The Court of Appeals in Fair Price Med. Supply Corp. v. Travelers Indem. Co., recently held that an insurer was required to pay no-fault benefits to a medical provider for services that were never provided. The court’s conclusion certainly shocks the conscience, yet the court determined that no other result could be reached pursuant to the no-fault regulations. The purpose of this article is to provide the insurer with a way to defend itself. This article outlines counter-claims that can be interposed at the time of pleadings, and suggests a litigation strategy for counsel representing insurance carriers who find themselves liable for overdue no-fault payments to medical providers who submit fraudulent no-fault claims. New York’s no-fault automobile insu