Frequently Asked Questions

The Court authorized the Notice because you have a right to know about the Settlement, and all of your options, before the Court decides whether to grant final approval and make the Settlement final. The Notice explains the nature of the lawsuit that is the subject of the Settlement, the general terms of the Settlement, and your legal rights and options.

The Honorable Timothy P. Dillon of the Superior Court of the State of California, County of Los Angeles is overseeing this case captioned as Warren v. Pomona Valley Hospital Medical Center, Case No. 243STCV05324. The Person who brought the lawsuit is called the Class Representative. The entity being sued, Pomona Valley Hospital Medical Center, is called the Defendant.

The Action arises from Plaintiffs’ allegations against PVHMC alleging that its use of the “Facebook Pixel” and similar technology on its public website, located at https://pvhmc.org (i.e., the PVHMC Website), violated wiretapping and other statutes, called the Website Usage Disclosure. 

Defendant denies any wrongdoing whatsoever. No court or other judicial body has made any judgment or other determination that Defendant has done anything wrong.

In a class action, one or more people called Class Representatives sue on behalf of all people who have similar claims. Together, all of these people are called a Settlement Class, and the individuals are called Participating Settlement Class Members. One court resolves the issues for all Participating Settlement Class Members, except for those who exclude themselves from the Settlement Class.

The Court has not decided in favor of the Plaintiffs' or Defendant. Instead, both sides agreed to this Settlement. The Settlement avoids the cost and risk of a trial and related appeals, while providing benefits to Participating Settlement Class Members. The Class Representative appointed to represent the Settlement Class, and the attorneys for the Settlement Class (also referred to as Class Counsel) think the Settlement is best for all Settlement Class Members.

The Settlement Class means:
 

All California residents who visited the PVHMC Website and logged into the patient portal between January 1, 2019, through December 31, 2022.
 

Excluded from the Settlement Class are (1) the Judge(s) presiding over the Action, Class Counsel, and members of their families; (2) PVHMC and its subsidiaries, parent companies, successors, predecessors, and any entity in which PVHMC or its parents, have a controlling interest, and its current or former officers and directors; (3) Persons who properly execute and submit a Request for Exclusion prior to the expiration of the Opt-Out Period; and (4) the successors or assigns of any such excluded Persons.

If you are not sure whether you are included in the Settlement, you may call (833) 630-9966 with questions. You may also write with questions to:

PVHMC Website Usage Disclosure Action
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

The Settlement provides a Settlement Fund of $600,000 to be used to pay for: (i) all Administrative Expenses; (ii) any Taxes; (iii) any Service Payments; (iv) any Fee and Expense Award; (v) Settlement Payments and/or Settlement Benefits; and (viii) any other Settlement Benefits.

Participating Settlement Class Members under the Settlement Agreement may receive:

• Pro Rata Cash Fund Settlement Payments: Each Participating Settlement Class Member will automatically receive a check or electronic payment for a pro rata cash fund Settlement Payment

To receive a Settlement Payment, you do not need to do anything, unless you would like to receive an electronic payment. If you do not request exclusion from the Settlement, you will automatically receive a Settlement Payment.

TO RECEIVE AN ELECTRONIC OR ACH PAYMENT FOR YOUR SETTLEMENT PAYMENT, PLEASE VISIT HERE

The Court will hold a Final Fairness Hearing on January 5, 2026, at 10 a.m. PT to decide whether to approve the Settlement. You do not need to attend the Final Fairness Hearing. If the Court approves the Settlement, there may be appeals from that decision and resolving them can take time. Please be patient. Payments will begin after the Settlement has obtained Court approval and the time for all appeals has expired.

Defendant and its affiliates will receive a release from all claims that could have been or that were brought against Defendant relating to the Website Usage Disclosure. Thus, if the Settlement becomes final and you do not exclude yourself from the Settlement, you will be a Participating Settlement Class Member and you will give up your right to sue Defendant and all of its respective past, present, and future parent companies, partnerships, subsidiaries, affiliates, divisions, employees, servants, members, providers, partners, principals, directors, shareholders, and owners, and all of their respective attorneys, heirs, executors, administrators, insures, coinsurers, reinsurers, joint ventures, personal representatives, predecessors, successors, transferees, trustees, and assigns, and include, without limitation, any Person related to any such entities who is, was, or could have been named as a defendant in the Action. This release is described in the Settlement Agreement, known as Released Claims, which is available on the Documents Page. If you have any questions, you can talk to the law firms listed in Question 16 of the Notice for free or you can talk to your own lawyer.

No. If you exclude yourself, you will not be entitled to receive any benefits from the Settlement.

No. Unless you exclude yourself, you give up any right to sue Defendant and any other Released Parties for any claim that could have been or was brought relating to the Website Usage Disclosure. You must exclude yourself from the Settlement to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. 

