A Court authorized a Notice because you have a right to know about the proposed Settlement of this class action and about all of your options before the Court decides whether to grant Final Approval of the Settlement. The Notice explains the Action, your legal rights, what benefits are available, and who can receive them.

The Action is called In re ApolloMD Data Breach Litigation, Case No.: 1:25-cv-05439-SEG pending in the United States District Court for the Northern District of Georgia, Atlanta Division. The people who filed this Action are called the “Plaintiffs” and the company they sued, ApolloMD Business Services LLC (“ApolloMD”), is called the “Defendant.”
 

On or about May 22, 2025, the Defendant was alerted to unusual activity in its information technology network. Upon investigation, the Defendant learned that between May 22, 2025, and May 23, 2025, an unauthorized third party may have accessed and/or acquired files containing Private Information of patients treated by the Defendant’s affiliated physicians and practices (the “Data Incident”). Private Information means some combination of the following: names, dates of birth, addresses, diagnosis information, provider names, dates of service, treatment information, health insurance information, and Social Security numbers. For a list of the Affiliated Healthcare Providers, please see Addendum A to the Settlement Agreement.. The Defendant caused notice to be sent to individuals whose Private Information may have been impacted in the Data Incident in two waves—the first wave was mailed beginning on September 17, 2025 and the second wave was in March 2026. The Complaint alleges claims of negligence and breach of implied contract, among others. The Defendant denies all of the Plaintiffs’ claims and maintains that it did not do anything wrong.
 

In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals who sue are known as “Class Representatives” or Plaintiffs. Together, the people included in the class action are called a “Settlement Class” or “Settlement Class Members.” One court resolves the lawsuit for all Settlement Class Members, except for those who exclude themselves (sometimes called, “opting out”) from a settlement. 

In this Action, the Class Representatives are Lee Flint, Shawanna Townsend, Paul Brini, Cathy O’Donnell, Cynthia Hall, Sarah Inman, Evelyn Adams, Lauren McEntee, , Pamela Govan, Dominique Williams, and Carita Matthres.

The Court did not decide in favor of the Plaintiffs or the Defendant. The Defendant denies all claims and contends that it has not violated any laws. The Plaintiffs and the Defendant agreed to a Settlement to avoid the costs and risks of a trial, and, through the Settlement, Settlement Class Members are eligible to claim benefits. The Plaintiffs and their attorneys, who also represent Settlement Class Members as “Class Counsel,” think the Settlement is best for all Settlement Class Members. 

The Settlement Class consists of all individuals residing in the United States who were sent a notice of the Data Incident indicating their Private Information may have been impacted by the Data Incident. 

Yes. Excluded from the Settlement Class are: the Defendant and the Defendant’s parents, subsidiaries, affiliates, officers and directors, and any entity in which Defendant has a controlling interest; all individuals who timely and properly opt out of the Settlement; any and all federal, state, or local governments, including but not limited to their departments, agencies, divisions, bureaus, boards, sections, groups, counsels, and/or subdivisions; and all judges assigned to hear any aspect of this litigation, as well as their immediate family members; and any person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding, or abetting any criminal activity related to the Data Incident, or who pleads nolo contendere to any such charge.
 

Under the proposed Settlement, the Defendant will pay $4,020,000.00 into a Settlement Fund to resolve the Action. The Settlement Fund will provide Cash Payments and Medical Data Monitoring for Settlement Class Members who submit Valid Claims, as well as Settlement Administration Costs and Attorneys’ Fees and Costs awarded by the Court.
 

Settlement Class Members may choose to receive either Cash Payment A or Cash Payment B:
(1)    Cash Payment A - Documented Losses: Reimbursement of up to $5,000.00 for reasonable documented losses from fraud and/or identity theft related to the Data Incident; or 
(2)    Cash Payment B - Alternate Cash: An alternate cash payment estimated at $75.00.
In addition to Cash Payment A or Cash Payment B, Settlement Class Members may also make a claim for one year of Medical Data Monitoring.
 

