In Healthplus Surgery Center, LLC v. State Farm Mut. Auto. Ins. Co., 703556/19 (Civ. Ct. N.Y. Co.), GMR argued that a New Jersey medical provider that is not registered to do business in New York cannot maintain a cause of action in a New York Court to collect New York No-Fault benefits. The court held that the fact that the medical provider had filed hundreds of collection cases in New York State demonstrated a continuous pattern of doing business rather than isolated event, which would be permitted. This holding will force these non-New York medical providers to comply with New York State registration requirements or be precluded from bringing collection actions in New York.