Frequently Asked Questions

This is a court-authorized Settlement Website of a proposed Settlement (the “Settlement”) in a Class Action lawsuit, Doe v. Wood County Hospital, Case No. 23CV160, pending in the Court of Common Pleas, Sandusky County, Ohio, General Division (the “Court”).  The Settlement would resolve the Lawsuit brought on behalf of persons who allege that the IP addresses  of Plaintiffs and members of the Settlement Class were allegedly disclosed to Facebook and Google as a result of Wood County Hospital’s (“Wood County Hospital” or “Defendant”) use of certain marketing analytics technologies on its website, www.woodcountyhospital.org, between February 24, 2019 to March 14, 2024. The Court has granted Preliminary Approval of the Settlement Agreement and has conditionally certified the Settlement Class for purposes of Settlement only. This Settlement Website explains the nature of the class action lawsuit, the terms of the Settlement Agreement, and the legal rights and obligations of members of the Settlement Class. Please read the instructions and explanations below carefully so that you can better understand your legal rights. The Settlement Administrator in this case is Kroll Settlement Administration LLC. 

You may have received a notice because you were identified as a person who had a patient portal account with Wood County Hospital and potentially had their IP address disclosed to Facebook and Google because of Wood County Hospital’s use of  certain marketing analytics technologies on its website, www.woodcountyhospital.org, between February 24, 2019 and March 14, 2024.

The Litigation arises out of Wood County Hospital’s implementation and use of certain marketing analytics technologies on Wood County Hospital’s website, defined below as the “Website Usage Disclosure,” during which Plaintiffs allege their web usage data was shared with Facebook allegedly resulting in the invasion of Plaintiffs’ and Settlement Class Members’ privacy.
“Website Usage Disclosure” means the alleged disclosure of the IP addresses of Plaintiffs and members of the Settlement Class to Facebook and Google as a result of Wood County Hospital’s use of certain marketing analytics technologies on its Website between February 24, 2019 to March 14, 2024.

A class action is a lawsuit in which an individual called a “Class Representative” brings a single lawsuit on behalf of other people who have similar claims. All of these people together are a “Settlement Class” or “Settlement Class Members.” When a class action is settled, the settlement, which must be approved by the Court, resolves the issues for all Settlement Class Members, except for those who exclude themselves from the settlement.

To resolve this matter without the expense, delay, and uncertainties of protracted litigation, the Parties reached a Settlement that resolves all claims brought on behalf of the Settlement Classes related to the data security incident. If approved by the Court, the Settlement Agreement requires Wood County Hospital to provide cash compensation to certain Settlement Class Members who submit valid and timely Claim Forms. The Settlement is not an admission of wrongdoing by Wood County Hospital and does not imply that there has been, or would be, any finding that Wood County Hospital violated the law.

The Court already has preliminarily approved the Settlement Agreement. Nevertheless, because the settlement of a class action determines the rights of all members of the Settlement Class, the Court overseeing this lawsuit must give final approval to the Settlement Agreement before it can be effective. The Court has conditionally certified the Settlement Class for settlement purposes only, so that members of the Settlement Class may be given notice and the opportunity to exclude themselves from the Settlement Class, and to voice their support or opposition to final approval of the Settlement Agreement. If the Court does not grant final approval to the Settlement Agreement, or if it is terminated by the Parties, then the Settlement Agreement will be void, and the lawsuit will proceed as if there had been no settlement and no certification of the Settlement Class.

You are a member of the Settlement Class if you logged into a MyChart patient portal account maintained by Wood County Hospital at least once between February 24, 2019, and March 14, 2024 (“Settlement Class”).

Settlement Class Members who file a valid Claim Form may receive monetary compensation of an equal share of the Net Settlement Fund.  The Net Settlement Fund is the funds that remain for the $1,475,000 Settlement Fund following the payment of Notice and Claims Administration Costs, Class Representative Service Awards, and Attorneys’ Fees, Costs and Expenses Award.

***To receive Settlement benefits, you must submit a Claim Form.
 

If you timely submit a valid Claim Form for monetary recovery, you will receive payment in the amount approved by the Settlement Administrator after processing your Claim Form, and the Settlement is Final and has become effective.

For claims for Cash Compensation:  To submit a claim for Cash Compensation, you must timely submit the Claim Form on this Settlement Website or by mail to Settlement Administrator 83030 c/o Kroll Settlement Administration, PO BOX 5324, New York, NY 10150-5324.

You must submit any claims by June 1, 2024. There can be only one valid and timely claim per Settlement Class Member. 

By staying in the Settlement Class, all the Court’s orders will apply to you and will bind you, and you give Defendant a “release.” A release means you cannot sue or be part of any other lawsuit or other legal action against Defendant about or arising from the claims or issues in this lawsuit with respect to the alleged sharing of your information stored in Defendant’s system prior to March 14, 2024.

The precise terms of the release are in the Settlement Agreement, which is available on this Settlement Website. Unless you formally exclude yourself from this Settlement, you will release your claims.

If you have any questions, you can talk for free to the attorneys identified below who have been appointed by the Court to represent the Settlement Class, or you are welcome to talk to any other lawyer of your choosing at your own expense.

The precise terms of the release are in the Settlement Agreement, which is available on this Settlement Website. Unless you formally exclude yourself from this Settlement, you will release your claims. If you have any questions, you can talk for free to the attorneys identified below who have been appointed by the Court to represent the Settlement Class or you are welcome to talk to any other lawyer of your choosing at your own expense.
 

