1. Why is there a Notice?
2. What is the Action about?
3. Why is this a class action?
4. Why is there a Settlement?
5. How do I know if I am part of the Settlement?
6. What if I am not sure whether I am included in the Settlement?
7. What does the Settlement provide?
8. How do I get a Settlement benefit?
9. When will I get my Settlement benefit?
10. What am I giving up as part of the Settlement?
11. If I exclude myself, can I get a benefit from this Settlement?
12. If I exclude myself, can I get a benefit from this Settlement?
13. How do I exclude myself from the Settlement?
14. How do I object to the Settlement?
15. What is the difference between objecting and asking to be excluded?
16. Do I have a lawyer in this case?
17. How will Class Counsel be paid?
18. When and where will the Court decide whether to approve the Settlement?
19. Do I have to attend the Final Approval hearing?
20. May I speak at the hearing?
21. What happens if I do nothing?
22. How do I get more information?
23. What if my contact information changes or I no longer live at my address?
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 Melvin Oden-Orr of the Circuit Court of Multnomah County is overseeing this case captioned as Katherine Layman v. Legacy Health, Case No. 25CV40104. The person who brought the lawsuit is called the “Class Representative” or “Plaintiff.” The company being sued, Legacy Health, is called the “Defendant.”
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The Action alleges that Legacy Health disclosed certain types of its patients’ personally identifiable information to Meta and Google without permission. Plaintiff asserted claims against Legacy Health for: (1) breach of confidence; (2) breach of implied contract; (3) unjust enrichment; and (4) negligence.
Legacy Health denies any wrongdoing whatsoever, and has agreed to the Settlement to avoid the expense, burden, and uncertainties associated with continuing the litigation. No court or other judicial body has made any judgment or other determination that Legacy Health has done anything wrong.
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In a class action, one or more people called a Class Representative 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.
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The Court did not decide in favor of the Class Representative or Legacy Health. Instead, both sides have agreed to this Settlement to avoid the costs and risks of a trial and related appeals, while providing benefits to 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.
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You are affected by the Settlement and potentially a Settlement Class Member if you are a patient of Legacy Health residing in the United States who (1) was invited to and did register for a Legacy Health patient portal account from February 18, 2019, through December 31, 2020 (“Category 1”), and (2) do not fall within Category 1, but otherwise logged into the Patient Portal from January 1, 2021, through February 9, 2024.
Excluded from the Settlement Class are: (1) any Judge presiding over this Action, any members of the Judges’ respective staffs, and immediate members of the Judge’s family; (2) officers and directors of Legacy Health, its agents, affiliates, subsidiaries, parent companies, successors, predecessors, and any entity in which Legacy Health or its parents have a controlling interest; (3) persons who timely and validly request exclusion from, or opt-out of, the Settlement Class; (4) the legal representatives, successors or assigns of any such excluded persons; and (5) Class Counsel.
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If you are not sure whether you are included in the Settlement, you may call (833) 647-9039 with questions. You may also write with questions to:
Layman v. Legacy Health
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
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Legacy Health will pay or cause to be paid the following benefits to every Settlement Class Member: (i) automatic access to one (1) year of CyEx’s Medical Shield Complete product, free of charge and without the need to submit any Claim; (ii) approved Claims for a one-time Claim for a cash payment of $15.00 submitted by Settlement Class Members; (iii) the Notice and Settlement Administrative Expenses actually incurred by the Settlement Administrator; (iv) the Fee Award for attorneys’ fees, costs, and expenses not to exceed $2,200,000.00; and (v) any Incentive Award to the Plaintiff of $2,500.00, as may be ordered by the Court.
Cash Payment: Each Settlement Class Member may submit a Claim for a cash payment of $15.00.
Medical Shield Complete: All Settlement Class Members will be entitled to automatically receive a code for redeeming one (1) year of Medical Shield Complete, a comprehensive privacy protection solution offered by CyEx, which includes the following features: One Bureau of Credit Monitoring, Health Insurance Plan ID Monitoring, Medicare Beneficiary Identifier ID Monitoring, Medical Record Number Monitoring, Dark Web Monitoring, Health Savings Account Monitoring, National Provider Identifier Monitoring, $1,000,000 Identity Theft Insurance, High-Risk Transaction Monitoring, Security Freeze Assistance, and Victim Assistance.
An enrollment code and link to enroll in Medical Shield Complete was emailed to all Class Members. If you did not receive that email, or no longer have it, please contact the Settlement Administrator.
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To receive a Settlement cash benefit, you must complete and submit a Claim Form online or by mail to:
Layman v. Legacy Health
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Read the Claim Form instructions carefully, fill out the Claim Form and submit online by March 16, 2026, or by mail postmarked by March 16, 2026.
To Receive An Electronic Or ACH Payment For Your Approved Claim, You Must File A Claim Form Online.
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The Court will hold a Final Approval Hearing on April 16, 2026, at 10:00 a.m. PT to decide whether to grant final approval of this Settlement. You do not need to attend the Final Approval Hearing. If the Court grants final approval of this 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. Settlement benefits will begin after the Settlement has obtained Court approval and the time for all appeals has expired.
