Question 1

Why is there a Notice?

Accepted Answer

You received a Notice because your personal information may have been
compromised in a data security incident involving the Clay-Platte defendants
that occurred in or about June 2024. A Court authorized the notice because you
have a right to know how the proposed settlement may affect your rights.

The Notice
[https://angeion-public.s3.amazonaws.com/www.cpfmsettlement.com/docs/Clay-Platte+-+Long+Form+Notice+FINAL.pdf]explains
the nature of the lawsuit, the terms of the proposed Settlement, who is eligible
to receive benefits from this Settlement, a description of the benefits, and how
to obtain those benefits.

Question 2

What is the lawsuit about?

Accepted Answer

Plaintiffs allege that on or around June 26, 2024, cybercriminals obtained
unauthorized access to Defendants’ servers and exfiltrated personally
identifiable information and protected health information of approximately
53,916 current and former patients of Defendants (the “Data Breach”). The
information potentially accessed included names, Social Security numbers, dates
of birth, addresses, confidential medical information, gender, and telephone
numbers.

Defendants deny that they did anything wrong, and no court or other entity has
made any judgment or other determination of any wrongdoing or that any law has
been violated. Instead, Plaintiffs and Defendants have agreed to a settlement to
avoid the risk, cost, and time of further litigation.

The specific legal claims alleged by the Plaintiffs can be viewed in Plaintiffs’
First Amended Complaint
[https://angeion-public.s3.amazonaws.com/www.cpfmsettlement.com/docs/2025+01-27+(13)+Plaintiffs'+First+Amended+Complaint.pdf].

Question 3

Why is this a class action?

Accepted Answer

In a class action lawsuit, one or more individuals (called the “Plaintiffs” or
“Named Plaintiffs”) bring claims on behalf of a larger group of people who have
similar claims (the “Settlement Class” or “Settlement Class Members”). The Court
resolves the claims for all Settlement Class Members, except for those who
choose to exclude themselves from the Settlement Class. Under the Settlement,
members of the Settlement Class who do not exclude themselves from the
Settlement are referred to as “Participating Settlement Class Members.”

Question 4

Why is there a Settlement?

Accepted Answer

The Plaintiffs and the Defendants disagree over the legal claims made in this
Action. The Action has not gone to trial, and the Court has not decided in favor
of the Plaintiffs or Defendants (collectively referred to as the “Parties”).
Instead, the Parties have agreed to settle the Action after considering the
risks and uncertainties of continuing the lawsuit, and all factors related to
the Settlement. The Parties believe that this Settlement is fair, reasonable,
adequate, and in the best interests of themselves and the Settlement Class.

Question 5

How do I know if I am part of the Settlement?

Accepted Answer

You are a Settlement Class Member if you received a Notice. The Settlement Class
includes approximately 53,916 individuals residing in the United States who were
sent notification by Defendants that their personal information and/or protected
health information was potentially compromised as a result of the data security
incident.

FAQs

Basic Information

Who is Included in the Settlement?

The Settlement Benefits

How to Get Settlement Benefits?

The Lawyers Representing You

Excluding Yourself from the Settlement

The Final Approval Hearing

If you Do Nothing

Getting More Information

Digital Payment Terms and Conditions

Basic Information

1. Why is there a Notice?

2. What is the lawsuit about?

3. Why is this a class action?

4. Why is there a Settlement?

Who is Included in the Settlement?

5. How do I know if I am part of the Settlement?

6. Are there exceptions to individuals who are included in the Settlement Class?

7. What if I am still not sure whether I am part of the Settlement?

The Settlement Benefits

8. What does the Settlement provide?

9. Are there other Settlement Benefits?

10. What am I giving up in order to receive a Settlement Benefit or stay in the Settlement Class?

11. What are the Released Claims?

How to Get Settlement Benefits?

12. How do I make a claim for Settlement Benefits?

13. Can I request a Claim Form?

14. What happens if my contact information changes after I submit a Claim Form?

15. When and how will I receive the Settlement Benefits?

The Lawyers Representing You

16. Do I have a lawyer in this case?

17. How will Class Counsel be paid?

Excluding Yourself from the Settlement

18. How do I get out of the Settlement?

19. If I exclude myself, can I still receive Settlement Benefits?

20. If I do not exclude myself, can I sue the Defendants for the same thing later?

21. How do I tell the Court that I do not like the Settlement?

22. What is the difference between objecting and requesting exclusion?

The Final Approval Hearing

23. When and where will the Court decide whether to approve the Settlement?

24. Do I have to come to the Final Approval Hearing?

25. May I speak at the Final Approval Hearing?

If you Do Nothing

26. What happens if I do nothing at all?

Getting More Information

27. How do I get more information?

Digital Payment Terms and Conditions

28. What are the terms and conditions for digital payments offered?