Frequently Asked Questions

About the Notice

1. Why was the Notice issued?

The Notice is to tell Class Members about the Settlement of a class action lawsuit, Merle v. USC Arcadia Hospital brought on behalf of people who completed forms on the USC Arcadia Hospital website to sign up for email or event updates. Individuals received the Notice because they may be a member of the group of people affected, called the “Class.” The Notice gives them a summary of the terms of the proposed Settlement Agreement, explains what rights Class Members have, and helps Class Members make informed decisions about what action to take.

2. What to do next?

Read the Notice to understand the Settlement and to determine if you are a class member. Then, decide if you want to:

Read on to understand the specifics of the Settlement and what each choice would mean.

Learning about the lawsuit

3. What are the most important dates?

The deadline to submit a claim form, object in writing, or opt out: December 7, 2026

Final Fairness Hearing: Monday, December 14, 2026

4. What is this lawsuit about?

A class action lawsuit was filed against USC Arcadia Hospital on behalf of people who used the Hospital’s website. The lawsuit Claims that USC Arcadia Hospital shared website users’ private information with Meta and other third parties by installing the Meta Pixel and other tracking technologies on its website and, as a result, the website users’ privacy has been violated.

USC Arcadia Hospital denies that it did anything wrong including violating HIPAA or other privacy statutes.

5. Why is there a settlement in this lawsuit?

The parties agreed to settle, which means they have reached an Agreement to resolve the lawsuit. Both sides want to avoid the risk and expense of further litigation.

The Settlement is on behalf of the website user who brought the case and all members of the Settlement Class, which includes people who completed forms on the USC Arcadia Hospital website to sign up for email or event updates from February 1, 2022, to January 31, 2023. The Court has not decided this case in favor of either side.

6. What happens next in this lawsuit?

The Court will hold a Final Fairness Hearing to decide whether to approve the Settlement. The hearing will be held at:

Where: Department 001 of the Spring Street Courthouse, Los Angeles County Superior Court.

When: 10:30 A.M. on Monday, December 14, 2026.

The Court has directed the parties to send you the Notice about the proposed Settlement. Because the Settlement of a class action decides the rights of all members of the proposed class, the Court must review and approve the Settlement before it can take effect. Settlement benefits will be provided only if the Court grants Final Approval and the Settlement becomes effective. If the Court approves the Settlement, the judgment, whether favorable or not, will bind all Class Members who do not opt out.

You are not required to attend the Final Fairness Hearing, but you may attend at your own expense. You may also ask the Court for permission to speak and express your opinion about the Settlement. If the Court does not approve the Settlement or the parties decide to end it, it will be void and the lawsuit will continue. The date of the hearing may change without further notice to members of the class. To learn more and confirm the hearing date, please read the Notice.

Learning about the Settlement

7. What does the Settlement provide?

Benefits

The Settlement provides two benefits that are available to all Class Members. You may choose to receive one or both of these benefits.

• CyEx Privacy Shield Pro. CyEx Privacy Shield Pro is a service that keeps your personal information safe by checking for it on the dark web. If it finds your private details there, it will alert you immediately. If fraud does occur, a dedicated case manager will help you fix the problem. All Settlement Class Members will receive an activation code for one year of this service.

• Cash Payment. All Settlement Class Members may claim a pro rata share of the Settlement Fund. USC Arcadia Hospital has agreed to pay $200,000.00 into a Settlement Fund. This money will be distributed to Settlement Class Members in equal shares and will also be used to pay for any lawyers’ fees and costs approved by the Court, and the cost of administering this Settlement, which includes providing CyEx Privacy Shield activation codes for all Settlement Class Members.

If there is money left over after the Claims process is completed, it will be donated to The Los Angeles Trust for Children’s Health.

Release

Settlement Class Members who do not submit a timely and valid request for exclusion will “Release” their Claims as part of the Settlement, which means they cannot sue USC Arcadia Hospital for the same issues in this lawsuit.

