In re Community Dental Care
Case No. 62-CV-25-2490
NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE
DECEMBER 2024 COMMUNITY DENTAL CARE DATA BREACH,
A PROPOSED CLASS ACTION SETTLEMENT MAY AFFECT YOUR
RIGHTS, AND MAY ENTITLE YOU TO BENEFITS AND A CASH PAYMENT.
A court has authorized this notice. This is not a solicitation from a lawyer.
You are not being sued.
Please read this Notice carefully and completely.
• A Settlement has been reached with Community Dental Care (“CD” or “Defendant”), a Minnesota-
based nonprofit dental services provider, in a class action lawsuit. This case is about the targeted
cyberattack on CD's computer systems that occurred in December 2024 (the “Data Breach”).
Certain files that contained private information were allegedly accessed by an unauthorized actor.
These files may have contained personal information such as names; health insurance information;
dates of birth; medical information; and Social Security numbers.
• The lawsuit is called In re Community Dental Care, Case No. 62-CV-25-2490. It is pending in the
District Court for Ramsey County, Minnesota (the “Litigation”).
• CD denies that it did anything wrong, and the Court has not decided who is right.
• The parties have agreed to settle the lawsuit (the “Settlement”) to avoid the costs and risks,
disruptions, and uncertainties of continuing the Litigation.
• If you received a postcard notifying you of this Settlement, CD's records indicate that you are a Class
Member, and may be entitled to one or more benefits under the Settlement. You may have received
a previous notice directly from CD.
• Your rights are affected whether you act or don’t act. Please read this Notice carefully and
completely.
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SUMMARY OF YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT DEADLINE
SUBMIT A CLAIM The only way to receive benefits or payments from this Settlement October 19, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.CDDataBreach.com. If you prefer, you can download the
Claim Form from the Settlement Website and mail it to the
Settlement Administrator. You may also call or email the
Settlement Administrator to receive a paper copy of the Claim
Form.
OPT OUT OF THE You can choose to opt out of the Settlement and receive no benefit September 24, 2026
SETTLEMENT or payment. This option allows you to sue, continue to sue, or be
part of another lawsuit against the Defendant related to the legal
claims resolved by this Settlement. You can hire your own lawyer at
your own expense.
OBJECT TO THE If you do not opt out of the Settlement, you may object to it by September 24, 2026
SETTLEMENT AND/OR writing to the Court about why you don’t like the Settlement. You
may also ask the Court for permission to speak about your
ATTEND A HEARING
objection at the Final Approval Hearing.
DO NOTHING Unless you opt out of the Settlement, you are automatically part of No Deadline
the Settlement. If you do nothing, you will not receive benefits or
payments from this Settlement and you will give up the right to sue,
continue to sue, or be part of another lawsuit against the Defendant
related to the legal claims resolved by this Settlement.
• These rights and options—and the deadlines to exercise them—are explained in this Notice.
• The Court in charge of this case still has to decide whether to approve the Settlement. Benefits will be
provided only after any issues with the Settlement are resolved. Please be patient.
• No opinion concerning the tax consequences of this Settlement to any Settlement Class Member is given
or will be given by Defendant, Defense Counsel, or Proposed Class Counsel, nor is any Party or his/her/its
counsel providing any representation or guarantee respecting the tax consequences of the Settlement
as to any Settlement Class Member. Settlement Class Members should consult their own tax advisors
regarding the tax consequences of the Settlement and any tax reporting obligations with respect thereto.
Each Settlement Class Member is responsible for his/her taxes or tax reporting and other obligations
respecting the Settlement, if any.
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WHAT THIS NOTICE CONTAINS
BASIC INFORMATION .................................................................................................... 3
WHO IS IN THE SETTLEMENT .......................................................................................... 4
THE SETTLEMENT BENEFITS........................................................................................... 4
SUBMITTING A CLAIM FORM FOR SETTLEMENT BENEFITS ................................................ 6
THE LAWYERS REPRESENTING YOU ............................................................................... 6
EXCLUDING YOURSELF FROM THE SETTLEMENT ............................................................ 7
COMMENTING ON OR OBJECTING TO THE SETTLEMENT.................................................. 7
THE COURT’S FINAL APPROVAL HEARING ...................................................................... 8
IF I DO NOTHING ........................................................................................................... 9
GETTING MORE INFORMATION ...................................................................................... 9
Basic Information
1. Why was this Notice issued?
The District Court for Ramsey County, Minnesota, authorized this Notice. You have a right to know about the
proposed Settlement of this class action lawsuit, and about all of your options, before the Court decides
whether to grant final approval of the Settlement. This Notice explains the lawsuit, your legal rights, what
benefits are available, and who can receive them.