The Class Representatives will seek a payment of $5,000 each to Jane Doe and Janet Doe for their services to the Settlement Class. This payment is subject to the Court’s Approval and will be paid form the Settlement Fund.

If you do not want to remain in the Settlement, but you want to keep your legal claims against Defendant, then you must take steps to exclude yourself from this Settlement.

To exclude yourself from the Settlement, you must send a letter by mail stating that you want to be excluded from Doe et al. v. The Wood County Hospital, Case No. 23CV160 in the Court of Common Pleas (Ohio) to the Settlement Administrator. Such notice shall state: (1) your full name and address; (2) the case name and docket number; (3) a written statement that you wish to be excluded from the Settlement; and (4) your signature. You must mail your exclusion request so that it is postmarked no later than May 15, 2024, to:

Settlement Administrator - 83030
c/o Kroll Settlement Administration LLC
PO BOX 5324
New York, NY 10150-5324
 

No, if you submit an opt-out notice, you will not receive anything resulting from the Settlement, but you may sue Defendant over the claims raised in this case, either on your own or as a part of a different lawsuit. If you exclude yourself, the time you have in which to file your own lawsuit (called the “statute of limitations”) will begin to run again. You will have the same amount of time to file the suit that you had when this case was filed. If you file an objection, you may still receive benefits if you timely file a claim.

The Court has appointed three attorneys to represent the Settlement Class as Class Counsel:

Matthew R. Wilson 
Meyer Wilson Co., LPA
305 W. Nationwide Blvd, Columbus, Ohio 43215
Phone: 866.827.6537
[email protected]

Samuel Strauss
Turke & Strauss
613 Williamson Street, Suite #201
Madison, WI 53703
Phone: 608.237.1775
[email protected]

Foster C. Johnson
Ahamd, Zavitsanos, & Mensing, PLLC
1221 McKinney, Suite 2500
Houston, Texas 77010
[email protected]

These attorneys will be paid using funds from the Settlement Fund. If you want to be represented by your own lawyer, you may hire one at your own expense.
 

Class Counsel will request to be paid reasonable attorneys’ fees up to 35% of the Settlement Fund plus their expenses incurred in the Litigation, subject to Court approval. The motion for attorneys’ fees and expenses will be posted on this Settlement Website after it is filed.

You can tell the Court that you do not agree with the Settlement or some part of it.  If you are a Settlement Class Member, you can object to the Settlement and the Court will consider your views.  In order to object to the Settlement, you must provide a written Objection (such as a letter or legal brief) stating that you object and the reasons why you think the Court should not approve the Settlement.  Your Objection should include: (1) the objector’s full name, telephone number, email address and address; (2) proof of being a member of the Settlement Class; (3) the case name and docket number, Doe et al. v. The Wood County Hospital, Case No. 23CV160; (4) all grounds for the objection, with factual and legal support for the stated Objection, including any supporting materials; (5) the identification of any other objections he/she has filed, or has had filed on his/her behalf, in any other class action cases in the last four years; (6) whether the objector intends to appear at the Final Approval Hearing; and (7) the objector’s signature.

If represented by counsel, the objecting Settlement Class Member must also provide the name and telephone number of his/her counsel. If the objecting Settlement Class Member intends to appear at the Final Approval Hearing, either with or without counsel, he/she must state as such in the written Objection, and must also identify any witnesses he/she may call to testify at the Final Approval Hearing and all exhibits he/she intends to introduce into evidence at the Final Approval Hearing, which must also be attached to, or included with, the written objection.

To be timely, written notice of an Objection in the appropriate form must be filed with the Court no later than the Objection Deadline, May 15, 2024, and served on Class Counsel and Defendant’s Counsel as noted below:
 

Judge Jon M. Ickes
Court of Common Pleas
Sandusky County, Ohio 
General Division
100 N Park Ave #310
Fremont, OH 43420

Matthew R. Wilson 
Meyer Wilson Co., LPA
305 W. Nationwide Blvd, Columbus, Ohio 43215
Phone: 866.827.6537
[email protected]

Samuel Strauss
Turke & Strauss
613 Williamson Street, Suite #201
Madison, WI 53703
Phone: 608.237.1775
[email protected]

Foster C. Johnson
Ahamd, Zavitsanos, & Mensing, PLLC
1221 McKinney, Suite 2500
Houston, Texas 77010
[email protected]

The Court will hold a hearing to decide whether to grant final approval of the Settlement. You may attend if you wish, but you are not required to do so.

The Court has already given Preliminary Approval to the Settlement Agreement. A final hearing on the Settlement, called a Final Approval Hearing, will be held to determine the fairness of the Settlement Agreement.

The Court will hold a hearing on July 11, 2024, at 10:00 AM Eastern Time. The purpose of the hearing will be for the Court to determine whether the proposed Settlement is fair, reasonable, and adequate and in the best interests of the Settlement Class and to determine the appropriate amount of compensation for Class Counsel and rule on the request for a Service Award for the Plaintiffs. At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the proposed Settlement. After the hearing, the Court will decide whether to approve the Settlement.

YOU ARE NOT REQUIRED TO ATTEND THE FINAL APPROVAL HEARING TO RECIEVE BENEFITS FROM THIS SETTLEMENT. Please be aware that the hearing may be postponed to a later date without notice.
 

This Settlement Website only provides a summary of the proposed Settlement. Complete details about the Settlement can be found in the Settlement Agreement.

If you have any questions, you can contact the Settlement Administrator or Class Counsel at the numbers or email addresses set forth above. In addition to the documents available on this Settlement Website, all pleadings and documents filed in this Litigation may be reviewed or copied at the Clerk of Court’s office.