Ambrosio and Trenholm argued that the PSA unfairly lowered the actual cash value (ACV) of their vehicles, resulting in reduced insurance payments. They claimed the PSA did not account for reasons a vehicle might sell below list price, such as special discounts, and excluded transactions where vehicles sold above the list price. According to the plaintiffs, this method breached Progressive’s standard auto policy, which required payment of the “market value, age, and condition” of the vehicle at the time of loss.