless the licensee first discloses in writing to the patient, that there is such an interest and advises the patient that the patient may choose any organization for the purpose of obtaining the services ordered or requested by the licensee." Cal.

Moreover, Plaintiff's UCL claims are uncertain to the extent that she fails to state with reasonable particularity the alleged business practices that were violated by Bof-1. By example, Plaintiff claims that BofH violated California Penal Code section 550, which relates to claims under an insurance policy, but the FAC is wholly lacking any allegations about BofH's (or Plaintiff's) purported insurance, or that Plaintiff has standing to assert claims against BofH's insurer. FAC,1186, 92-93. Plaintiff also provides no authority that the Hawaii UCL should be governed by an alleged violation of California law.