The lawsuit is called In re Community Dental Care, Case No. 62-CV-25-2490. It is pending in the District Court
for Ramsey County, Minnesota. The people that filed this lawsuit are called the “Plaintiffs” (or “Class
Representatives”) and the company they sued, Community Dental Care, is called the “Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the December 2024 targeted cyberattack on CD's computer systems, certain
files that contained private information were accessed by an unauthorized actor. These files may have
contained personal information such as names; health insurance information; dates of birth; medical
information; and Social Security numbers.
CD denies the allegations, and denies that it violated any laws or harmed any persons. By agreeing to settle,
CD is not admitting liability on any of the factual allegations or claims in the lawsuit, or that the case can or
should proceed as a class action. More information about the lawsuit and CD’s position can be found on the
Settlement Website in the “Court Documents” section.
3. What is a class action?
In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals
are called the “Plaintiffs” or “Class Representatives.” Together, the people included in the class action are
called a “Class” or “Class Members.” One court resolves the lawsuit for all Class Members, except for those
who opt out from the settlement. In this Settlement, the Class Representatives are Tracy Knight; Aaron Brown
(on behalf of minor child A.B.); Tina Ihrke; Sheila Schutz; Danelle Whittaker; Kathy McKenzie; Keiryn Kuehn
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(on behalf of minor children H.K. and M.D.); and Ka Vang. Everyone included in this Action are the Class
Members.
4. Why is there a Settlement?
The Court did not decide whether the Plaintiffs or the Defendant are right. By preliminarily approving the
Settlement and issuing this notice, the Court is not suggesting which side would win or lose if the case went
to trial. Both sides have agreed to a Settlement to avoid the costs and risks of litigation and a trial. The
Settlement is not an admission of wrongdoing by CD. The Plaintiffs and their attorneys think the Settlement
is best for all Class Members.
Who is in the Settlement?
5. Who is included in the Settlement?
The court has defined the Class this way: “All individuals whose Personal Information was accessed without
authorization in the Data Breach, including all those who received a notice of the Data Breach.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) CD and its officers, directors, and related companies; (2) governmental
entities; (3) the Judge in this case, and the Judge’s family and staff; and (4) anyone who perpetrated the Data
Security Incident.
If you are not sure whether you are a Class Member, you can ask for free help any time by contacting the
Settlement Administrator at:
• Email: [email protected]
• Call toll free, 24/7: (866) 675-2314
• By mail: CD Data Breach Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
You may also view the Settlement Agreement at www.CDDataBreach.com.
The Settlement Benefits
7. What does the Settlement provide?
CD has agreed to pay for a number of Class benefits, which are explained below. All Class Members may
enroll in two years of Medical and Credit Monitoring from CyEx Medical Shield Pro, and may claim one of two
cash payment options.
MEDICAL AND CREDIT MONITORING. All Class Members are eligible to enroll in two years of CyEx Medical
Shield Complete. Enrollment codes have been sent to all Class Members by postcard. If you no longer have
your enrollment code, please contact the Administrator.
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This comprehensive service comes with $1 million of medical identity theft insurance, and includes
monitoring for:
• healthcare insurance ID exposure
• Medical Record Number (MRN) exposure
• unauthorized Health Savings Account (HSA) spending
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
CASH PAYMENT OPTIONS
Cash Payment A – Documented Losses. If you incurred actual, unreimbursed, documentarily
provable out-of-pocket losses arising from and actually caused by the Data Breach, you may seek to
get back up to $5,000.00. The losses must have occurred between December 20, 2024, and October
19, 2026.
This benefit covers monetary, out-of-pocket expenses like:
• losses because of identity theft or fraud
• fees for credit reports, credit monitoring, or freezing and unfreezing your credit
• cost to replace your IDs
• postage to contact banks by mail
This benefit does not cover claims for lost time or other non-monetary losses. You need to send proof
that supports your claimed unreimbursed expenses, like bank statements or receipts, to show when
the loss occurred and how much you spent or lost. You can also send notes or papers you made
yourself to explain or support other proof, but those self-prepared notes or papers alone are not
enough to make a valid claim. Your proof or notes must show that your expenses were because of
the Data Breach.
