NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Singh v. The Moses H. Cone Memorial Hospital Operating Corp., et al.
Case No. 1:24-cv-00558
United States District Court for the Middle District of North Carolina
IF YOU ACCESSED THE MYCHART PATIENT PORTAL OR
COMPLETED A SUBMISSION FORM ON A CONE MEMORIAL
HOSPITAL OR CONE HEALTH WEBSITE BETWEEN SEPTEMBER
1, 2016 AND NOVEMBER 3, 2022, A PROPOSED CLASS ACTION
SETTLEMENT MAY AFFECT YOUR RIGHTS AND ENTITLE YOU
TO 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 The Moses H. Cone Memorial Hospital Operating
Corporation, d/b/a Cone Health and The Moses H. Cone Memorial Hospital d/b/a Cone Health
(“Defendants” or “Cone Health”), in a class action lawsuit that claims Cone Health improperly
tracked the information of users on their website, including the MyChart patient portal.
• The lawsuit is captioned Singh v. The Moses H. Cone Memorial Hospital Operating Corp., et al.,
Case No. 1:24-cv-00558, pending in the United States District Court for the Middle District of
North Carolina (the “Action”).
• Cone Health denies each and every one of the claims and contentions alleged against it in the
Action and denies all charges of wrongdoing or liability alleged (or which could be alleged) in the
Action, but has agreed to a settlement to avoid the costs and risks associated with continuing the
litigation.
• You are included in the Settlement Class if between September 1, 2016 and November 3, 2022,
you accessed the MyChart patient portal on Defendants’ website or completed a submission form
on Defendants’ website.
• 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
DEADLINE
THIS SETTLEMENT
The only way to receive benefits from this
Settlement is by submitting a valid and timely
Claim Form.
The fastest way to submit your Claim Form is
online at www.ConePixelSettlement.com.
SUBMIT A CLAIM October 5, 2026
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.
You can choose to opt out of the Settlement and
receive no payment. This option allows you to
OPT OUT OF THE sue, continue to sue, or be part of another lawsuit
October 5, 2026
SETTLEMENT against the Defendants related to the legal claims
resolved by this Settlement. You can hire your own
legal counsel at your own expense.
If you do not opt out of the Settlement, you may
OBJECT TO THE object to it by writing to the Court about why you
SETTLEMENT don’t like the Settlement. You may also ask the
October 5, 2026
AND/OR ATTEND A Court for permission to speak about your objection
HEARING at the Final Approval Hearing. If you object, you
may also file a claim for Settlement benefits.
Unless you opt out of the Settlement, you are
automatically part of the Settlement. If you do
nothing, you will not receive benefits from this
DO NOTHING Settlement and you will give up the right to sue, N/A
continue to sue, or be part of another lawsuit
against the Defendants 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 that is presiding over this case still must decide whether to grant final approval of the
Settlement. Payments will only be made after the Court grants final approval of the Settlement and after
any appeals are resolved.
For complete information and to file a
claim, scan this QR code to go directly
to the Settlement website:
www.ConePixelSettlement.com
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WHAT THIS NOTICE CONTAINS
BASIC INFORMATION
1. Why was this Notice Issued? ......................................................................................................4
2. What is this lawsuit about? .........................................................................................................4
3. What is a class action? ................................................................................................................4
4. Why is there a Settlement? .........................................................................................................4
WHO IS IN THE SETTLEMENT
5. Who is included in the Settlement? ............................................................................................4
6. Are there exceptions to being included? .................................................................................4, 5
THE SETTLEMENT BENEFITS
7. What does the Settlement provide? .............................................................................................5
8. What claims am I releasing if I stay in the Settlement Class? ....................................................5
RECEIVING SETTLEMENT BENEFITS
9. Do I need to submit a claim to receive a Settlement payment? ..................................................6
10. Are there any deadlines I need to know about? ........................................................................6
11. When will the Settlement benefits be issued? ...........................................................................6
THE LAWYERS REPRESENTING YOU
12. Do I have a lawyer in this case? ................................................................................................6
13. Should I get my own lawyer? ...................................................................................................6
14. How will Class Counsel be paid? .............................................................................................6
EXCLUDING YOURSELF FROM THE SETTLEMENT
15. How do I opt out of the Settlement? .........................................................................................7
COMMENTING ON OR OBJECTING TO THE SETTLEMENT
16. How do I tell the Court if I like or do not like the Settlement? ............................................7, 8
17. What is the difference between objecting and excluding? ........................................................8
THE COURT’S FINAL APPROVAL HEARING
18. When is the Court’s Final Approval Hearing? .....................................................................8, 9
19. Do I have to come to the Final Approval Hearing? ..................................................................9
GETTING MORE INFORMATION
20. How do I get more information? ...............................................................................................9
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BASIC INFORMATION
1. Why was this Notice issued?
The United States District Court for the Middle District of North Carolina authorized this Notice because
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 captioned Singh v. The Moses H. Cone Memorial Hospital Operating Corp., et al., Case
No. 1:24-cv-00558, pending in the United States District Court for the Middle District of North Carolina.
