1. Why was notice issued?
2. What is a class action?
3. What is this lawsuit about?
4. Why is there a settlement?
5. How do I know if I am in the Settlement Class?
6. What does the Settlement provide?
7. How much will my cash payment be?
8. When will I get my payment?
9. How do I get a payment?
10. What am I giving up if I stay in the Class?
11. What happens if I do nothing at all?
12. How will the lawyers be paid?
13. How will the lawyers be paid?
14. How do I get out of the Settlement?
15. If I don’t exclude myself, can I sue the Defendant for the same thing later?
16. If I exclude myself, can I get anything from this Settlement?
17. How do I object to the Settlement?
18. What’s the difference between objecting and excluding myself from the Settlement?
19. When and where will the Court decide whether to approve the Settlement?
20. May I speak at the hearing?
21. May I speak at the hearing?
22. Where do I get more information?
A Court authorized the Notice because you have a right to know about a proposed Settlement of this class action lawsuit and about all of your options, before the Court decides whether to give final approval to the Settlement. The Notice explains the lawsuit, the Settlement, and your legal rights.
The case is called Jane Doe v. Reid Health, Case No. 89D01-2311-PL-000074, pending in Wayne County Superior Court, State of Indiana. The person who sued is called the Plaintiff. The Defendant is Reid Health.
Back To Top
In a class action, one or more people called the class representatives (in this case, Jane Doe) sued on behalf of a group or a “class” of people who have similar claims. In a class action, the court resolves the issues for all class members, except for those who exclude themselves from the Class.
Back To Top
This lawsuit claims that Defendant violated the law by disclosing patients’ confidential personally identifiable information (“PII”) and/or protected health information (“PHI”) (collectively referred to as “Private Information”) to third-party technologies without consent. Defendant firmly denies all of Plaintiff’s claims in the lawsuit and maintains that it did nothing wrong.
Back To Top
By agreeing to settle, both sides avoid the cost and risk of a trial, and people who submit valid, timely claims will get compensation. The Class Representatives and their counsel believe the Settlement is fair, reasonable, and adequate and, thus, best for the Settlement Class and its members. The Settlement does NOT mean that Defendant did anything wrong.
Back To Top
The Settlement Class is defined as:
“All Indiana citizens Private Information was allegedly disclosed to third parties through Reid Health’s use of the Meta pixel or any other website tracking, analytics and/or advertising technologies on its Websites.“
Excluded from the Settlement Class are: (1) any Judge presiding over this Action, any members of the Judges’ respective staffs, and immediate members of the Judge’s family; (2) officers and directors of the Defendant, its agents, affiliates, subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendant or its parents have a controlling interest; (3) persons who timely and validly request exclusion from and/or opt-out of the Settlement Class; (4) the legal representatives, successors or assigns of any such excluded persons; and (5) Class Counsel.
Back To Top
Monetary Relief and Privacy Shield Product: Each Settlement Class Member will automatically receive a code to enroll in the Medical Shield product. The code is listed at the top of the Notice. Each Settlement Class Member may also file a timely, valid claim for a cash payment of $25.00. In addition, Defendant has agreed to pay the costs of notice and administration of the Settlement, approved attorneys’ fees and costs to Class Counsel, and an incentive award to the Class Representative. To submit a claim, you can do so online here , or you may download a claim form here to be mailed to the Settlement Administrator.
A detailed description of the settlement benefits can be found in the Settlement Agreement.
Back To Top
You must submit a Claim Form (see instructions in FAQ 9) to receive a payment. If you submit a valid Claim Form and elect to receive a cash payment, you will receive a $25.00 cash payment.
You must verify you are a Settlement Class member when filing a claim by providing the Unique ID and PIN Number printed on the Notice you may have received by email. If for some reason you did not receive this information, but believe you are a Settlement Class Member, please call 1-844-496-1154 or email info@ReidHospitalPixelSettlement.com to verify your identity and receive further information on how to file a claim.
Back To Top
The hearing to consider the fairness of the settlement is scheduled for December 9, 2025, at 1:30 p.m. If the Court approves the settlement, eligible Class Members whose claims were approved by the Settlement Administrator will receive their payment forty-five (45) days after the Settlement has been finally approved and any appeals process is complete. The payment will be made in the form of a check, unless you elect to receive payment by PayPal, Venmo, or Zelle, and all checks will expire and become void 180 days after they are issued.
Back To Top
You must complete and submit a Claim Form to receive a payment. You may submit a Claim Form either electronically on this Settlement Website by clicking here, or by printing and mailing in a paper Claim Form, copies of which are available for download here. Claim Forms must be submitted online by 11:59 p.m. EST on December 24, 2025, or postmarked and mailed by December 24, 2025.
Back To Top
If the Settlement becomes final, you will give up your right to sue Defendant for the claims this Settlement resolve. The Settlement Agreement describes the specific claims you are giving up against the Defendant. You will be “releasing” the Defendant and their affiliates described in Section 1.25 of the Settlement Agreement. Unless you exclude yourself (see FAQ 14), you are “releasing” the claims, regardless of whether you submit a claim or not. The Settlement Agreement is available here.
The Settlement Agreement describes the released claims with specific descriptions, so read it carefully. If you have any questions you can talk to the lawyers listed in FAQ 12 for free or you can, of course, talk to your own lawyer if you have questions about what this means.
