Frequently Asked Questions

A Court authorized the Notice because you have a right to know about a proposed Settlement of this class action lawsuit and about all 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 Doe v. HSCGP, LLC, Case No. 23C2513, pending in the Fifth Circuit Court for Davidson County, Tennessee. The people who sued are called the Plaintiffs. The Defendant is HSCGP, LLC.

In a class action, one or more people called the Class Representatives (in this case, Jane Doe, Anita Augusty, Patricia Ball, Jamie Barry, Effie Carter, Evita Cooper, Demorris Gear, Dawn Harper, Barbara Janssen, Tonya Lynn Johnson, Tammie Knight, Roberta Malone Shay, Summer McDonald, Zachary Maxwell, Sharee Peacock, Kevin Prescott, Denny Randall, Cheryl Rhoades, Laura Shelton, James Shewey, Alyssa Swetlock, Betty Bogard, and Tina Tucker) sue 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.

The lawsuit alleges that HSCGP, LLC managed the websites of Serviced Companies in such a way as to disclose their patients’ personally identifiable information (“PII”) to third parties via the Meta Pixel and other tracking, analytics, and/or advertising technologies without consent in violation of applicable law. Defendant denies all of the Plaintiffs' claims in the lawsuit and maintains that it did nothing wrong.

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 attorneys 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.

The Settlement Class is defined as: 

             all United States residents who, from August 1, 2021, to June 30, 2023, accessed the Patient Portal of any                Serviced Company.

Excluded from the Settlement Class are: (1) the Judge presiding over the lawsuit, any members of the Judge’s respective staffs, and immediate members of the Judge’s family; (2) officers and directors of Defendant, its 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; and (4) the legal representatives, successors or assigns of any such excluded persons.

Monetary Relief: Each Settlement Class Member who files a valid claim will receive a cash payment of $38. In addition, Defendant has agreed to pay the costs of notice and administration of the settlement, and approved attorneys’ fees and costs to Class Counsel.

A detailed description of the settlement benefits can be found in the Settlement Agreement.

You must submit a Claim Form (see instructions below) to receive a payment. If you submit a valid Claim Form, you will receive a $38 cash payment.

You must provide proof of your Settlement Class membership when filing a claim by providing the unique Class Member ID on the notice you received by postcard. If for some reason you did not receive this information, but believe you are a Settlement Class Member, please call (833) 627-2756 to verify your identity and receive further information on how to file a claim.

The hearing to consider the fairness of the Settlement is scheduled for March 19, 2025 . If the Court approves the settlement, eligible Class Members whose claims were approved by the Settlement Administrator will receive their payment 160 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.

You must complete and submit a Claim Form to receive a payment. You may submit a Claim Form either electronically on this 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. CT on May 19, 2025 or postmarked and mailed by May 19, 2025.

If the Settlement becomes final, you will give up your right to sue Defendant and other released parties for the claims this Settlement resolves. The Settlement Agreement describes the specific claims you are giving up against Defendant. You will be “releasing” the Defendant and certain other parties described in Section 1.27 of the Settlement Agreement. You will be releasing these persons as to all claims described in Section 1.26 of the Settlement Agreement. Unless you exclude yourself (see Question 14), you are “releasing” the claims, regardless of whether you submit a claim or not. The Settlement Agreement is available through the “Documents” section on this website.

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 Question 12 for free or you can, of course, talk to your own lawyer if you have questions about what this means.

If you do nothing, you will not get any benefits from this Settlement. But, unless you exclude yourself, you will not be able to pursue a lawsuit or be part of any other lawsuit against Defendant for the claims being resolved by this Settlement.

The Court has appointed J. Gerard Stranch, IV of Stranch, Jennings & Garvey, PLLC, Lynn Toops of Cohen & Malad, LLP, and Gary Klinger of Milberg Coleman Bryson Phillips Grossman, PLLC to be the attorneys representing the Settlement Class. They are called “Class Counsel.” They believe, after conducting an extensive 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.

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 $8,000,000, but the Court may award less than this amount. Class Counsel’s fee award will not reduce any payments to Class Members.

Class Representatives may receive, subject to Court approval, Service Awards not to exceed $2,500 each.

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 in Doe v. HSCGP, LLC, Case No. 23C2513, pending in the Fifth Circuit Court for Davidson County, Tennessee. Your letter or request for exclusion must also include your name, your address, your signature, the name and number of this case, and a statement that you wish to be excluded. You must mail or deliver your exclusion request no later than February 10, 2025 to:

HSCGP Settlement 

c/o Kroll Settlement Administration LLC

PO Box 225391

New York, NY 10150-5391

No. Unless you exclude yourself, you give up any right to sue the Defendant for the claims being resolved by this Settlement.

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.

If you’re a Settlement Class Member, you can object to the Settlement if you do not 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 with the Court a letter or brief stating that you object to the Settlement in Doe v. HSCGP, LLC, Case No. 23C2513, pending in the Fifth Circuit Court for Davidson County, Tennessee, and identify all your reasons for your objections (including citations and supporting evidence) and attach any materials you rely on for your objections. Your letter or brief must also include your name, an explanation of the basis upon which you claim to be a Settlement Class Member, the name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with your objection, and your signature. If you, or an attorney assisting you with your objection, have ever objected to any class action settlement where you or the objecting attorney has asked for or received payment in exchange for dismissal of the objection (or any related appeal) without modification to the settlement, you must include a statement in your objection identifying each such case by full case caption. You must also mail or deliver a copy of your letter or brief to Class Counsel and Defendant’s Counsel listed below.

Class Counsel will file with the Court and post on this website its request for attorneys’ fees by January 27, 2025.

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 Question Number 21), you must say so in your letter or brief and file the objection with the Court and mail a copy to Class Counsel and Defendant’s Counsel postmarked no later than February 10, 2025.

Objecting simply means telling the Court that you do not like something about the Settlement, such that you believe the Court should not approve the Settlement. You can object only if you stay in the Class. Excluding yourself from the Class is telling the Court that you do not want to be part of the Class. If you exclude yourself, you have no basis to object because the case no longer affects you.

The Court will hold the Final Approval Hearing at 9:00 a.m. on March 19, 2025 in Courtroom 509 at the Historic Metro Courthouse, Fifth Circuit Court for Davidson County, 1 Public Square, Nashville, Tennessee 37201. 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 Class and to consider the Class Counsel’s request for attorneys’ fees and expenses. 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 or call (833) 627-2756.

No. Class Counsel will answer any questions the Court may have. Nevertheless, you are welcome to come at your own expense. If you submit a valid objection, you do not have to come to Court to argue it. If you filed and mailed your written objection on time, the Court will consider it. You may also pay another lawyer to attend, but that is not required.

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 Doe v. HSCGP, LLC, Case No. 23C2513.” 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 February 10, 2025, and must be sent to the addresses listed in Question 17.

The Notice summarizes the Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement from the Documents section of this website. You may also write with questions to HSCGP Settlement, c/o Kroll Settlement Administration LLC, P.O. Box 225391, New York, NY 10150-5391. You can call the Settlement Administrator at (833) 627-2756 or Class Counsel at 317-636-6481, if you have any questions. Before doing so, however, please read the full Notice carefully. You may also find additional information elsewhere on this website. For any address changes contact the Settlement Administrator listed above.

PLEASE DO NOT CONTACT THE COURT FOR INFORMATION ABOUT THE CLASS ACTION LAWSUIT SETTLEMENT