The person who filed this lawsuit is called the “Plaintiff” (or “Class Representative”) and the entities they
sued, The Moses H. Cone Memorial Hospital Operating Corporation, d/b/a Cone Health, and The Moses
H. Cone Memorial Hospital d/b/a Cone Health, are called the “Defendants.”
2. What is this lawsuit about?
This lawsuit claims that Cone Health improperly tracked the information of users on their website,
including the MyChart patient portal.
3. What is a class action?
In a class action, one or more individuals sue on behalf of other people with similar claims. This individual
is known as “Plaintiff” or “Class Representative.” 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 a settlement. In this Settlement, the Class Representative is Ashika Singh. Everyone
included in this Action is a Class Member.
4. Why is there a Settlement?
The Court did not decide in favor of the Plaintiff or the Defendants. Plaintiff and the Defendants have
agreed to a Settlement to avoid the costs and delays of litigation, and to allow the Class Members to
receive benefits from the Settlement. The Plaintiff and her attorney think the Settlement is best for all
Class Members. This Settlement is not an admission of wrongdoing by Cone Health and does not imply
that there has been, or would be, any finding that Cone Health violated the law. There has been no
determination by the Court in this Action that Cone Health has done anything wrong.
WHO IS IN THE SETTLEMENT?
5. Who is included in the Settlement?
The Settlement Class includes living individuals who between September 1, 2016 and November 3, 2022
accessed the MyChart patient portal on Defendants’ website or completed a submission form on
Defendants’ website.
6. Are there exceptions to being included?
Yes. Excluded from the Settlement Class are: (a) any Judge presiding over this Action, any members of
the Judges’ respective staffs, and immediate members of the Judge’s family; (b) employees, officers, and
agents of the Defendants, Defendants’ affiliates, subsidiaries, parent companies, successors, predecessors,
and any entity in which the Defendants or their parents have a controlling interest; (c) persons who timely
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and validly request exclusion from or opt out of the Settlement Class; (d) the legal representatives,
successors, or assigns of any such excluded persons; and (e) Class Counsel.
If you are not sure whether you are included in the Settlement Class, you can ask for free help by contacting
the Settlement Administrator at:
• Email: [email protected]
• Call toll free, 24/7: 1-833-421-7350
• By mail:
Cone Health Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also view the Settlement Agreement at www.ConePixelSettlement.com
THE SETTLEMENT BENEFITS
7. What does the Settlement provide?
Cone Health has agreed to provide a Settlement Fund of $1,765,000.00. After reasonable attorneys’ fees
and expenses, a service award for the Class Representative, and costs of administration are paid, the net
amount of the Settlement Fund will be equally distributed to all Settlement Class Members who submit a
valid and timely claim. The final amount of the payment will depend on the total number of valid claims.
If you have questions about receiving your settlement payment, you can ask for free help by contacting
the Settlement Administrator at:
• Email: [email protected]
• Call toll free, 24/7: 1-833-421-7350
• By mail:
Cone Health Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also view the Settlement Agreement at www.ConePixelSettlement.com
8. What claims am I releasing if I stay in the Settlement Class?
Unless you opt out of the Settlement, you cannot sue, continue to sue, or be part of any other lawsuit
against the Defendants about any of the legal claims this Settlement resolves. The “Release” section of
the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement
Class. The Settlement Agreement is available for review at www.ConePixelSettlement.com.
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Questions? Call 1-833-421-7350 Toll-Free or Visit www.ConePixelSettlement.com
RECEIVING SETTLEMENT BENEFITS
9. Do I need to submit a claim to receive a Settlement payment?
Yes, you must submit a valid and timely claim by October 5, 2026, to receive a Settlement payment. If
you are submitting a paper Claim Form by U.S. Mail, it must be postmarked by October 5, 2026.
To submit your claim, affirm that between September 1, 2016 and November 3, 2022, you accessed the
MyChart patient portal on Defendants’ website or completed a submission form on Defendants’ website,
and sign the Claim Form.