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Legacy Health and its affiliates will receive a release from all claims that could have been or that were brought against Legacy Health relating to the Action. Thus, if the Settlement becomes Final and you do not exclude yourself from the Settlement, you will be a Settlement Class Member and you will give up your right to sue Legacy Health, as well as any and all of its respective present or past heirs, executors, estates, administrators, predecessors, successors, assigns, parent companies, subsidiaries, licensors licensees, associates, affiliates, employers, employees, agents, consultants, independent contractors, insurers, reinsurers, directors, managing directors, officers, partners, principals, members, attorneys, accountants, financial and other advisors, underwriters, shareholders, lenders, auditors, investment advisors, legal representatives, successors in interest, assigns and companies, firms, trusts, and corporations., without limitation, any person related to any such entity who is, was, or could have been named as a defendant in the Action. This release is described in the Settlement Agreement, under Section 3, which is available here. If you have any questions, you can talk to the law firms listed in Question 16 for free or you can talk to your own lawyer.
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If you do not want to be part of the Settlement, then you must take steps to exclude yourself from the Settlement Class. This is called a “Request for Exclusion,” and is sometimes referred to as “opting out” of the Settlement Class.
No. If you exclude yourself, you will not be entitled to receive any benefits from the Settlement.
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No. Unless you exclude yourself, you give up any right to sue Legacy Health and any other Released Parties for any claim that could have been or was brought relating to the Action. 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.
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To exclude yourself, send a Request for Exclusion or written notice of intent to opt-out. To exercise the right to be excluded, a person in the Settlement Class must timely send a written request for exclusion to the Settlement Administrator as specified in the Notice, which must include: (1) his/her name, current address, telephone number, and unique ID; (2) a personal signature; (3) the name and number of the case; and (4) a statement that he or she wishes to be excluded from the Settlement Class for purposes of this Settlement.
You must mail your Request for Exclusion to the Settlement Administrator postmarked by March 16, 2026, to:
Layman v. Legacy Health
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
To exclude yourself, send a request for exclusion. Any member of the Settlement Class who validly elects to be excluded from the Settlement shall not: (i) be bound by any orders or the Final Judgment; (ii) be entitled to relief under the Settlement Agreement; (iii) gain any rights by virtue of the Settlement Agreement; or (iv) be entitled to object to any aspect of the Settlement Agreement.
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You can tell the Court that you do not agree with the Settlement or some part of it by objecting to the Settlement. Any Settlement Class Member who wishes to object to the Settlement must (a) file copies of such papers he or she proposes to be submitted at the Final Approval Hearing with the Clerk of the Court, or alternatively, if the objection is from a Settlement Class Member represented by counsel, files any objection through the Court’s electronic filing system, and (b) sends copies of such papers by mail, hand, or overnight delivery service to Class Counsel and Defendant’s Counsel at the addresses below, with a postmark date no later than March 16, 2026:
Clerk of the Court | Class Counsel | Defendant’s Counsel |
1200 SW 1st Avenue | Gary M. Klinger | Paul G. Karlsgodt |
The name of the Action;
the objector’s full name, telephone number, email address, and mailing address;
an explanation of the basis upon which the objector claims to be a Settlement Class Member;
all grounds for the objection, including all citations to legal authority and evidence supporting the objection;
the name and contact information of any and all attorneys representing, advising, or in any was assisting the objector in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection (the “Objecting Attorneys”);
a statement indicating whether the objector intends to appear at the Final Approval Hearing (either personally or through counsel who files an appearance with the Court in accordance with the Local Rules); and
a list, by case name, court, and docket number, of all other cases in which the objector and/or the Objecting Attorneys have filed an objection to any proposed class action settlement within the last three (3) years
If a Settlement Class Member or any of the Objecting Attorneys has objected to any class action settlement where the objector or the Objecting Attorneys asked for or received any payment in exchange for dismissal of the objection, or any related appeal, without any modification to the settlement, then the objection must include a statement identifying each such case by full case caption and amount of payment received.
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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.
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Yes. The Court appointed Gary M. Klinger of Milberg Coleman Bryson Phillips Grossman PLLC, Terry Coates and Dylan J. Gould of Markovits, Stock & DeMarco, LLC, Bryan L. Bleichner and Philip J. Krzeski of Chestnut Cambronne PA, Joseph M. Lyon of the Lyon Firm, and Timothy S. Dejong of Stoll, Stoll, Berne, Lokting & Schlater, P.C., 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.
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Class Counsel may receive, subject to Court approval, attorneys’ fees, costs, and expenses not to exceed $2,200,000.00 in connection with commencing, prosecuting, and settling the Action on behalf of Settlement Class Members. If the Court approves the Fee Award, it shall be paid by Legacy Health.
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 an Incentive Award of $2,500.00 to the Class Representative in recognition of their contributions to this Action. If the Court approves the Incentive Award, it shall be paid by Legacy Health.
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The Court may hold a Final Approval Hearing at 10:00 a.m. PT on April 16, 2026, at the Multnomah County Courthouse, 1200 SW 1st Avenue Portland, OR 97204, Room ___ as ordered by the Court. 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 reasonable Fee Award, as well as an Incentive Award for the Class Representative. 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.
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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.
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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 14, including all the information required.
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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 Legacy Health or the other Released Parties based on any claim that could have been or that was brought relating to the Action.
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This website and the Notice summarize 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 or to receive a Claim Form at (833) 647-9039.
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It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below or by calling toll-free (833) 647-9039.
Layman v. Legacy Health
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
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