Frequently Asked Questions

You received this notice because your personal information may have been compromised in a data breach initially disclosed by Carl Buddig on or about April 17, 2024. A Court authorized this notice because you have a right to know how the proposed settlement may affect your rights. This notice explains the nature of the litigation, the general terms of the proposed settlement and what it may mean to you. This notice also explains the ways you may participate in, or exclude yourself from, the Settlement.

Near or around May 2023, cybercriminals obtained unauthorized access to Carl Buddig’s servers and exfiltrated the personal information of current and former employees of Carl Buddig. The personal information potentially accessed included names, Social Security numbers, and medical information.

Carl Buddig denies that it did anything wrong, and no court or other entity has made any judgment or other determination of any wrongdoing. Instead, Plaintiff and Carl Buddig have agreed to a settlement to avoid the risk, cost, and time of further litigation.

In a class action, one or more people called class representatives sue on behalf of all people who have similar claims. Together all these people are called a “Settlement Class” or “Settlement Class Members.” One court resolves the issues for all Settlement Class Members, except for those Settlement Class Members who timely exclude themselves from the Settlement Class.

The Court has not decided in favor of Plaintiff or Carl Buddig. Instead, both sides agreed to a settlement. Settlements avoid the costs and uncertainty of a trial and related appeals, while more quickly providing benefits to members of the Settlement Class.

You are a Settlement Class Member if you received this notice or you were one of the approximately 11,821 individuals who were mailed or e-mailed a notification that your personal information may have been impacted in the Data Breach in or around April 17, 2024.

Yes. Excluded from the Settlement Class is Carl Buddig, its representatives and any judicial officer presiding over this matter, members of their immediate family, and members of their immediate family and judicial staff.

If you are still not sure whether you are a Settlement Class Member, you may call the Settlement Administrator’s toll-free number at: 1-888-726-1339.

Under the Settlement, Carl Buddig will pay $850,000.00 into a Settlement Fund that will be used to provide the following benefits:

• Reimbursement for Out-of-Pocket Expenses: The settlement fund will be used to reimburse settlement class members for out-of-pocket expenses or losses traceable to the Data Breach, up to $15,000.00 per individual. This may include, but is not limited to:
  • Out-of-pocket costs, expenses, losses, or other charges incurred as a result of identity theft or identity fraud, falsified tax returns, or other possible misuse of a Settlement Class Member’s Personal Information;
  • Out-of-pocket costs incurred after the Data Breach was disclosed associated with changing accounts or engaging in other mitigative conduct, such costs may include notary, fax, postage, copying, mileage, and long-distance telephone charges;
  • Out-of-pocket professional fees incurred to address the Data Breach; and
  • Out-of-pocket purchases of credit monitoring or other mitigative services after the Data Breach was disclosed, through the date of the Settlement Class Member’s Claim submission.
• Reimbursement for Lost Time: The settlement fund will be used to reimburse settlement class members who spent addressing issues related to the Data Breach for up to twenty (20) hours at twenty-five dollars ($25) per hour, totaling $500.00 per individual.
• Free Credit Monitoring Services: The settlement fund will also be used to pay for 3-Bureau Credit Monitoring and Identity Restoration Services which will be offered to all Settlement Class Members who elect to enroll for two years.
• Additional Cash Payments: If there is money remaining after reimbursing settlement class members for Out-of-Pocket Expenses, Credit Monitoring Services, Lost Time, and other settlement related obligations, additional cash payments may be provided on a pro rata basis for claims traceable to the Data Breach among participating settlement class members up to $2,500.00. Please note that additional cash payments are not guaranteed and the amount of these payments will depend on the number of individuals who submit valid claims.
• Business Practice Commitments: Carl Buddig has agreed to implement and maintain certain business practice commitments relating to its information security program for seven years following the Settlement.

Yes. Settlement Class Members seeking reimbursement must complete and submit a Claim Form to the Settlement Administrator by May 1, 2025. Claim Forms can be submitted online or by mail. If by mail, the Claim Form must be postmarked by May 1, 2025.

Unless you exclude yourself, you are choosing to remain in the Settlement Class. If the Settlement is approved and becomes final, all of the Court’s orders will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against Carl Buddig and the Released Parties for the Released Claims.
Paragraph 34 of the Settlement Agreement defines the claims that will be released by Settlement Class Members who do not exclude themselves from the Settlement. More information regarding the Released Parties and the Released Claims can be found in the Settlement Agreement available at www.CarlBuddigSettlement.com.

To submit a claim for settlement benefits including reimbursement for Out-of-Pocket Expenses, Lost Time, Additional Cash Payments, and 3-Bureau Credit Monitoring Services, you will need to submit a claim form. There are two options for submitting claims:

(1)          Submit Online: You may fill out and submit the claim form online. This is the easiest way to file a claim.

