In Radiology Resource Network, P.C. v. Fireman's Fund Insurance Co. (12 AD3d 185, 784 N.Y.S.2d 101 [1st Dept 2004]), a case involving the assignment of 68 separate individual no-fault claims, the court determined that it was unlikely that these claims, arising out of totally separate accidents, would involve identical legal or factual issues. Some of the factual issues identified by the court that would have to be considered included, for each of the claims: (1) the validity of the assignments; (2) the necessity of the services provided in light of each assignor's medical condition and history; (3) the insurer's receipt of the bills; (4) the sufficiency of the no-fault forms that have been submitted. The Court further opined that the viability of the insurer's defenses would depend on the particular facts relating to each separate claim, and that, " under the circumstances, to try all 68 claims together would be unwieldy and would create a substantial risk of confusing the trier of fact." Id. at 186.