Civil Action No. 1:23-cv-1029-AJT-IDD in United States District Court for the Eastern District of Virginia (Alexandria Division)

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A proposed class action settlement may affect your rights.

This notice explains the Settlement, the Settlement Class, and your legal rights and options. Please read the entire notice carefully.

You should:
1. Read this notice.
2. If you do not want to remain in the Class, submit an opt-out request by Tuesday, June 18, 2024.


Important things to know:

  • If you remain in the Settlement Class and the Court approves the Settlement, you will receive a monetary payment.
  • If you take no action, you will still be bound the Settlement and its releases.
  • You can learn more at: Important Court Documents.


If you do nothing, you will receive a settlement payment and the other relief described in this Notice and you will be bound by the Court’s decisions regarding the Settlement. You will not be able to pursue any potential claims against the Defendant that have been released as part of the Settlement. Review the full release at Important Court Documents


You can opt out of the Settlement if you want to maintain any legal rights you may have against Defendant. But if you opt out, you will not receive a settlement payment or other relief provided under the Settlement if the Court grants final approval.

To opt out from the Settlement, you must send a written request addressed to the Settlement Administrator and state that you wish to be excluded from the Settlement and include the information discussed in more detail in this Notice. The opt-out deadline is Tuesday, June 18, 2024.


You have the right to write to the Court to object to the Settlement if you believe it is unfair. You would remain a part of the Class and be bound by the Court’s decisions regarding the Settlement. The objection deadline is Tuesday, June 18, 2024.