(2)          Submit by Mail: You can download a copy of the claim form found in the Case Documents tab and mail it to the address below. Alternatively, you can ask the Settlement Administrator to mail a claim form to you by calling 1-888-726-1339. Fill out your claim form, and mail it (including postage) to:

Williams v. Carl Buddig & Company Settlement Administrator

PO Box 301174

Los Angeles, CA 90030-1174

Claims Forms must be submitted online or postmarked by May 1, 2025; otherwise you will not be entitled to any of the Settlement benefits, but you will be bound by the Settlement and the Court’s judgment.

If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by calling 1-888-726-1339 or by writing to:

Williams v. Carl Buddig & Company Settlement Administrator

PO Box 301174

Los Angeles, CA 90030-1174

If you make a valid claim, payment will be provided by the Settlement Administrator after the Settlement is approved by the Court and becomes final.

It may take time for the Settlement to be approved and become final. Please be patient and check the website for updates.

Yes, the Court has appointed Rachel Dapeer of Dapeer Law, P.A. and Mark Hammervold of Hammervold Law LLC to represent you and the Settlement Class for the purposes of this Settlement. You may hire your own lawyer at your own cost and expense if you want someone other than Class Counsel to represent you in this Lawsuit.

Class Counsel have undertaken this case on a contingency-fee basis and have not been paid any money in relation to their work on this case to date. Accordingly, Class Counsel will ask the Court to award them reimbursement for costs and expenses and attorneys’ fees of up to thirty-eight percent (38%) of the Settlement Fund to be paid from the Settlement Fund. You will not have to separately pay any portion of these fees yourself.
The Court will decide the amount of fees and costs and expenses to be paid. Class Counsel’s request for attorneys’ fees and costs (which must be approved by the Court) will be filed by February 19, 2025 and will be available to view on the Settlement Website at www.CarlBuddigSettlement.com.

To exclude yourself from the Settlement, you must mail the Settlement Administrator written notice of a request for exclusion, which includes:

(1)   The case name (Williams v. Carl Buddig and Co., Case No. 2024 CH 09830or similar identifying words such as “Carl Buddig Data Breach Lawsuit”;

(2)   Your name, address, and telephone number;

(3)   A clear statement you want to be excluded from the Settlement Class, such as “I hereby request to be excluded from the proposed Settlement Class in Williams v. Carl Buddig and Co., Case No.: 2024 CH 09830 in the Circuit Court of Cook County, Illinois; and

(4)   Your signature

The exclusion request must be postmarked and sent to the Settlement Administrator at the following address by March 12, 2025:

Williams v. Carl Buddig & Company Settlement Administrator

PO Box 301174

Los Angeles, CA 90030-1174

You cannot exclude yourself by telephone or by email.

No. If you exclude yourself, you are telling the Court you do not want to be part of the Settlement. You can only get Settlement benefits if you stay in the Settlement and submit a valid Claim Form.

No. Unless you exclude yourself, you give up any right to sue Carl Buddig and the Released Parties for the Released Claims in this Settlement. You must exclude yourself from this Lawsuit to start or continue with your own lawsuit or be part of any other lawsuit against the Defendant or any of the Released Parties. If you have a pending lawsuit, speak to your lawyer in that case immediately.

Objecting is simply telling the Court you do not like something about the Settlement or the requested attorneys’ fees and expenses. You can object only if you stay in the Settlement Class (that is, do not exclude yourself). You will still be bound by the Settlement if you object. Requesting exclusion is telling the Court you do not want to be part of the Settlement Class or the Settlement. If you exclude yourself, you cannot object to the Settlement, and you will not be bound by the Settlement and will not receive any Settlement benefits.

The Court will hold a Final Approval Hearing on April 17, 2025 at 10:30 a.m. before the Honorable Anna Loftus, Circuit Court of Cook County,  Richard J. Daley Center, 50 West Washington Street, Chicago IL 60602.

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and decide whether to approve: the Settlement, Class Counsel’s application for attorneys’ fees, costs and expenses, and a service award to Plaintiff. If there are objections, the Court will consider them. The Court will also listen to people who have asked to speak at the hearing.

Note: The date and time of the Final Approval Hearing are subject to change. The Court may also decide to hold the hearing via videoconference or by phone. Any change will be posted at www.CarlBuddigSettlement.com.

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you send an objection, you do not have to come to Court to talk about it. As long as you file or mail your written objection on time the Court will consider it.

Yes, as long as you do not exclude yourself, you can (but do not have to) participate and speak for yourself at the Final Approval Hearing. This is called making an appearance. You also can have your own lawyer speak for you. If you choose to make an appearance, you must follow all of the procedures for objecting to the Settlement listed in FAQ 19 above and specifically include a statement whether you and your counsel will appear at the Final Approval Hearing.

If you are a Settlement Class Member and you do nothing, you will not receive any Settlement benefits. You will give up the rights explained in the “Excluding Yourself from the Settlement” section of this Notice, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Carl Buddig or any of the Released Parties about the legal issues in this lawsuit that are released by the Settlement Agreement relating to the Data Breach.

This Notice summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available in the Case Documents tab, by calling 1-888-726-1339 or by writing to:

Williams v. Carl Buddig & Company Settlement Administrator

PO Box 301174

Los Angeles, CA 90030-1174

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT’S CLERK OFFICE REGARDING THIS NOTICE.