Frequently Asked Questions

The Court authorized this Notice because you have a right to know about the settlement, and all of your options, before the Court decides whether to grant final approval and make the settlement Final. This Notice explains the nature of the lawsuit that is the subject of the settlement, the general terms of the settlement, and your legal rights and options.

The Honorable Judge Andrea R. Wood of the Circuit Court of Sangamon County, Illinois is overseeing this case captioned as Tambroni, et al. v WellNow Urgent Care, P.C., et al., Case No. 2025LA000013. The people who brought the lawsuit are called the Representative Plaintiffs. The companies being sued, WellNow Urgent Care, P.C., ADMI Corp. d/b/a TAG – The Aspen Group, Physicians Immediate Care LLC, Physicians Immediate Care Chicago PLLC, and Aspen Dental Management, Inc. are called the Defendants.

The Civil Action arises from Plaintiffs’ allegation that on April 25, 2023, Defendants discovered that an unauthorized actor had gained access to files containing information pertaining to approximately 597,000 individuals for whom Defendants held personal information, known as the Data Security Incident. After investigating, Defendants published notice of the Data Security Incident in February 2024. 

Defendants deny any wrongdoing whatsoever. No court or other judicial body has made any judgment or other determination that Defendants have done anything wrong.
 

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

The Court has not decided in favor of the Plaintiffs or Defendants. Instead, both sides agreed to the settlement. The settlement avoids the cost and risk of a trial and related appeals, while providing benefits to Settlement Class Members. The Representative Plaintiffs appointed to represent the Settlement Class, and the attorneys for the Settlement Class (also referred to as Class Counsel), think the settlement is best for all Settlement Class Members.

There are two subclasses that make up the Settlement Class:

                 Non-SSN Class Members – You are a Non-SSN Class Member if you were identified as one of the approximately 541,870 individuals within the United States of America who had Non-Social Security Number personal information exposed to unauthorized third parties as a result of the Data Security Incident.
                 SSN Class Members – You are an SSN Class Member if you identified as one of the approximately 55,131 Settlement Class Members whose personal information, including Social Security Numbers, was impacted in the Data Security Incident.

The Settlement Class specifically excludes: (a) Defendants and their respective officers and directors; (b) all Settlement Class Members who timely and validly request exclusion from the Settlement Class; (c) the Judge and/or magistrate assigned to evaluate the fairness of this settlement; and (d) any other Person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding, or abetting the Data Security Incident or who pleads nolo contendre to any such charge.
 

If you are not sure whether you are included in the settlement, you may call (833) 421-4559 with questions. You may also write with questions to:

Settlement Administrator - 83193
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
 

Settlement Class Members under the Settlement Agreement may submit a Claim to receive:

