Frequently Asked Questions

The Court authorized this Notice because you have a right to know about the Settlement, and all of your options, before the Court decides whether to give Final Approval to the Settlement. This Notice explains the nature of the Action that is the subject of the Settlement, the general terms of the Settlement, and your legal rights and options.
 

The Honorable Susan M. Bazis of the United States District Court for the District of Nebraska is overseeing this case captioned as In Re: ALN Medical Management LLC Data Incident Litigation, Case No. 4:25-cv-03067-SMB-MDN. The people who brought the lawsuit are called the Class Representatives. The companies being sued are ALN Medical Management LLC (or Defendant ALN), certain of its Clients, and Long View Systems Corporation (USA) (or Defendant Long View). This Settlement involves only Defendant ALN and its Clients. The case against Defendant Long View is ongoing. Defendant Long View denies all liability and any wrongdoing.

The Action alleges that, between March 18, 2024, and March 24, 2024, an unauthorized actor accessed certain systems within Defendant ALN’s third-party hosted environment that was hosted, supported, and managed by Defendant Long View. Defendant ALN confirmed through its investigation that there was unauthorized access and/or acquisition of certain files and folders containing its current and former patients’ Private Information. That information included names, Social Security Numbers, drivers’ license numbers, government-issued ID numbers (e.g., passports, state ID cards), financial information (e.g., account number, credit or debit card number), medical information, and health insurance information.
 

Defendant ALN denies all liability and any wrongdoing whatsoever. No Court or other judicial body has made any judgment or other determination that Defendant ALN has done anything wrong.

In a class action, one or more people called “Class Representatives” or “Plaintiffs” 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 “Settlement Class Members.” One Court resolves the issues for all Settlement Class Members, except for those who exclude themselves from the Settlement Class. In this Settlement, the Class Representatives are Cameron Reed, Eugene Rosenberg, Lauren Mullis, Jeffrey Judka, Virginia Gilleland, Robert Meyers, Caroline Hurley, and Timothy Keggins.

The Court has not decided in favor of the Plaintiffs or Defendant ALN. Instead, Plaintiffs and Defendant ALN agreed to the Settlement. The Settlement avoids the cost and risk of a trial and related appeals, while providing benefits to Settlement Class Members. The Class Representatives appointed to represent the Settlement Class, and the attorneys for the Settlement Class, Class Counsel, think the Settlement is fair, adequate, reasonable, and in the best interests of the Settlement Class.

You are affected by the Settlement and potentially a Settlement Class Member if you are a living individual residing in the United States who was sent a notice from ALN Medical Management LLC of the Data Incident, which occurred in March of 2024, indicating their Private Information may have been impacted in the Data Incident.

Only Settlement Class Members are eligible to receive Benefits under the Settlement. Excluded from the Settlement Class are: (1) all persons who are parents, subsidiaries, directors, officers, members, and agents of Defendant ALN; (2) governmental entities; (3) the Judge assigned to the Action, that Judge’s immediate family, and that Judge’s chamber’s staff; and (4) all individuals who timely opt-out of the Settlement; and (5) any person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the criminal activity occurrence of the Data Incident, or who pleads nolo contendere to any such charge.

If you are not sure whether you are included in the Settlement, you may call (833) 754-8507 with questions. You may also write with questions to:

ALN Medical Management LLC Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

The Settlement provides a $4,000,000.00 Settlement Fund that will be used to pay: (1) all Settlement Class Member Benefits to Settlement Class Members who submit timely Valid Claims; (2) all Settlement Administration Costs; and (3) any attorneys’ fees, costs, and Service Awards approved by the Court. The Settlement provides the following Settlement Class Member Benefits available to Settlement Class Members who submit Valid Claims: (a) Cash Payment A – Documented Losses up to $5,000.00 per Settlement Class Member upon presentment of reasonable documentation; or (b) Cash Payment B – Alternate Cash estimated to be $50.00; and in addition to a Cash Payment, (c) Medical Data Monitoring that includes one (1) year of CyEx’s Medical Shield Complete which will provide the following benefits: one bureau credit monitoring, medical identity monitoring, real-time alerts, and insurance coverage for up to $1,000,000.00 for medical identity theft.

Settlement Class Members that submit a Valid Claim may select one of the following Cash Payments:

Cash Payment A – Documented Losses: All Settlement Class Members are eligible to submit a Claim for a Cash Payment for Documented Losses for up to $5,000.00 per Settlement Class Member upon presentment of reasonable documentation of losses related to the Data Incident.