Settlement Class Members may submit a claim of up to $5,000.00 for reasonable documented losses from fraud and/or identity theft related to the Data Incident. Reasonable third-party documentation must be provided. Examples of reasonable third-party documentation include, but are not limited to, telephone records, correspondence (including emails), and receipts. Personal certifications, declarations, or affidavits from the Settlement Class Member do not constitute reasonable documentation, but may be included to provide clarification, context, or support for other submitted reasonable documentation. 

If you do not submit reasonable documentation or your claim for Cash Payment A is rejected by the Settlement Administrator for any reason, and you fail to cure your claim for Documented Losses, it will be rejected and become a claim for Cash Payment B. 
 

As an alternative to Cash Payment A, Settlement Class Members may submit a claim to receive a cash payment estimated to be $75.00 (Cash Payment B). This payment amount may be adjusted up or down on a pro rata (proportional) basis (see Question 11). No documentation is required to submit a claim for Cash Payment B.
 

In addition to Cash Payment A or Cash Payment B, Settlement Class Members may also submit a claim for Medical Data Monitoring that will include one year of CyEx’s medical data monitoring product that will include: real time monitoring of the credit file with one credit bureau; dark web scanning with immediate notification of potential unauthorized use; security freezing assistance; victim assistance; $1,000,000.00 in identity theft insurance with no deductible; and access to fraud resolution agents to help investigate and resolve instances of identity theft. No documentation is required to submit a claim for Medical Data Monitoring.
 

All Cash Payments will be subject to a pro rata (proportional) adjustment based on the amount of Valid Claims filed and the amount of money left in the Settlement Fund after all Settlement Administration Costs and Attorneys’ Fees and Costs awarded by the Court are paid (the “Net Settlement Fund”). Valid Claims for Settlement Class Member Benefits will be calculated and distributed from the Net Settlement Fund in the following order: Medical Data Monitoring Services, Cash Payment A – Documented Losses, and Cash Payment B – Alternate Cash.
 

Unless you opt out of the Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against the Defendant or Released Parties about any of the legal claims this Settlement resolves. The Releases section in the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The Settlement Agreement can be found here. 
 

To receive Settlement Class Member Benefits, you must submit a Claim Form, with any necessary documentation, online by 11:59 p.m. ET on September 30, 2026 on this Settlement Website, or by mail, postmarked by September 30, 2026, to: 
 

Settlement Administrator - #83375
c/o Kroll Settlement Administration LLC
P.O. Box 5324
New York, NY 10150-5324
 

Claim Forms are available on the Settlement Website or by calling (833) 980-0984.
 

The short answer is – after the Settlement is “finally approved” and any challenges to that approval are finally resolved. The Court is scheduled to hold a Final Approval Hearing on October 5, 2026, at 10:00 a.m. ET, at the Richard B. Russell Federal Building and United States Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303-3309, Courtroom 2307, to decide whether to approve the Settlement and the Application for Attorneys’ Fees and Costs for Class Counsel for representing the Settlement Class.

If the Court approves the Settlement, there may be appeals. It is always uncertain whether appeals will be filed and, if so, how long it will take to resolve them. Settlement Class Member Benefits will be distributed as soon as possible, if and when the Court grants Final Approval of the Settlement and after any appeals are resolved.
 

Yes, the Court appointed Jeff Ostrow of Kopelowitz Ostrow P.A. and Casondra Turner of Milberg PLLC as Class Counsel. You will not be charged directly for these lawyers; instead, they will be paid out of the Settlement Fund (subject to Court approval). If you want to be represented by your own lawyer, you may hire one at your own expense.

It is not necessary for you to hire your own lawyer because Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel will ask the Court to approve attorneys’ fees of up to 33 percent of the Settlement Fund ($1,340,000.00), plus reimbursement of costs. If approved, these amounts will be paid from the Settlement Fund before making payments to Settlement Class Members who submit Valid Claims.

If you do not want to receive any benefits from the Settlement, and you want to keep your right to separately sue the Defendant about the legal issues in this case, you must take steps to exclude yourself from the Settlement Class. This is called “opting out” of the Settlement Class. The deadline to opt out of the Settlement by submitting an “opt-out request” is August 31, 2026.
 

