UNIQUE ID: AF2F7F7233

NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Young v. Military Advantage, Inc. d/b/a Military.com, Case No. 2023LA000535
(Circuit Court of DuPage County, Illinois)

Our Records Indicate You Have Subscribed to Military.com and May Be Entitled to a Payment From a Class Action Settlement.

NOTE: You will not qualify as a Class Member if you did not have an active Facebook account at the same time you subscribed to Military.com and accessed a video on Military.com.

A court authorized this notice. You are not being sued. This is not a solicitation from a lawyer.

This notice is to inform you that a settlement has been reached in a class action lawsuit claiming that Defendant, Military Advantage, Inc. d/b/a Military.com, disclosed its subscribers’ personally identifiable information (“PII”) to Facebook via the Facebook Tracking Pixel without consent in violation of the Video Privacy Protection Act (the “VPPA”). The VPPA defines PII to include information which identifies a person as having requested or obtained specific video materials or services from a video tape service provider. Defendant denies that it violated any law and denies that it disclosed any PII of its subscribers to Facebook, but has agreed to the settlement to avoid the uncertainties and expenses associated with continuing the case.

Am I a Class Member? Our records indicate you are a subscriber to Military.com and may be a Class Member. Class Members are all digital subscribers to Military.com who have a Facebook account, in the United States, and who accessed a video through the Military.com website from the same browser where the individual accessed his or her Facebook account from June 8, 2020, through November 1, 2022. If you did not have an active Facebook account at the time you subscribed to and watched a video on Military.com you are not a class member.

What Can I Get? You must submit a Claim Form here to receive a share of the Settlement Fund, which will be up to $30, subject to pro rata adjustment depending on the number of valid claims that are filed. A Settlement Fund of up to $7,350,000.00 will be established to pay all approved claims to the Settlement Class, together with notice and administrative expenses, approved attorneys’ fees and costs to Class Counsel, and Service Awards to the Class Representatives. The Settlement also requires Defendant to suspend operation of the Facebook Tracking Pixel on any pages on its website that include video content, within 45 days of the Preliminary Approval Order, for a period of at least two years from the date Military.com removes the Pixel.

How Do I Get a Payment? You must submit a timely and complete Claim Form no later than October 24, 2023. You can file a claim by clicking here. Your payment will come by check unless you elect to receive payment electronically by PayPal or Venmo. Claim Forms must be submitted online by 11:59 p.m. CT on October 24, 2023 or postmarked and mailed by October 24, 2023.

Who Represents Me? The Court has appointed lawyers Philip L. Fraietta, Joshua D. Arisohn, and Christopher R. Reilly of Bursor & Fisher, P.A. and Gary M. Klinger, Alex Honeycutt, and Alexander Wolf of Milberg Coleman Bryson Phillips Grossman PLLC to represent the class. These attorneys are called Class Counsel. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your expense.

When Will the Court Consider the Proposed Settlement? The Court will hold the Final Approval Hearing at 9:00 a.m. on November 9, 2023 in Courtroom 2018 at the DuPage County Courthouse, 505 North County Farm Road, Wheaton, IL 60187. At that hearing, the Court will: hear any objections concerning the fairness of the settlement; determine the fairness of the settlement; decide whether to approve Class Counsel’s request for attorneys’ fees and costs; and decide whether to award Class Representative David Ramirez $5,000 and Class Representatives Darrick Young and Jeremy Lam $2,500 each from the Settlement Fund for their service in helping to bring and settle this case. Defendant has agreed to pay Class Counsel reasonable attorneys’ fees in an amount to be determined by the Court. Class Counsel is entitled to seek no more than one-third of the Settlement Fund, but the Court may award less than this amount.

How Do I Get More Information? For more information, including the full Notice, Claim Form and Settlement Agreement go to www.MilitaryVPPASettlement.com, contact the Settlement Administrator at 1-877-352-0889 or Military.com Privacy Settlement, P.O. Box 2239, Portland, OR 97208-2239, or call Class Counsel at 1-646-837-7150.

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