Doe et al. v. Knox College, Inc.

• 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.