You cannot claim a payment for expenses that have already been reimbursed by a third party. If you
make a claim for this benefit, you may not seek Cash Payment B - $50.00 Alternative Cash Payment.
-OR-
Cash Payment B – Alternative Cash. Instead a payment for documented losses, you may claim a
one-time $50.00 cash payment. You do not have to provide any proof or explanation to claim this
payment.
If you have questions about these benefits, you can ask for free help any time by contacting the Settlement
Administrator at:
• Email: [email protected]
• Call toll free, 24/7: (866) 675-2314
• By mail: CD Data Breach Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
8. What claims am I releasing if I stay in the Class?
If you stay in the class, you won’t be able to be part of any other lawsuit against CD about the issues that this
Settlement covers. The “Releases” section of the Settlement Agreement (Section XI) describes the legal
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claims that you give up if you remain in the Class, so read it carefully. The Settlement Agreement is available
at www.CDDataBreach.com. 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 class, or you are welcome to talk to any other attorney
of your choosing at your own expense.
Submitting a Claim Form for a Settlement Payment
9. How do I submit a claim for a Settlement benefit?
The fastest way to submit your Claim Form is online at www.CDDataBreach.com. If you prefer, you can
download a printable Claim Form from the website and mail it to the Settlement Administrator at:
CD Data Breach Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free,
(866) 675-2314, by email [email protected], or by U.S. mail at the address above.
10. Are there any important Settlement payment deadlines?
If you are submitting a Claim Form online, you must do so by October 19, 2026. If you are submitting a claim
by U.S. mail, the completed and signed Claim Form, including supporting documentation, must be
postmarked no later than October 19, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on November 23, 2026 (see Question 18). If the Court approves
the Settlement, there may be appeals. We do not know if appeals will be filed, or how long it will take to resolve
them if they are filed.
Settlement payments will be distributed if the Court grants final approval, and after any appeals are resolved.
The Lawyers Representing You
12. Do I have a lawyer in the case?
Yes, the Court has appointed attorneys Raina C. Borrelli of Strauss Borrelli PLLC; Christopher P. Renz of
Chestnut Cambronne PA, to represent you and other Class Members (“Class Counsel”).
13. Should I get my own lawyer?
You do not need to hire your own lawyer because Class Counsel is working on your behalf. You will not be
charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense, without
any right to seek reimbursement of those costs from CD.
14. How will Class Counsel be paid?
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Class Counsel will ask the court to approve $400,000.00 as reasonable attorneys' fees and reimbursement
of litigation costs. The amount determined by the court amount will be paid by CD.
Class Counsel will also ask for Service Award payments of $2,500.00 for each of the Class Representatives.
Service Award payments will also be paid by CD.
Excluding Yourself from the Settlement
15. How do I opt out of the Settlement?
If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement. This
is called a Request for Exclusion, and is sometimes also called “opting out.” If you opt out, you will not receive
Settlement benefits or payment. However, you will keep any rights you may have to sue CD on your own about
the legal issues in this case.
If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You will not
be eligible to receive any Settlement benefits if you exclude yourself.
The deadline to exclude yourself from the Settlement is September 24, 2026.
To be valid, your Request for Exclusion must be in writing have the following information:
(1) the name of the Litigation: In re Community Dental Care, Case No. 62-CV-25-2490, pending in the
District Court for Ramsey County, Minnesota;
(2) your full name, current mailing address, telephone number, and email address;
(3) personal signature; and
(4) the words “Request for Exclusion” or a clear and similar statement that you do not want to
participate in the Settlement.
You may only exclude yourself—not any other person.
Mail your Request for Exclusion to the Settlement Administrator at:
CD Data Breach Settlement
ATTN: Exclusion Request
PO Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be submitted, postmarked, or emailed by September 24, 2026.
Commenting on or Objecting to the Settlement
16. How do I tell the Court if I like or do not like the Settlement?
If you are a Class Member and do not like part or all of the Settlement, you can object to it. Objecting means
telling the Court your reasons for why you think the Court should not approve the Settlement. The Court will
consider your views.
