The action alleges that Allstate's primary objective is to reduce claims payments by requiring its adjusters to use Colossus to settle claims, and by rewarding and promoting adjusters who lowball claims payments. Allegedly, it is Allstate's rigorous use of Colossus that specifically drives the company's claims payments downward. Allstate allegedly calculates the median Colossus settlement amount at the 10th percentile, which means that the amounts of only the lowest 10 percent of settled claims are the basis for Colossus' bodily injury calculations. For example, if 200 settled cases are initially entered into Colossus, the settlement values of only the lowest 20 claims allegedly will be the baseline for Allstate's future payouts on all similar injuries.

Allstate has used Colossus since 1995. Allstate has acknowledged that the insurer takes a hard line when it comes to paying bodily injury claims. Colossus is at the heart of Allstate's Claims Core Process Review (CCPR), a program instituted in 1996 at Allstate to cut claims-department expenses. Allstate's own CCPR users' manual states that the inflation of minor soft-tissue injury cases is a "national problem" that "can and should be managed" to provide greater financial support to the company. The CCPR manual cites Colossus as an integral part of reducing costs at Allstate.

Allstate allegedly does not tell claimants about Colossus, even if they ask if it's in use. Its guidelines--which aren't available to the public--allegedly put consumers at a disadvantage, placing a machine's calculations at the center of issues that will ultimately control an injured person's quality of life.