• Non-SSN Settlement Benefits: Non-SSN Settlement Class Members shall have the opportunity to submit a Claim for Non-SSN Settlement Benefits. The benefits available to Non-SSN Settlement Class Members are (a) Lost-Time Claims; and (b) actual and documented Extraordinary Out-of-Pocket Expense Claims.
  • Lost-Time Claims: Non-SSN Settlement Class Members may submit a Claim for up to two (2) hours of time spent related to the Data Security Incident at $25 per hour if the Settlement Class Member (i) attests that any claimed lost time was spent related to and arising out of the Data Security Incident and (ii) provides a brief general description of how the claimed lost time was spent. No documentation need be submitted in order to be eligible to receive the benefit of Lost-Time Claims.
  • Extraordinary Out-of-Pocket Expense Claims: Non-SSN Settlement Class Members may submit a Claim for reimbursement of actual and documented out-of-pocket losses up to $7,500 per Claimant, reasonably and fairly traceable to the Data Security Incident. 
    1. Extraordinary Out-of-Pocket-Expense Claims include unreimbursed losses relating to fraud or identity theft; professional fees including attorneys’ fees, accountants’ fees, and fees for credit report services; costs associated with freezing or unfreezing credit with any credit reporting agency; credit monitoring costs incurred on or after April 25, 2023, that the Claimant attests under penalty of perjury were directly caused by the Data Security Incident, through  Jully 11, 2025; and miscellaneous expenses such as notary, data charges (if charged based on the amount of data used), fax, postage, copying, mileage, cell phone charges (only if charged by the minute), and long-distance telephone charges. 
    2. Non-SSN Settlement Class Members with Extraordinary Out-of-Pocket Expense Claims must submit both documentation and attestation supporting their claims. 
    3. Documentation may include receipts or other documentation. “Self-prepared” documents such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but may be considered to add clarity or support to other submitted documentation. Extraordinary Out-of-Pocket Expense Claims must include an attestation by the Claimant that the monetary losses are fairly traceable to the Data Security Incident and were not incurred due to some other event or reason.
• SSN Settlement Fund Benefits: The SSN Settlement Fund Benefits are (a) Pro Rata Cash Payments; (b) Lost-Time Claims, and (c) Extraordinary Out-of-Pocket Expense Claims, as outlined below. These benefits shall be paid entirely from the $1,100,000 SSN Settlement Fund after the deduction of (a) 10% of Notice and Settlement Administration Costs and (b) 10% of attorneys’ fees, costs, and service awards approved by the Court.
  1. Pro Rata Cash Payment: As an alternative to claiming reimbursement for documented extraordinary out-of-pocket losses, SSN Settlement Class Members may claim an alternative cash payment in a pro rata amount of the SSN Class Settlement Fund after reimbursement for documented Extraordinary Out-of-Pocket Expenses as well as payment of 10% of all Court-approved Notice and Settlement Administration Costs, service awards, attorneys’ fees, costs, and litigation expenses. SSN Settlement Class Members claiming Extraordinary Out-of-Pocket Expenses are not eligible to also claim a Pro Rata Cash Payment.
  2. Lost-Time Claims: SSN Settlement Class Members may submit a Claim for up to three (3) hours of time spent remedying issues related to the Data Security Incident at $25 per hour if the Settlement Class Member:
     1. attests that any claimed lost time was spent related to and arising out of the Data Security Incident, and 
     2. provides a brief general description of how the claimed lost time was spent. No documentation need be submitted in order to be eligible to receive the benefit of Lost-Time Claims.
  3. Extraordinary Out-of-Pocket Expense Claims: SSN Settlement Class Members may submit a Claim for up to $7,500 per individual for actual and documented extraordinary out-of-pocket losses reasonably and fairly traceable to the Data Security Incident. 
     1. Extraordinary Out-of-Pocket Expense Claims will include, without limitation:
        • unreimbursed losses relating to fraud or identity theft; professional fees including attorneys’ fees, accountants’ fees, and fees for credit repair services; costs associated with freezing or unfreezing credit with any credit reporting agency; credit monitoring costs incurred on or after April 25, 2023, that the Claimant attests under penalty of perjury were caused or otherwise incurred as a result of the Data Security Incident, through July 11, 2025; and miscellaneous expenses such as notary, data charges (if charged based on the amount of data used), fax, postage, copying, mileage, cell phone charges (only if charged by the minute), and long-distance telephone charges. 
     2. SSN Settlement Class Members with Extraordinary Out-of-Pocket Expense Claims must submit documentation and attestation supporting their claims. 
        • This may include receipts or other documentation. “Self-prepared” documents such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but may be considered to add clarity or support to other submitted documentation. Extraordinary Out-of-Pocket Expense Claims must include an attestation by the Claimant that the monetary losses are fairly traceable to the Data Security Incident and were not incurred due to some other event or reason.
• SSN Settlement Class Members may choose either: Extraordinary Out-of-Pocket losses and Lost-Time benefits OR Pro Rata Cash Payment and Lost-Time benefits as available to them under the settlement.
   

To receive a settlement payment, you must complete and submit a Claim Form here or by mail to Settlement Administrator - 83193, c/o Kroll Settlement Administration LLC, P.O. Box 225391, New York, NY 10150-5391. Read the Claim Form instructions carefully, fill out the Claim Form and submit online by July 11, 2025, or by mail postmarked by July 11, 2025.

TO RECEIVE AN ELECTRONIC OR ACH PAYMENT FOR YOUR VALID CLAIM, YOU MUST FILE A CLAIM FORM ONLINE HERE

The Court will hold a Final Fairness Hearing on August 15, 2025, at 11 a.m. CT to decide whether to approve the settlement. If the Court approves the settlement, there may be appeals from that decision and resolving them can take time. It also takes time for all of the Claim Forms to be processed. Please be patient. Payments will begin after the settlement has obtained Court approval and the time for all appeals has expired.

Defendants and its affiliates will receive a release from all claims that could have been or that were brought against Defendants relating to the Data Security Incident. Thus, if the settlement becomes Final and you do not exclude yourself from the settlement, you will be a Settlement Class Member and you will give up your right to sue Defendants and the Defendant Released Parties and each of their past or present parents, subsidiaries, divisions, and related or affiliated entities, and each of their respective predecessors, successors, directors, officers, principals, agents, attorneys, insurers and reinsurers, and includes, without limitation, any Person related to any such entity who is, was or could have been named as a defendant in any of the actions in the Civil Action. This release is described in the Settlement Agreement, known as Released Claims, which is available here. If you have any questions, you can talk to the law firms listed in Question 16 for free or you can talk to your own lawyer.

No. If you exclude yourself, you will not be entitled to receive any benefits from the settlement.

No. Unless you exclude yourself, you give up any right to sue Defendants and any other Defendant Related Entities for any claim that could have been or was brought relating to the Data Security Incident. You must exclude yourself from the settlement to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. 