Back To Top
If you do nothing, you won’t get any benefits from this Settlement. But, unless you exclude yourself, you won’t be able to start a lawsuit or be part of any other lawsuit against the Defendant for the claims being resolved by this Settlement.
Back To Top
The Court has appointed CohenMalad LLP, Stranch, Jennings & Garvey PLLC, and Strauss Borrelli PLLC, to be the attorneys representing the Settlement Class. They are called “Class Counsel.” They believe, after conducting a thorough investigation, that the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your expense.
Back To Top
Class Counsel’s attorneys’ fees, costs, and expenses will be paid separately by Defendant and awarded by the Court. Class Counsel is entitled to seek no more than $500,000.00, but the Court may award less than this amount. As approved by the Court, the Class Representative will separately be paid an incentive award by Defendant for helping to bring and settle the case. The Class Representative may seek up to $5,000.00 as an incentive award, but the Court may award less than this amount.
Back To Top
to exclude yourself from the Settlement, you must mail or otherwise deliver a letter (or request for exclusion) stating that you want to be excluded from the settlement. Your letter or request must be in writing and must: (i) identify the case name and number (Jane Doe v. Reid Health, Case No. 89D01-2311-PL-000074); (ii) state the name. current address, telephone number, and Unique ID of the Class Member seeking exclusion; (iii) be physically signed by the person(s) seeking exclusion; and (iv) must also contain a statement to the effect that “I hereby request to be excluded from the Settlement Class for purposes of this Settlement.” You must mail or deliver your exclusion request no later than October 25, 2026, to:
Reid Health Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Back To Top
No. Unless you exclude yourself, you give up any right to sue the Defendant for the claims being resolved by this Settlement.
Back To Top
No. If you exclude yourself you will not be entitled to any benefits of the settlement, and you should not submit a Claim Form to ask for benefits.
Back To Top
If you’re a Class Member, you can object to the Settlement if you don’t like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views. To object, you must file a letter or brief stating that you object to the Settlement in Jane Doe v. Reid Health, Case No. 89D01-2311-PL000074, which must be personally signed, and identify all reasons for your objections.
Your letter or brief must include: (1) the objector’s name and address; (2) an explanation of the basis upon which the objector claims to be a Settlement Class Member; (3) all grounds for the objection, including all citations to legal authority and evidence supporting the objection; (4) the name and contact information of any and all attorneys representing, advising, or in any way assisting the objector in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection (the “Objecting Attorneys”); (5) a statement indicating whether the objector intends to appear at the Final Approval Hearing (either personally or through counsel who files an appearance with the Court in accordance with the Local Rules); and (6) a list, by case name, court, and docket number, of all other cases in which the objector and/or the Objecting Attorneys have filed an objection to any proposed class action settlement within the last three (3) years.
All objections must be submitted to the Settlement Administrator, Class Counsel, and to the Court as identified below. Class Counsel will file with the Court and post on this website its request for attorneys’ fees no later than 15 days before the Objection Deadline.
If you want to appear and speak at the Final Approval Hearing to object to the Settlement, with or without a lawyer (explained below in answer to FAQ 21), you must say so in your letter or brief. File the objection with the Court and mail a copy to these two different places postmarked no later than October 25, 2025.
Court | Class Counsel | Defendants’ Counsel |
Clerk’s Office Wayne | Lynn A. Toops | Kimberly Castellino Metzger |
Back To Top
Objecting simply means telling the Court that you don’t like something about the Settlement. You can object only if you stay in the Class. Excluding yourself from the Class is telling the Court that you don’t want to be part of the Settlement Class. If you exclude yourself, you have no basis to object because the case no longer affects you.
Back To Top
The Court will hold the Final Approval Hearing at 1:30 p.m. on December 9, 2025, at the Wayne County Superior Court, 301 E Main St, Richmond, IN 47374. The hearing may be held remotely, and if so, instructions will be posted on the Settlement Website. The purpose of the hearing will be for the Court to determine whether to approve the Settlement as fair, reasonable, adequate, and in the best interests of the Settlement Class; to consider the Class Counsel’s request for attorneys’ fees and expenses; and to consider the request for an incentive award to the Class Representative. At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement.
The hearing may be postponed to a different date or time without notice, so it is a good idea to check this website for updates.
Back To Top
No. Class Counsel will answer any questions the Court may have. But you are welcome to come at your own expense. If you send an objection or comment, you don’t have to come to Court to talk about it. As long as you filed and mailed your written objection on time, the Court will consider it. You may also pay for your own lawyer to attend, but it’s not required.
Back To Top
You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must include in your letter or brief objecting to the settlement a statement saying that it is your “Notice of Intent to Appear in Jane Doe v. Reid Health, Case No. 89D01-2311-PL000074.” It must include your name, address, telephone number and signature as well as the name and address of your lawyer, if one is appearing for you. Your objection and notice of intent to appear must be filed with the Court and postmarked no later than October 25, 2025, and be sent to the addresses listed in FAQ 17.
Back To Top
This website and the Notice summarize the Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement, along with other case-related, on the Important Documents page. You may also contact the Settlement Administrator with questions by calling (844) 496-1154 or writing to Reid Health Settlement, c/o Settlement Administrator, P.O. Box 25226, Santa Ana, CA 92799. You may also call Class Counsel listed in FAQ 17, if you have any questions. Before doing so, however, please read this website and the full Notice carefully.
Back To Top
Do not contact the Court or Clerk of Court regarding this Settlement.