By participating in the Settlement, members of the Settlement Class will Release any and all claims or causes of action arising out of the facts giving rise to the Action that were alleged or reasonably could have been alleged based on the facts in the Complaint, including, but not limited to, all Claims and causes of action under California Civil Code § 56, Cal. Pen. Code §§ 631, 637, and all similar statutes in effect in any states in the United States, including, but not limited to, any and all Claims for damages, injunctive relief, disgorgement, declaratory relief, equitable relief, attorneys’ fees and expenses, pre-judgment interest, credit monitoring services, the creation of a fund for future damages, statutory damages, punitive damages, special damages, exemplary damages, restitution, the appointment of a receiver, Claims under California law, and any other state or federal law for statutory damages arising from the Action described in Section 2.2 of this Agreement or the disclosure of personal, confidential medical, or genetic information. The definition of “Released Claims” shall be construed as broadly as possible under California law to effect complete finality over this Action. Released Claims shall not include the right of any Settlement Class Member or any of the Released Parties to enforce the terms of the settlement contained in this Settlement Agreement and shall not include the Claims of Settlement Class Members who have timely opted out of the Settlement Class. For avoidance of doubt, “Released Claims” do not include medical malpractice, or other bodily injury Claims, or Claims relating to the enforcement of the Settlement.

8. How do I know if I am part of this Settlement?

If you completed a form on the USC Arcadia Hospital website to sign up for email notifications or event updates from February 1, 2022, to January 31, 2023, you may be a Settlement Class Member. Settlement Class Members who do not exclude themselves are eligible for one year of CyEx Privacy Shield Pro, and those who submit a timely and valid Claim Form are also eligible for a cash payment.

Under the Settlement Agreement, the Settlement Class defined as “any person who completed forms on Defendant’s website to sign up for email/events updates from Defendant from February 1, 2022, to January 31, 2023 (“Class Period”).” Excluded from the Settlement Class are: (1) the Judge(s) presiding over the Action and members of their families; (2) Defendant, its subsidiaries, parent companies, successors, predecessors, and any entity in which Defendant or its parents have a controlling interest, and its current or former officers and directors; (3) natural persons who properly execute and submit a Request for Exclusion prior to the Response Deadline; and (4) the successors or assigns of any such excluded natural person.

9. How much will my cash payment be?

Settlement Class Members who submit a timely and valid Claim Form, will receive an equal pro rata share of the Net Settlement Fund—the amount remaining after payment of (1) Fee and Expense Award approved by the Court (see Question 13 “Do I have to pay the lawyers in this lawsuit?”), (2) Notice and Administration Expenses, including the cost of CyEx Privacy Shield Pro, and (3) any Service Award approved by the Court.

10. How do I weigh my options?

Class Members have four options. They can stay in the Settlement and submit a claim, opt out of the Settlement, object to the Settlement, or they can do nothing. This chart shows the effects of each option:

11. What is the best path for me?

*You may object to the Settlement and submit a timely and valid Claim Form to receive a cash payment.

Submitting a Claim Form

12. How do I get a cash payment if I am a Settlement Class Member?

To receive a cash payment, you must submit a completed Claim Form by December 7, 2026. You may submit a Claim online here or download a claim form here and mail to the Settlement Administrator at

Merle v. USC Arcadia Hospital
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

13. Do I have a lawyer in this lawsuit?

In a class action, the Court appoints Class Representatives and lawyers to work on the case and represent the interests of all the Class Members. For this Settlement, the Court has appointed the following Settlement Class Counsel: Nicholas A. Coulson and Ellyn Gendler of Coulson P.C., and Mike M. Arias, Arnold C. Wang, and M. Anthony Jenkins of Arias Sanguinetti Wang & Team LLP. These are the lawyers who negotiated this Settlement on your behalf.

If a Class Members want to be represented by their own lawyer, they may hire one at their own expense.

