Law360, New York (April 15, 2016, 11:01 AM EDT) -- In recent weeks, two courts ruled on motions to dismiss the first wave of class action lawsuits based on alleged price optimization of auto insurance rates. In both Stevenson v. Allstate Insurance Co., No. 15-cv-04788 (N.D. Cal. March 17, 2016) and Harris v. Farmers Insurance Exchange, No. BC579498 (Cal. Super. Jan. 25, 2016), the courts invoked the "primary jurisdiction" doctrine to stay the litigation, pending further proceedings by California regulators. Yet both courts also issued rulings on important elements of the plaintiffs' claims — holding, among other things, (1) that insureds whose rates are affected by price optimization suffer an "injury in fact"; (2) that failure to disclose price optimization can make advertisements "false and misleading"; and (3) that insurers using price optimization may have been unjustly enriched. These rulings raise more questions than they answer about the exposure insurers now face for their actual practices — especially because the two courts came to opposite conclusions about what it is the defendants were accused of doing in the first place....