• Type-A Numbers: Those associated with calls coded as “prerecorded” and appearing on internal do-not-call lists.
• Type-B Numbers: Those that received a prerecorded call after a call coded as “disconnected.”

Using this data, Verkhovskaya proposed a multi-step notification plan, including reverse lookups, cross-referencing subscriber information with carrier data, and issuing subpoenas to telephone carriers to identify account holders. Potential class members would then be sent claim forms asking whether they received a wrong-number call, whether they were Humana customers, and other verifying information.