You cannot object if you have excluded yourself from the Settlement (see Question 15)
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You must provide the following information for the Court in writing to consider your objection:
(1) the name of the Litigation: In re Community Dental Care, Case No. 62-CV-25-2490, pending in the
District Court for Ramsey County, Minnesota;
(2) your full name, current mailing address, telephone number, and email address;
(3) information that proves that you are a Class Member (such as a notice you have received);
(4) a clear description of all the reasons you object; include any legal support, such as documents,
you may have for your objection;
(5) if you have hired your own lawyer to represent you for this objection, provide their name, bar
number, and contact information;
(6) if you or your lawyer have objected in any other cases in the past five years, list the names, courts,
the orders ruling on your objections, and civil action numbers for each of those cases;
(7) whether or not you or your lawyer would like to appear or speak at the Final Approval Hearing;
(8) if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a
full list of both, with a summary of each witness’s testimony;
(9) your signature (if you have hired your own lawyer, their signature is not sufficient).
For your objection to be valid, it must meet each of these requirements.
To be considered by the Court, you must file your complete objection with the Clerk of Court by September
24, 2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and
counsel for Defendants by September 24, 2026.
Clerk of the Court Settlement Administrator
Clerk of the Court CD Data Breach Settlement
District Court for Ramsey County ATTN: Objections
15 West Kellogg Boulevard PO Box 25226
St. Paul, MN 55102 Santa Ana, CA 92799-9958
Class Counsel Counsel for Defendant
Raina C. Borrelli Anju Suresh
Strauss Borrelli PLLC Hinshaw & Culbertson LLP
One Magnificent Mile 250 Nicollet Mall, Suite 1150
980 North Michigan Avenue, Suite 1610 Minneapolis, Minnesota 55401
Chicago, Illinois 60611
David M. Schultz
Christopher P. Renz Margaret A. Hayes
Chestnut Cambronne PA Hinshaw & Culbertson LLP
100 Washington Avenue South, Suite 1700 151 North Franklin Street, Suite 2500
Minneapolis, Minnesota 55401 Chicago, Illinois 60606
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Any Class Member who fails to comply in full with the requirements for objecting waives the right to object or
to be heard at the Final Approval Hearing and will be barred from making any objection to the Settlement and
shall be bound by the terms of the Agreement, including the Release.
Plaintiffs or CD or both shall have the right, but not the obligation, to respond to any objection by filing a copy
of the response with the Court, and serving a copy to the objector or their attorney.
17. What is the difference between objecting and excluding?
Objecting is telling the Court that you do not like something about the Settlement. You can object to the
Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement is
opting out and stating to the Court that you do not want to be part of the Settlement. If you opt out of the
Settlement, you cannot object to it because the Settlement no longer affects you.
The Court’s Final Approval Hearing
18. When is the Court’s Final Approval Hearing?
The Court will hold a final approval on November 23, 2026, at 11:00 AM Central Time, via Zoom.
At the final approval hearing, the Court will decide whether to approve the Settlement. The court will also
decide how Class Counsel should be paid, and whether to award Service Award payments to the Class
Representatives. The Court will also consider any objections to the Settlement.
If you are a Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost
(See Question 16).
The date and time of this hearing may change without further notice. Please check
www.CDDataBreach.com for updates.
19. Do I have to come to the Final Approval Hearing?
No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you
wish, but you do not have to.
If you file an objection, you do not have to come to the Final Approval Hearing to talk about it; the Court will
consider it as long as it was filed on time and meets the other criteria described in Question 16. You may also
pay your own lawyer to attend, but you do not have to.
If I Do Nothing
20. What happens if I do nothing at all?
If you do nothing, you will not receive a benefit from this Settlement.
You will also give up the rights described in Question 8.
Getting More Information
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21. How do I get more information?
This Notice is a summary of the proposed Settlement. The full Settlement Agreement and other related
documents are available at the Settlement Website, www.CDDataBreach.com.
If you have additional questions, you can ask for free help any time by contacting the Settlement
Administrator at:
• Email: [email protected]
• Call toll free, 24/7: (866) 675-2314
• By mail: CD Data Breach Settlement
c/o Settlement Administrator
PO Box 25226
Santa Ana, CA 92799-9958
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 15 West
Kellogg Boulevard, St. Paul, Minnesota 55102.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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