• Documented expenses include, by way of example, unreimbursed losses relating to fraud or identity theft: if (i) the loss is an actual, documented, and unreimbursed monetary loss; (ii) the loss was more likely than not caused by the Data Incident; and (iii) the loss was incurred after the date of the Data Incident.
• To receive payment for documented losses, a Settlement Class Member must complete and submit a Claim Form and include documentation in support of the claim. 
• Except as expressly provided herein, personal certifications, declarations, or affidavits from the Settlement Class Member do not constitute proper documentation, but may be included to provide clarification, context, or support for other submitted reasonable documentation. 
• Settlement Class Members shall not be reimbursed for expenses if they have been reimbursed for the same expenses by another source, including compensation provided in connection with any credit monitoring and identity theft protection product. 
• If a Settlement Class Member does not submit documentation supporting a loss, or if the Settlement Administrator rejects for any reason the Settlement Class Member’s Claim and the Settlement Class Member fails to cure the Claim, the Claim will be converted to a Claim for Cash Payment B – Alternate Cash.

OR

Cash Payment B – Alternate Cash: As an alternative to Cash Payment A – Documented Losses above, a Settlement Class Member may elect to receive Cash Payment B – Alternate Cash, which is a Cash Payment in an estimated amount of $50.00.

Cash Payments will be subject to a pro rata increase from the Net Settlement Fund in the event the amount of Valid Claims is insufficient to exhaust the entire Net Settlement Fund. Similarly, in the event the amount of Valid Claims exhausts the amount of the Net Settlement Fund, the amount of the Cash Payments will be subject to a pro rata decrease.

In addition to electing a Cash Payment, Settlement Class Members may also elect:

Medical Data Monitoring: In addition to Cash Payment A – Documented Losses or Cash Payment B – Alternate Cash, Settlement Class Members may also make a Claim for Medical Data Monitoring that includes one (1) year of CyEx’s Medical Shield Complete. The product includes credit monitoring with one bureau, with additional monitoring of: (a) healthcare insurance plan IDs; (b) healthcare beneficiary identifier IDs; (c) medical records; (d) national provider identifiers; (e) international classification of disease; (f) health savings accounts; (g) high risk transactions; and (h), Dark Web. The product also provides for $1,000,000.00 of identity theft insurance and contains real-time alerts and victim assistance.

To receive Settlement Class Member Benefits, you must complete and submit a Claim Form online at here or by mail to ALN Medical Management LLC Data Incident Litigation, c/o Kroll Settlement Administration LLC, P.O. Box 225391, New York, NY 10150-5391. Read the Claim Form instructions carefully, fill out the Claim Form, provide the required documentation, and submit online by April 3, 2026, 11:59 p.m. CT or by mail postmarked by April 3, 2026.

The Court will hold a Final Approval Hearing on May 15, 2026, at 12:00 p.m. CT to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals from that decision and resolving them can take time. It also takes time for all of the Claim Forms to be processed. Please be patient. Payments will begin after the Settlement has obtained Court approval and the time for all appeals has expired.

Upon the Effective Date, and in consideration of the Settlement relief and other consideration described herein, Defendant ALN and the Released Parties will fully, finally, and forever be released, acquitted, relinquished, and completely discharged from any and all Released Claims. The Releasing Parties agree that, once this Agreement is executed, they will not, directly or indirectly, individually or in concert with another, maintain, cause to be maintained, or voluntarily assist in maintaining any further demand, action, claim, lawsuit, arbitration, or similar proceeding, in any capacity whatsoever, based on any of the Released Claims. These Releases are described in Section XIII of the Settlement Agreement, which is available here. If you have any questions, you can talk to the law firms listed in Question 17 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 ALN and any other Released Parties for any Claim that could have been or was brought relating to the Data Incident. 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, mail a request to opt-out that says you want to be excluded from the Settlement of In Re: ALN Medical Management LLC Data Incident Litigation, Case No. 4:25-cv-03067-SMB-MDN. The opt-out request must be personally signed by the Settlement Class Member and contain: (1) the requestor’s name, address, telephone number, and email address (if any); (2) the case name and number: In re: ALN Medical Management LLC Data Incident Litigation, Case No. 4:25-cv-03067-SMB-MDN (D. Neb.); and (3) a statement indicating a request to opt-out of the Settlement Class. Mass or class requests to opt-out filed by third parties on behalf of a mass or class of Settlement Class Members or multiple Settlement Class Members where the opt-out has not been signed by each and every individual Settlement Class Member will not be allowed. Any Settlement Class Member who does not timely and validly request to opt-out shall be bound by the terms of the Agreement even if that Settlement Class Member does not submit a Valid Claim. You must mail your opt-out request to the Settlement Administrator postmarked no later than April 15, 2026, to:

ALN Medical Management LLC Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391

You can tell the Court that you do not agree with the Settlement and/or Application for Attorneys’ Fees, Costs and Service Awards, or some part of it, by objecting to the Settlement. For an objection to be a valid objection under the Settlement, it must be sent to the Clerk of Court, and sent by U.S. Mail to Class Counsel, Defendant ALN’s Counsel, and the Settlement Administrator at the addresses listed below, postmarked by no later than April 15, 2026.