To exclude yourself from the Settlement, you must submit a written opt-out request that includes:

• Your name, Class Member ID, address, telephone number, and email address (if any)
• A statement indicating that you want to be excluded from the Settlement Class, such as, “I hereby request to be excluded from the proposed Settlement Class in In re ApolloMD Data Breach Litigation, Case No.: 1:25-cv-05439-SEG”; and
• Your personal signature.

All opt-out requests must be mailed to the Settlement Administrator at the address below, postmarked on or before, August 31, 2026.
 

Settlement Administrator - #83375
c/o Kroll Settlement Administration LLC
ATTN: Opt-Out Request
P.O. Box 5324
New York, NY 10150-5324

If you are a Settlement Class Member, you can choose (but are not required) to object to the Settlement if you do not like it or a portion of it, whether that be to the Settlement Class Member Benefits, the Application for Attorneys’ Fees and Costs, the Releases provided to the Defendant, or some other aspect of the Settlement. Through an objection, you give reasons why you think the Court should not approve the Settlement. Objections must be submitted in writing and must include: 
 

• Your full name, mailing address, telephone number, and email address (if any);
• The case name and number, In re ApolloMD Data Breach Litigation, Case No.: 1:25-cv-05439-SEG;
• Documentation sufficient to establish membership in the Settlement Class, such as a copy of the Postcard Notice you received;
• All grounds for the objection, accompanied by any legal support for the objection known to you or your counsel;
• The identity of all counsel representing you (if any), including any former or current counsel who may be entitled to compensation for any reason related to the objection to the Settlement and/or Application for Attorneys’ Fees and Costs;
• A list, including case name, court, and docket number, of all other cases in which you and/or your counsel and/or your counsel’s law firm have filed an objection to any proposed class action settlement in the past five (5) years, as well as a copy of any orders or rulings related to the prior objections that were issued by the trial and appellate courts in each listed case;
• A list of all persons who will be called to testify at the Final Approval Hearing in support of your objection (if any);  
• A statement whether you and/or your counsel will appear at the Final Approval Hearing;
• Whether you and/or your counsel utilized artificial intelligence to create the objection; and
• Your signature (an attorney’s signature is not sufficient).

Objections must be filed with the Court no later than August 31, 2026.

Richard B. Russell Federal Building and United States Courthouse
75 Ted Turner Drive, SW
Atlanta, GA 30303-3309
 

A copy of your objection also must be mailed to Class Counsel, Defendant’s Counsel, and the Settlement Administrator at the addresses below, postmarked no later than August 31, 2026.
 

Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from it. Excluding yourself from the Settlement means telling the Court you do not want to be part of the Settlement. If you exclude yourself or opt out of the Settlement, you cannot object to it because the Settlement no longer affects you.
 

The Court is scheduled to hold a Final Approval Hearing on October 5, 2026 at 10:00 a.m. ET, at the Richard B. Russell Federal Building and United States Courthouse, 75 Ted Turner Drive, SW, Atlanta, GA 30303-3309, Courtroom 2307, to decide whether to approve the Settlement and Class Counsel’s Application for Attorneys’ Fees and Costs of $1,340,000.00, plus reimbursement of costs. The date and time of this hearing may change without further notice. Please check this Settlement Website for updates.
 

No. Class Counsel will answer any questions the Court may have. You may attend at your own expense. If you file an objection, you may, but you do not have to come to the Final Approval Hearing to talk about it. If you file your written objection on time and in accordance with the requirements above, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.
 

If you are a Settlement Class Member and you do nothing, you will give up your right to start a lawsuit, continue a lawsuit, or be part of any other lawsuit against the Defendant and the Released Parties, as defined in the Settlement Agreement, about the legal issues resolved by this Settlement. In addition, you will be bound by the Releases in the Settlement Agreement and will not be eligible to receive any Settlement Class Member Benefits.
 

The Notice summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement. The Settlement Agreement, Long Form Notice, and other related documents are available here.

If you have additional questions or need to update your address, you may contact the Settlement Administrator toll free at (833) 930-0984 or by mail at Settlement Administrator - #83375, c/o Kroll Settlement Administration LLC, P.O. Box 5324, New York, NY 10150-5324.