[brief] Plaintiff is a sophisticated, highly educated individual that operates multiple businesses, including a neurosurgery medical practice, “medical-legal consulting business,” medical billing company, and race car team, and works with an accountant and lawyer.  (Pa005, Pa007-Pa011, Pa013, Pa016-Pa017).  [...] is a licensed insurance broker employed by [...], which is an insurance and financial services business in Pennsylvania.  (Pa005-Pa007).  [...] is another licensed insurance professional at [...], who was held out as a “disability insurance expert” that advised on coverage.  (Pa006-Pa007).  Plaintiff alleges that he turned to Defendants for various insurance and financial services needs for approximately 20 years.  (Pa007-Pa025).  Plaintiff alleges that “Defendants held themselves and their agents out as highly skilled insurance experts and financial consultants, possessing the special knowledge and expertise needed to market, sell, interpret and understand all insurance policies sold” to Plaintiff.  (Pa011).  Plaintiff continues that as insurance producers, brokers, and agents selling insurance in New Jersey, Defendants --- 1  The parties are constrained to accept as true the allegations asserted in the Complaint at this stage of litigation, though [...] and [...] deny all claims and crossclaims.  See Malik v. Ruttenberg, 398 N.J. Super. 489, 494 (App. Div. 2008) (“Thus, like the trial court, this court must accept as true the facts alleged in the complaint, and credit all reasonable inferences of fact therefrom, to ascertain whether there is a claim upon which relief can be granted. ”) (citing Donato v. Moldow, 374 N.J. Super. 475, 483 (App. Div. 2005); Seidenberg v. Summit Bank, 348 N.J. Super. 243, 250 (App. Div. 2002)). owed a fiduciary duty to and had a special relationship with Plaintiff.  (Pa011 – Pa012).  Plaintiff alleges that Defendants, with Plaintiff’s accountant and lawyer, assisted with obtaining disability and business overhead expense insurance policies for his medical practice.  (Pa007 – Pa025).  Nowhere in the 46-page Complaint is there any assertion that the relevant services or policies are of the type that are sold or marketed for mass distribution to the general public.  (Pa004-Pa049).  Instead, Plaintiff’s Complaint is replete with assertions about the specific nature of his insurance needs having provided details on all aspects of his personal, business, and investment dealings and expressing concerns about his particular situation – mainly, coverage for if or when a disability prevented Plaintiff from performing neurosurgery.  (Pa007-Pa025).  Plaintiff stopped performing neurosurgery in September 2021 because his maculopathy reduced his vision, thus causing him to cease earning income as a neurosurgeon and divest his interest in his medical practice.  (Pa025).  Plaintiff then made a claim for “maximum benefits” under the disability and business overhead expense policies in December 2021.  (Pa025).  Plaintiff alleges that one insurer, [...], made only partial payments under its policy because it considered his other income sources, such as Plaintiff’s “medical-legal consulting business” and a litigated dispute with his former business partner.  (Pa025 – Pa030).  Plaintiff claims he went through great lengths to fight for “maximum payments” under the policies, but despite Defendants’ representations otherwise, [...] refused to pay him “full benefits. ” (Pa025 – Pa030).  Plaintiff asserts causes of action sounding in professional negligence (Count I), negligence *per se* under N.J.A.C. 11:17A-4.10 (Count II), negligent misrepresentation (Count III), breach of fiduciary duties (Count IV), common law fraud (Count V), fraud in the inducement (Count VI), under the CFA (Count VII), breach of the insurance professional special relationship (Count VIII), and breach of contract (Count IX).