"As a means of marketing the P-STIM, the Defendants conceived of promoting the P-STIM as billable under a particular set of medical billing codes known as Current Procedural Terminology ("CPT"). CPT codes are the United States' standard for how medical professionals document and report medical, surgical, radiology, laboratory, anesthesiology, and evaluation and management services. All healthcare providers, payers, and facilities use CPT codes. The five character CPT codes are used by insurers to help determine the amount of reimbursement that a practitioner will receive for services provided. CPT codes are developed, maintained, and copyrighted by the American Medical Association."
"To entice medical providers and facilities to purchase their P-STIM devices, the Defendants promoted the billing of the P-STIM using a particular set of medical billing codes, including CPT 64555, Percutaneous Implantation of Neurostimulator Electrodes at a Peripheral Nerve. This code and the ancillary codes billed with it covering facility and individual provider charges provided for between $3,000 and $6,000 in reimbursement from health insurers for a procedure with little associated cost, taking ten minutes to perform."

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