Doe et al. v. Knox College, Inc.

Case No. 2023LA9
Knox County Circuit Court
in the Ninth Judicial Circuit, State of Illinois

Doe et al. v. Knox College, Inc.
Case No. 2023LA9, Knox County Circuit Court
in the Ninth Judicial Circuit, State of Illinois

• A settlement has been reached in a class action lawsuit filed against Knox College, Inc. (the “Defendant”) regarding a security breach of their IT system (the “Data Incident”) that occurred in approximately November 2022, when an unauthorized party accessed its computer system which contained names, dates of birth, addresses, driver’s license numbers, passport numbers, and Social Security numbers (“Private Information”) of some current and former students, applicants, and family members of students and applicants.

• On January 20, 2023, Jane Doe (the “Plaintiff”) filed a Class Action Complaint against the Defendant in the United States District Court for the Central District of Illinois, Case No. 4:23-cv-04012-SLD-JEH (“Doe Class Action”). On February 2, 2023, Rachael Morrissey filed a Complaint, and then a First Amended Class Action Complaint, against Defendant in the same Court, Case No. 4:23-cv-04019-SLD-JEH. On February 3, 2023, Le’Andra Mosley filed a Class Action Complaint against the Defendant in the same Court, Case No. 4:23-cv-04023-SLDS-JEH. These three actions were subsequently consolidated into the Doe Class Action. The consolidated Doe Class Action was voluntarily dismissed and Plaintiffs Jane Doe, Rachel Morrissey, Le’Andra Mosley, and Catherine Peck (“Plaintiffs” or “Settlement Class Representatives”) refiled a Class Action Complaint in the Circuit Court of Knox County, Illinois, Ninth Judicial District, Case No. 2023LA9 (“Litigation”). Defendant and Plaintiffs in the Litigation are collectively referred to herein as the “Parties.”

• Following arms-length negotiations, the Parties negotiated a settlement with the assistance of Hon. Morton Denlow (ret.) at a mediation on April 24, 2023, by which the Parties agree and hereby wish to resolve all matters pertaining to, arising from, or associated with the Litigation, including all claims Plaintiffs and Class Members have or may have had against Defendant and related persons and entities, as set forth herein.

• Class Members are eligible to receive the following relief: (1) compensation for Unreimbursed Economic Losses, up to a total of $2,500 per person, upon submission of a valid and timely Claim with supporting documentation, for unreimbursed monetary losses incurred as a result of the Data Incident; (2) compensation for up to four (4) hours of Lost Time, at $25.00/hour ($100.00 cap), for time spent mitigating the effects of the Data Incident - Claims for Lost Time can be combined with Claims for Unreimbursed Economic Loss but are subject to the $2,500.00 cap; and (3) three (3) years of one-bureau Credit Monitoring Services provided by Experian or other comparable provider, regardless of whether the Class Member submits a Claim for reimbursement of Unreimbursed Economic Losses or Lost Time. In the alternative to compensation for Unreimbursed Economic Losses, Lost Time, or Credit Monitoring, Class Members can elect to make a Claim for a $100 Alternative Cash Payment. To receive this benefit, Class Members must submit a timely and valid Claim Form. In the event that Approved Claims for Settlement Benefits (i.e., Credit Monitoring Services, Unreimbursed Economic Losses, Lost Time, and Alternative Cash Payments) exceeds the amount of the Net Settlement Fund, the amount to be paid for Approved Claims shall be reduced on a pro rata basis and paid in accordance with the terms and conditions in the Settlement Agreement. In the event the Net Settlement Fund exceeds the Approved Claims for Settlement Benefits (i.e., Credit Monitoring Services, Unreimbursed Economic Losses, Lost Time, and Alternative Cash Payments), then the Residual Funds shall be paid in accordance with the terms of the Settlement Agreement. 


YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

Submit A Claim Form

This is the only way you may receive benefits from this Settlement. The Claims Deadline is January 24, 2024.

Exclude Yourself from the settlement

“Opt-Out”

Get out of the lawsuit and the settlement. This is the only option that allows you to ever bring or join another lawsuit raising the same legal claims against the Defendant. You will receive no payment or Credit Monitoring Services under this settlement.  The Opt-Out Deadline to exclude yourself from the settlement is December 26, 2023.

Object to the settlement

Write to the Court, with a copy to Class Counsel and Defendant’s Counsel, about any aspect of the settlement you don’t like or you don’t think is fair, adequate, or reasonable. (If you object to any aspect of the settlement, you must submit a written objection and that objection must be received by the Deadline. Your objection must follow the Objection Procedures stated herein). The deadline to object to the Settlement is December 26, 2023.

Attend the Final Approval Hearing

You may ask the Court for permission for you or your attorney to speak about your objection at the Final Approval Hearing. (If you object to any aspect of the Settlement, you must submit a written objection by the objection Deadline noted above. If you Opt-Out of the settlement you cannot object.) The Final Approval Hearing will be held on January 19, 2024.

Do Nothing

If you do nothing you will not receive any payment or the free Credit Monitoring Services. You will have no right to sue the Defendant later for the claims released by the Settlement.

This website is authorized by the Court, supervised by Counsel for the Parties and controlled by Kroll Settlement Administration LLC, the Settlement Administrator approved by the Court. This is the only authorized website for this case.
Call
(833)-383-9695
Mail
Knox College Data Breach c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324

Important Dates

  • Opt-Out Deadline

    Tuesday, December 26, 2023 You must complete and mail your Request for Exclusion form so that it is postmarked no later than Tuesday, December 26, 2023.
  • Objection Deadline

    Tuesday, December 26, 2023 You must mail your objection(s) and/or notice of intent to appear at the Final Approval Hearing so that it/they are postmarked no later than Tuesday, December 26, 2023.
  • Claim Form Deadline

    Wednesday, January 24, 2024 You must submit your Claim Form online no later than Wednesday, January 24, 2024 or mail your completed paper Claim Form so that it is postmarked no later than Wednesday, January 24, 2024.
  • Final Approval Hearing

    Friday, January 19, 2024 The Final Approval Hearing is scheduled for Friday, January 19, 2024. Please check this website for updates.

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