To exclude yourself, send an opt-out request or written notice of intent to opt-out that says you want to be excluded from the settlement. The written notice must clearly manifest the Settlement Class Member’s intent to opt-out of the Settlement Class. You must mail your opt-out request to the Settlement Administrator postmarked by July 11, 2025, to:

Settlement Administrator - 83193
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
 

You can tell the Court that you do not agree with the settlement or some part of it by objecting to the settlement. For an objection to be a valid objection under the settlement, it shall state: 

1. the objector’s full name and address; 
2. the case name and docket number: Tambroni, et al. v. WellNow Urgent Care, P.C., et al., Case No. 2025LA000013 
3. a written statement of all grounds for the objection, including whether the objection applies only to the objector, to a subset of the Settlement Class, or to the entire Settlement Class, accompanied by any legal support for the objection the objector believes applicable; 
4. the identity of any and all counsel representing the objector in connection with the objection; 
5. a statement whether the objector and/or his or her counsel will appear at the Final Fairness Hearing; and 
6. the objector’s signature or the signature of the objector’s duly authorized attorney or other duly authorized representative (if any) representing him or her in connection with the objection.

To be timely, written notice of an objection in the appropriate form must be mailed, with a postmark date no later than July 11, 2025, to Defendants’ Counsel and Class Counsel at the following addresses:

The objector or his or her counsel may also file an objection with the Court through the Court’s Odyssey system, with service on Class Counsel and Defendants’ Counsel, to be made through the Odyssey system. For all objections mailed to Class Counsel and Defendants’ Counsel, Class Counsel will file them with the Court as an exhibit to Representative Plaintiffs’ motion for final approval.
 

Objecting is telling the Court that you do not like the settlement or parts of it and why you do not think it should be approved. You can object only if you are a Settlement Class Member. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class and do not want to receive any payment from the settlement. If you exclude yourself, you have no basis to object because you are no longer a Settlement Class Member, and the case no longer affects you. 

Yes. The Court appointed David Almeida and Britany Kabakov of Almeida Law; Laura Van Note of Cole & Van Note; Brandon Wise of Peiffer Wolfe Carr Kane Conway & Wise; and Andrew Heldut and Evan Meyers of McGuire Law, as Class Counsel to represent the Settlement Class in settlement negotiations. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel may petition the Court for an award of attorneys’ fees, inclusive of any costs and expenses of the Civil Action, in an amount not to exceed $1,452,000, which equals 33% of the sum of the SSN Settlement Fund and the cap on Non-SSN Settlement Benefits. Class Counsel, in their sole discretion, shall allocate and distribute attorneys’ fees, costs, and expenses awarded by the Court among them.

Subject to Court approval, Defendants have agreed to not object to a request for a service award in the amount of $2,000 to each Representative Plaintiff, for a total of $16,000.

Any award of attorneys’ fees, costs, expenses, and service award is intended to be considered by the Court separately from the Court’s consideration of the fairness, reasonableness, and adequacy of the settlement.
 

The Court will hold a Final Fairness Hearing at 11AM CT on August 15  2025, via Zoom videoconference (Meeting ID: 9692307334; Password: 889222) as ordered by the Court. At this hearing, the Court will consider whether the settlement is fair, reasonable, and adequate. If there are timely and valid objections, the Court will consider them and will listen to people who have asked to speak at the hearing if such a request has been properly made. The Court will also rule on the award of attorneys’ fees, inclusive of any costs and expenses. After the hearing, the Court will decide whether to approve the settlement. We do not know how long these decisions will take. The hearing may be moved to a different date or time without additional notice, so Class Counsel recommends checking this Settlement Website, or calling (833) 421-4559.

No. Class Counsel will present the Settlement Class to the Court. You or your own lawyer are welcome to attend at your expense, but you are not required to do so. If you send an objection, you do not have to visit the Court to talk about it. As long as you filed your written objection on time with the Court and mailed it according to the instructions provided in Question 14, the Court will consider it.

You may ask the Court for permission to speak at the Final Fairness Hearing. To do so, you must file an objection according to the instructions in Question 14, including all the information required

If you do nothing, you will not receive any benefits from this settlement. If the settlement is granted final approval and becomes Final, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants or the other Defendant Related Entities based on any claim that could have been or that was brought relating to the Data Security Incident.

This Notice summarizes the settlement. More details are in the Settlement Agreement itself.  A copy of the Settlement Agreement is available here. You may also call the Settlement Administrator with questions or to receive a Claim Form at (833) 421-4559.

It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below or on the Contact Us page of the Settlement Website.

Settlement Administrator - 83193
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

PLEASE DO NOT CONTACT THE COURT, OR CLERK OF THE COURT FOR INFORMATION ABOUT THE CLASS ACTION SETTLEMENT