For an objection to be considered by the Court, your objection must be written and must include all of the following:

1. the objector’s full name, mailing address, telephone number, and email address (if any);
2. the case name and number: In Re: ALN Medical Management LLC Data Incident Litigation, Case No. 4:25-cv-03067-SMB-MDN (D. Neb.);
3. documentation sufficient to establish membership in the Settlement Class, such as a copy of the Postcard Notice or Email Notice the objector received;
4. all grounds for the objection, accompanied by any legal support for the objection known to the objector or objector’s counsel;
5. the number of times the objector has objected to a class action settlement within the five years preceding the date that the objector files the objection, the caption of each case in which the objector has made such objection, and a copy of any orders related to or ruling upon the objector’s prior objections that were issued by the trial and appellate courts in each listed case;
6. the identity of all counsel (if any) who represent the objector, and whether they will appear at the Final Approval Hearing, 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, Costs, and Service Awards;
7. the number of times in which the objector’s counsel and/or counsel’s law firm have objected to a class action settlement within the five years preceding the date of the filed objection, the caption of each case in which counsel or the firm has made such objection and a copy of any orders related to or ruling upon counsel’s or the counsel’s law firm’s prior objections that were issued by the trial and appellate courts in each listed case in which the objector’s counsel and/or counsel’s law firm have objected to a class action settlement within the preceding five years;
8. a list of all persons who will be called to testify at the Final Approval Hearing in support of the objection (if any);
9. a statement confirming whether the objector or their counsel (if any) intends to personally appear and/or testify at the Final Approval Hearing; and
10. the objector’s signature (an attorney’s signature is not sufficient). 

Class Counsel and/or Defendant ALN’s Counsel may conduct limited discovery on any objector or objector’s counsel, including taking depositions and propounding written discovery.

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 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 Benefit from the Settlement. If you exclude yourself, you have no basis to object because you are no longer a Settlement Class Member, and the case no longer affects you. 

Yes. The Court appointed Jeff Ostrow of Kopelowitz Ostrow P.A., Andrew Shamis of Shamis & Gentile, P.A., and John Nelson of Milberg PLLC, as Class Counsel to represent the Settlement Class in Settlement negotiations. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel will file an Application for Attorneys’ Fees, Costs, and Service Awards for an award of attorneys’ fees up to one-third of the Settlement Fund ($1,333,333.33), plus reimbursement of costs. 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 basis.

Class Counsel shall apply to the Court for Service Awards for the eight (8) Class Representatives of up to $2,500.00 each, from the Settlement Fund.

Any attorneys’ fees, costs and Service Award payments must be approved by the Court. The Court may award less than the amounts requested.

The Court will hold a Final Approval Hearing at 12:00 p.m. CT on May 15, 2026 at the United States District Court for the District of Nebraska, Courtroom No. 1, at the Robert V. Denney Federal Building and U.S. Courthouse, 100 Centennial Mall North, Lincoln, NE 68508-3803 as ordered by the Court. The hearing may also be held remotely. At this hearing, the Court will consider whether the Settlement is fair, adequate, and reasonable. If there are timely and valid objections, the Court will consider them and will listen to people who have asked to speak at the hearing if such a request has been properly made. The Court will also rule on the Application for Attorneys’ Fees, Costs, and Service Awards. 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, so Class Counsel recommends checking the Settlement Website here, or calling (833) 754-8507.

No. Class Counsel will present the Settlement Class to 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 15, the Court will consider it.

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must file an objection according to the instructions in Question 15, including all the information required. Your objection must be mailed to the Clerk of the Court, Class Counsel, Defendant ALN’s Counsel, and the Settlement Administrator, at the mailing addresses listed above, postmarked by no later than April 15, 2026.

If you do nothing, you will not receive any Benefits 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 ALNor the other Released Parties based on any Claim that could have been or that was brought relating to the Data Incident.

This Notice summarizes the Settlement. More details are in the Settlement Agreement itself. A copy of the Settlement Agreement is available at here. You may also call the Settlement Administrator with questions or to receive a Claim Form at (833) 754-8507.

It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below, calling toll-free (833) 754-8507 or at the “Contact Us” page of the Settlement Website:

ALN Medical Management LLC Data Incident Litigation
c/o Kroll Settlement Administration LLC
P.O; Box 225391
New York, NY 10150-5391