14. Do I have to pay the lawyers in this lawsuit?

Settlement Class Counsel’s fees and costs will be paid from the Settlement Fund. Class Members will not have to pay them directly.

To date, Settlement Class Counsel have not been paid any money for their work or the expenses that they have incurred for the case. To pay for some of their time and risk in bringing this case without any guarantee of payment unless they were successful, Settlement Class Counsel will request, as part of the final approval of this Settlement, that the Court approve a payment of $61,335.92 total in attorneys’ fees plus the reimbursement of out-of-pocket expenses of $15,992.25.

The Fee and Expense Award will only be awarded if approved by the Court as a fair and reasonable amount. You have the right to object to the requested Fee and Expense Award even if you think the other Settlement terms are fair.

Class Counsel will also ask the Court to approve a $1,500.00 Service Award to the Named Plaintiff for the time and effort he contributed to the case. If approved, the Service Award will be paid from the Settlement Fund.

Opting Out

15. What if I don’t want to be part of this Settlement?

Class Members can opt out. If they do, they will receive neither CyEx Privacy Shield Pro nor a cash payment and may not object to the Settlement. However, individuals will not be bound by the Settlement or its Release and may be able to bring their own lawsuit. The Court will exclude you from the class if you submit a timely and valid Request for Exclusion by December 7, 2026.

16. How do I submit a Request for Exclusion?

To opt out of the Settlement, Class Members must mail a letter to the Settlement Administrator that:

1. is postmarked by December 7, 2026;

2. includes the case name and number (Merle v. USC Arcadia Hospital, No. 23STCV01900 (Los Angeles County Superior Court))

3. includes Class Member’s full name, address, and telephone number;

4. includes a clear statement requesting exclusion from the proposed Settlement Class in Merle v. USC Arcadia Hospital, No. 23STCV01900 (Los Angeles County Superior Court).

5. includes Class Member’s signature.

Mail the letter to:

Merle v. USC Arcadia Hospital
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

Objecting

17. What if I disagree with the Settlement?

If Class Members disagree with any part of the Settlement (including the lawyers' fees) but don’t want to opt out, they may object. Class Members must give reasons why they think the Court should not approve it and say whether their objection applies to just them, a part of the class, or the entire class. The Court will consider the Class Members views. The Court can only approve or deny the Settlement — it cannot change the terms of the Settlement. Class Members may, but don’t need to, hire their own lawyer to help them.

To object, Class Members must either present their objection in person at the Final Fairness Hearing or send a letter to the Settlement Administrator that:

1. is postmarked by December 7, 2026;

2. includes the case name and number (Merle v. USC Arcadia Hospital, No. 23STCV01900 (Los Angeles County Superior Court))

3. includes Class Member’s full name, address, and telephone number;

4. states whether their objection applies to only themself, a subset of the Settlement Class, or the entire Settlement Class

5. states the reasons for their objection;

6. includes all documents they want the Court to consider;

7. states whether the Class Member or their lawyer intends to appear at the Final Fairness Hearing and includes the lawyer's name, if applicable;

8. includes Class Member’s signature.

Mail the letter to:

Merle v. USC Arcadia Hospital
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

Do Nothing

18. What are the consequences of doing nothing?

If a Class Member does nothing, they will remain eligible for one year of CyEx Privacy Shield Pro, although activation or enrollment may be required to use the service. You will not receive a cash payment because you did not submit a Claim Form. Class Members will still be bound by the settlement and its “Release” provisions, which means Class Members will not be able to start, continue, or participate in another lawsuit against USC Arcadia Hospital based on the Released Claims. A full description of Released Claims and Released Parties is available in the Settlement Agreement.

Key Resources

19. How do I get more information?

This website and the Notice are a summary of the proposed Settlement. The complete Settlement with all its terms can be found here. To get answers to your questions, you may contact the Settlement Administrator or the Class Members’ lawyers (information below).