To exclude yourself, send a Request for Exclusion or written notice of intent to opt-out that says you want to be excluded from the Settlement in Warren v. Pomona Valley Hospital Medical Center, Case No. 243STCV05324. Requests for Exclusion must be in writing and must identify the case name Warren v. Pomona Valley Hospital Medical Center, 23STCV05324 (Los Angeles Superior Court); state the name, address and telephone number of the Settlement Class Members seeking exclusion; be physically signed by the Person(s) seeking exclusion; and must also contain a statement to the effect that “I/We hereby request to be excluded from the proposed Settlement Class in Warren v. Pomona Valley Hospital Medical Center, 23STCV05324 (Los Angeles County Superior Court).” You must mail your Request for Exclusion to the Settlement Administrator postmarked by Tuesday, December 9, 2025, to:

PVHMC Website Usage Disclosure Action
Attn: Request for Exclusion
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

Any Person who elects to request exclusion from the Settlement Class shall not (i) be bound by any orders or Judgment entered in the Action, (ii) be entitled to relief under this Agreement, (iii) gain any rights by virtue of this Agreement, or (iv) be entitled to object to any aspect of this Agreement. No Person may request to be excluded from the Settlement Class through “mass” or “class” opt-outs.

You can tell the Court why you agree or disagree with the Settlement by filing an objection. For an objection to be a valid objection under the Settlement, it must be in writing, mailed to the Settlement Administrator, and be postmarked no later than Tuesday, December 9, 2025, to the following address:

All written objections must include the following:

1. the case name Warren v. Pomona Valley Hospital Medical Center, Case No. 23STCV05324 (Los Angeles Superior Court);
2. the Settlement Class Member’s full name, current physical mailing address, and telephone number;
3. a statement indicating whether the objection applies only to the objector, a subset of the Settlement Class, or the entire Settlement Class;
4. the specific grounds for the objection; and
5. all documents or writings that the Settlement Class Member desires the Court to consider.

Objecting is telling the Court that you do not like the Settlement or parts of it and why you do not think it should be approved. You can object only if you are a Participating Settlement Class Member. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class and do not want to receive any payment from the Settlement. If you exclude yourself, you have no basis to object because you are no longer a Participating Settlement Class Member, and the case no longer affects you.

Yes. The Court appointed John J. Nelson of Milberg Coleman Bryson Phillips Grossman, PLLC and Robert Ahdoot of Ahdoot & Wolfson PC as Class Counsel to represent the Settlement Class. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel will file a motion for an award of the Fee and Expense Award of up to 33% (or $200,000) to be paid from the Settlement Fund and subject to Court approval. Any such award would compensate Class Counsel for investigating the facts, litigating the case, and negotiating the Settlement and will be the only payment to them for their efforts in achieving this Settlement and for their risk in undertaking this representation on a wholly contingent fee basis.

Class Counsel will also ask the Court for Service Payment not to exceed $3,500 to be awarded and approved by the Court, and be paid from the Settlement Fund, in recognition of the Class Representatives' contributions to this Action.

The Court may hold a Final Fairness Hearing at 10AM PT on January 5, 2026, at the Spring Street Courthouse 312 North Spring Street, Los Angeles, CA 90012, as ordered by the Court. If there are no objections, the Court may rule on final approval without a Final Fairness Hearing. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely and valid objections, the Court will consider them. The Court will also rule on any motion seeking payment of the Fee and Expense Award, as well as the Service Payment. After the hearing, the Court will decide whether to approve the Settlement. We do not know how long these decisions will take. The hearing may be moved to a different date or time without additional notice.

No. Class Counsel will represent the Settlement Class before the Court. You or your own lawyer are welcome to attend at your expense, but you are not required to do so. If you send an objection, you do not have to visit the Court to talk about it. As long as you filed your written objection on time with the Court and mailed it according to the instructions provided in Question 14, the Court will consider it.

You may ask the Court for permission to speak at the Final Fairness Hearing. The Court may hear from any Class Member who attends the Final Fairness Hearing and asks to speak, regardless as to whether the Class Member has submitted an Objection in compliance with Section 14 above.

If you do nothing, you will still receive a Settlement Payment from this Settlement. If the Settlement is granted final approval and becomes Final, you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendant or the other Released Parties based on any claim that could have been or that was brought relating to the Website Usage Disclosure.

The Notice summarizes the Settlement. More details are in the Settlement Agreement itself.  A copy of the Settlement Agreement is available here. You may also call the Settlement Administrator with questions at (833) 630-9966.

It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below, by calling toll-free (833) 630-9966 or at the Contact section of the Settlement Website.

PVHMC Website Usage Disclosure Action
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

PLEASE DO NOT CONTACT THE COURT, CLERK OF THE COURT OR DEFENDANT FOR INFORMATION ABOUT THE CLASS ACTION SETTLEMENT

Email Notices have been sent to Settlement Class Members from the domain “[email protected]”. Postcard Notices will be sent out in the coming weeks.. Kroll Settlement Administration (KSA) is the Settlement Administrator for the Warren v. Pomona Valley Hospital Medical Center Settlement, and these notices contain information about your rights and options under the Settlement.