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You are a Settlement Class Member if you are a Person residing in the United States to whom Inline sent its notice of a Data Security Incident that Inline discovered on or about March 12, 2022.
The Settlement Class specifically excludes: (i) Inline Network Integration LLC (“Inline”); (ii) the Related Entities; (iii) all Settlement Class Members who timely and validly request exclusion from the Settlement Class; (iv) any judges assigned to this case and their staff and family; and (v) any other Person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the criminal activity occurrence of the Data Security Incident or who pleads nolo contendere to any such charge.
This website explains the nature of the Lawsuit and claims being settled, your legal rights, and the benefits to the Settlement Class.
This case is known as Cline v. Inline Network Integration LLC, Civil Action No.: 2023LA000402 (“Lawsuit”), filed in Illinois Circuit Court of the 18th Judicial Circuit, County of DuPage. The Persons who sued are called the “Plaintiffs” and the company they sued, Inline Network Integration LLC, is known as the “Defendant” in this case. Inline will be called “Defendant” on this website.
Plaintiffs filed a Lawsuit against Defendant, individually, and on behalf of anyone whose Private Information was potentially impacted as a result of the Data Security Incident.
This Lawsuit arises out of potential unauthorized access to Defendant’s systems and certain files containing sensitive information including, but not limited to, for some Persons full names, addresses, and Social Security Numbers. Such unauthorized access was discovered by Inline on or about March 12, 2022 (the “Data Security Incident”). After learning of the Data Security Incident, Defendant mailed notification to persons whose Private Information may have been impacted by the Data Security Incident on or about June 2022. Subsequently, this Lawsuit was filed asserting claims against Defendant relating to the Data Security Incident.
Defendant denies any wrongdoing.
The proposed Settlement will provide the following benefits to Settlement Class Members:
Expense Reimbursement
Documented Ordinary Loss Expense Reimbursement: All Settlement Class Members who submit a valid claim using the Claim Form are eligible for the following documented (except lost time, as defined below) ordinary loss expense reimbursement, not to exceed $500 per Settlement Class Member: (a) documented out-of-pocket expenses that were incurred as a result of the Data Security Incident, which may include: (i) bank fees, long distance phone charges, cell phone charges (only if charged by the minute), data charges (only if charged based on the amount of data used), postage, or gasoline for local travel, (ii) fees for credit reports, credit monitoring, or other identity theft insurance product purchased between March 12, 2022, and the date of the Settlement Agreement.
This list of reimbursable documented out-of-pocket expenses is not meant to be exhaustive, rather it is exemplary. Settlement Class Members may make claims for any documented out-of-pocket losses reasonably related to the Data Security Incident or to mitigating the effects of the Data Security Incident. The Claims Administrator shall have discretion to determine whether any claimed loss is reasonably related to the Data Security Incident.
To receive reimbursement for any of the above-referenced documented ordinary loss expenses, Settlement Class Members must submit a valid and timely Claim Form, including necessary supporting documentation, to the Claims Administrator.
Lost Time Reimbursement: Settlement Class Members are also eligible to receive reimbursement for up to three (3) hours of lost time spent dealing with the Data Security Incident (calculated at the rate of $20 per hour) for a maximum of up to $60 per Person. Settlement Class Members may receive reimbursement for lost time if the Settlement Class Member certifies that the lost time was spent responding to the Data Security Incident. Claims made for lost time can be combined with reimbursement for documented ordinary loss expense reimbursement and are subject to the same $500 documented ordinary loss expense reimbursement cap for all Settlement Class Members.
Documented Extraordinary Loss Reimbursement: Settlement Class Members who were the victim of actual documented identity theft are also eligible to receive reimbursement for documented extraordinary losses, not to exceed $5,000 per Settlement Class Member, including proven actual monetary losses, provided that: (i) the loss is an actual, documented, and unreimbursed monetary loss; (ii) the loss was more likely than not caused by the Data Security Incident; (iii) the loss occurred between March 12, 2022, and the date of the Settlement Agreement; (iv) the loss is not already covered by one or more of the normal reimbursement categories; and (v) the Settlement Class Member made reasonable efforts to avoid, or seek reimbursement for, the loss, including but not limited to exhaustion of all available credit monitoring insurance and identity theft insurance.
Credit Monitoring: Settlement Class Members shall be offered an opportunity to enroll in credit monitoring and identity theft protection with $1 million in insurance. Settlement Class Members who did not enroll in credit monitoring previously offered by Inline will be offered 2 years of credit monitoring. Settlement Class Members who did enroll in credit monitoring previously offered by Inline will be offered an extension of one additional year of credit monitoring. This is subject to confirmation that Inline has the ability to identify those persons who previously enrolled and offer this extension.
The maximum amount to be paid by Inline and its insurer is capped at no more than $750,000. In the unlikely event that the Notice and Claims Administration Costs would otherwise exceed $750,000, payments to Settlement Class Members will be reduced on a pro rata basis.
