Abubaker v. Dominion Dental USA, Inc. et al.

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Notice of Dominion National Security Incident Class Action Settlement

• A Settlement Agreement has been reached in a class action lawsuit against Dominion Dental USA, Inc., Dominion Dental Services USA, Inc., Dominion National Insurance Company, Dominion Dental Services of New Jersey, Inc., and Dominion Dental Services, Inc. (collectively “Dominion National”) and Avalon Insurance Company, Capital Advantage Insurance, Capital BlueCross, and Providence Health Plan (collectively “Defendants”), arising out of the security incident that Dominion National announced on June 21, 2019, wherein Dominion National’s computer network system was the target of an external unauthorized cyberattack that began on or around August 25, 2010 (the “Security Incident”).
• If you received a notice from or on behalf of Dominion National about the Security Incident, you are included in this Settlement as a “Class Member.”
• Under the Settlement, Dominion National has agreed to compensate certain losses arising from the Security Incident:
• Reimbursement for Lost Time: Receive cash payments for lost time spent responding to the Security Incident, up to five (5) hours of lost time, at $20/hour (up to $100), if at least one full hour was spent dealing with the Security Incident. You may receive compensation by submitting a certification describing the time you spent.
• Reimbursement for Ordinary Losses: Receive cash payments for ordinary losses incurred responding to the Security Incident, up to $300 per person, upon submission of a claim and supporting documentation for (a) out of pocket expenses incurred as a result of the Security Incident, including bank fees, long distance phone charges, cell phone charges (only if charged by the minute), data charges (only if charged based on amount of data used), postage, or gasoline for local travel; and (b) fees for credit reports, credit monitoring, or other identity theft insurance product purchased between August 14, 2019 and July 19, 2021.
• Reimbursement for Extraordinary Losses: Receive cash payments for extraordinary losses incurred responding to the Security Incident, up to $7,500 per person for proven monetary loss, if (a) the loss is an actual, documented, and unreimbursed (except from the claimant’s insurer) monetary loss; (b) the loss was fairly and reasonably traceable to the Security Incident; (c) the loss occurred between August 25, 2010 and January 15, 2022; (d) the loss is not already covered by one or more of the normal reimbursement categories; and (e) the loss exceeds all available credit monitoring insurance and identity theft insurance provided to the claimant by Dominion National. Dominion National’s aggregate compensation shall be capped at $2 million.
• If qualifying claims exceed $2 million in losses, compensation will be reduced pro rata. In addition, Dominion National has agreed to provide additional security measures with an approximated value of $2,679,500. Dominion National will also pay the costs of the settlement administration, court-approved attorneys’ fees and expenses, and service awards for named Plaintiffs.
• Your legal rights will be affected whether you act or do not act. You should read the entire Notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
FILE A CLAIM FORM DEADLINE: JANUARY 15, 2022	Submitting a Claim Form is the only way that you can receive any of the benefits provided by this Settlement, including reimbursement of Out-of-Pocket Losses of money, expenses incurred, and/or time spent addressing, or reimbursement for extraordinary losses fairly and reasonably traceable to the Security Incident. If you submit a Claim Form, you will give up the right to sue the Defendants and certain related parties in a separate lawsuit about the legal claims this Settlement resolves.
EXCLUDE YOURSELF FROM THIS SETTLEMENT DEADLINE: OCTOBER 2, 2021	This is the only option that allows you to be part of another lawsuit against the Defendants, or certain related parties, for the claims this Settlement resolves. If you exclude yourself, you will give up the right to receive any benefits from this Settlement.
OBJECT TO OR COMMENT ON THE SETTLEMENT DEADLINE: OCTOBER 2, 2021	You may object to the Settlement by writing to the Court and informing the Court why you don’t think the Settlement or the requested attorney’s fees and expenses should be approved. You also may write the Court to provide comments or reasons why you support the Settlement. If you file an objection to the Settlement, you must also serve a copy on the claim administrator at Dominion National Security Incident Settlement, Attn: Objections, P.O. Box 58220, Philadelphia, PA 19102.
GO TO THE FINAL FAIRNESS HEARING DATE: NOVEMBER 19, 2021	You can attend the Final Fairness Hearing where the Court may hear arguments concerning approval of the Settlement. If you wish to speak at the Final Fairness Hearing, you must make a request to do so in your written objection or comment. You are not required to attend the Final Fairness Hearing.
DO NOTHING	If you do nothing, you will not receive any of the Settlement benefits and you will give up your rights to sue Defendants and certain related parties for the claims this Settlement resolves.

• These rights and options—and the deadlines to exercise them—are explained in the Notice.
• The Court in charge of this case still has to decide whether to approve the Settlement and the requested attorneys’ fees and expenses. No Settlement benefits or payments will be provided unless the Court approves the Settlement and it becomes final.