If the Settlement is Finally approved by the Court, Settlement Class Members who make timely, valid claims for credit monitoring services will be provided with codes required to activate these services.
Remedial Relief: Inline will continue to provide security for Private Information and protected health information in its possession, custody or control. These security measures will be paid for by Inline separate and apart from other Settlement benefits.
If you stay in the Settlement Class, you will be eligible to receive benefits, but you will not be able to sue Inline Network Integration LLC its Related Entities, and each of their past or present parents, subsidiaries, divisions, and related or affiliated entities, and each of their respective predecessors, successors, assigns, owners, directors, officers, employees, principals, agents, attorneys, insurers, and reinsurers (collectively, the “Released Persons”) regarding the claims in this case.
The Settlement Agreement, which includes all provisions about settled claims, releases, and Released Persons, is available on the Documents section of this website.
The only way to keep the right to sue is to exclude yourself (see Question 10), otherwise you will be included in the Settlement Class, and, if the Settlement is approved, you give up the right to sue for the claims in this case.
If you do not want to be included in the Settlement, you must send a timely written Opt-Out Request, stating your full name, address, and telephone number. Your Opt-Out Request must be personally signed by you and contain your original signature (or the original signature of a Person previously authorized by law, such as a trustee, guardian, or Person acting under power of attorney to act on your behalf with respect to a claim or right, such as those in the Lawsuit). Your request must also clearly manifest your intent to be excluded from the Settlement Class, to be excluded from the Settlement, not to participate in the Settlement, and/or to waive all rights to the benefits of the Settlement.
Your written Opt-Out Request must be postmarked no later than December 6, 2023 to:
If you want to tell the Court that you do not agree with the proposed Settlement or some part of it, you must file an Objection with the Court telling it why you do not think the Settlement should be approved.
Objections must be submitted in writing and include all the following information:
Your Objection must be filed with the Clerk of Court and include the case name and docket number, Cline v. Inline Network Integration LLC, Civil Action No.: 2023LA000402 (“Lawsuit”), filed in Illinois Circuit Court of the 18th Judicial Circuit, County of DuPage (the “Inline Action”) to be received no than December 6, 2023 at:
Office of the Circuit Court Clerk
505 N. County Farm Road
Wheaton, IL 60187-0707
In addition, you must concurrently mail or hand deliver a copy of your Objection to Settlement Class Counsel and Inline Counsel, postmarked no later than December 6, 2023:
CLASS COUNSEL | INLINE (DEFENSE) COUNSEL |
Gary M. Klinger, Esq. MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN PLLC 227 W. Monroe Street Suite 2100 Chicago, IL 60606 | Jon Kardassakis LEWIS BRISBOIS BISGAARD & SMITH LLP 633 West 5th Street, Suite 4000 Los Angeles, California 90071 |
If you do not submit your Objection with all requirements, or if your Objection is not received by December 6, 2023, you will be considered to have waived all Objections and will not be entitled to speak at the Final Approval Hearing.
The Court will hold the Final Approval Hearing on December 13, 2023, at 9:30 a.m. CT in Courtroom 2018, of the Circuit Court of DuPage County, Illinois, 505 N. County Farm Road, Wheaton, IL 60187. The hearing may be moved to a different date, time, or location without additional notice, so it is recommended that you periodically check this website for updated information.
At the hearing, the Court will consider whether the proposed Settlement is fair, reasonable, adequate, and is in the best interests of Settlement Class Members, and if it should be Finally approved. If there are valid Objections, the Court will consider them and will listen to people who have asked to speak at the hearing if the request was made properly. The Court will also consider the Award of attorneys’ fees, costs, and expenses to Settlement Class Counsel and the request for a Service Award to the Settlement Class Representatives.
No. You are not required to come to the Final Approval Hearing. However, you are welcome to attend the hearing at your own expense.
If you submit an Objection, you do not have to come to the hearing to talk about it. If your Objection was submitted properly and on time, the Court will consider it. You also may pay your own lawyer to attend the Final Approval Hearing, but that is not necessary. However, you must follow the requirements for making objections in Question 15, including the requirements for making appearances at the hearing.
This is only a summary of the proposed Settlement. If you want additional information about this Lawsuit, including a copy of the Settlement Agreement, the Complaint, the Court’s Preliminary Approval Order, Settlement Class Counsel’s Motion for attorneys’ fees, costs, expenses, and Service Award for Settlement Class Representatives, and more, please visit the Documents section of this website or call (833) 933-6680. You may also contact the Claims Administrator at Cline v. Inline Network Integration LLC, c/o Kroll Settlement Administration, PO Box 5324, New York, NY 10150-5324.
PLEASE DO NOT ADDRESS ANY QUESTIONS ABOUT THE SETTLEMENT OR LITIGATION TO THE CLERK OF THE COURT, THE JUDGE, DEFENDANT, OR INLINE’S COUNSEL.