10. Are there any deadlines I need to know about?
Yes, claim forms must be submitted by October 5, 2026. If you are submitting a paper claim form by
U.S. Mail, it must be postmarked by October 5, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on November 5, 2026. If the Court approves the Settlement,
there may be appeals. It is always uncertain whether appeals will be filed and, if so, how long it will take
to resolve them.
Settlement benefits will be distributed if the Court grants final approval of the Settlement and after any
appeals are resolved, or after the period to seek an appeal has expired.
THE LAWYERS REPRESENTING YOU
12. Do I have a lawyer in the case?
Yes, the Court has appointed attorneys David S. Almeida of Almeida Law Group LLC, and Brandon M.
Wise of Peiffer Wolf Carr Kane Conway & Wise, LLP, to represent you and other Class Members (“Class
Counsel”).
13. Should I get my own lawyer?
You will not be charged for Class Counsel’s services. If you want to be represented by your own lawyer,
you may hire one at your own expense.
14. How will Class Counsel be paid?
Class Counsel will seek Court approval for attorneys’ fees, costs, and expenses not to exceed $613,333.33,
and a service award of $5,000.00 for the Class Representative for bringing this Action on behalf of the
Class. These fees and costs, as well as the costs of administration, will be paid from the Settlement Fund.
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Questions? Call 1-833-421-7350 Toll-Free or Visit www.ConePixelSettlement.com
EXCLUDING YOURSELF FROM THE SETTLEMENT
15. How do I opt out of the Settlement?
If you do not want to receive a Settlement payment, and you want to keep your right, if any, to separately
sue the Defendants about the legal issues in this case, you must exclude yourself (“opt out”) from the
Settlement Class. The deadline to submit a request for exclusion from the Settlement is October 5, 2026.
To exclude yourself from the Settlement, you must submit a written request with the following
information:
1. the case name: Singh v. The Moses H. Cone Memorial Hospital Operating Corp., et al., Case No.
1:24-cv-00558, pending in the United States District Court for the Middle District of North
Carolina
2. your full name and current address;
3. personal signature; and
4. the words “Request for Exclusion” or a clear and similar statement that you do not wish to
participate in the Settlement.
Your request for exclusion must be mailed to the Settlement Administrator at the address below,
postmarked no later than October 5, 2026.
Cone Health Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You
will not receive a Settlement payment if you exclude yourself.
You may only exclude yourself—not any other person.
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 a portion or all of the Settlement, you can object to it, if you
choose. You can give reasons why you think the Court should not approve it. The Court will consider your
views.
For an objection to be considered by the Court, the objection must include:
i. your full name, current address, telephone number, and email address;
ii. contain your original signature;
iii. contain proof that you are a member of the Settlement Class (e.g., copy of settlement notice);
iv. state that you object to the Settlement, in whole or in part;
v. state why you believe you are a member of the Settlement Class;
vi. provide a statement of the legal and factual basis for the Objection;
vii. state whether your objection applies to you alone, multiple people, or the entire class;
viii. provide copies of any documents that you wish to submit in support of your position;
ix. identify all counsel representing you, if any;
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x. contain the signature of your duly authorized attorney or other duly authorized representative,
if any, along with documentation setting forth such representation; and
xi. contain a list, including case name, court and docket number, of all other cases in which you
and/or your attorney have filed an objection to any proposed class action settlement in the past
three (3) years;
xii. state whether you intend to appear at the Final Approval Hearing, and if so, whether personally
or through counsel; and
xiii. if you are represented by counsel that intends to speak at the Final Approval Hearing, you must
also identify any witnesses you intend to call at the Final Approval Hearing and describe any
documents or evidence you intend to offer at the Final Approval Hearing.
To be timely, a written notice of an objection containing the above information must be filed with the
Clerk of the Court, with copies served on Class Counsel and Counsel for Cone Health, no later than
October 5, 2026.
Clerk of the Court Class Counsel Counsel for Cone Health
Clerk of the Court David S. Almeida Patrick M. Kane
324 W. Market Street Almeida Law Group LLC Fox Rothschild LLP
Greensboro, NC 27401-2544 849 W. Webster Avenue 230 N. Elm Street
Chicago, IL 60614 Suite 1200
Greensboro, NC 27401
Brandon M. Wise
Peiffer Wolf Carr Kane
Conway & Wise, LLP
One US Bank Plaza
Suite 1950
St. Louis, MO 63101
If you do not comply with the requirements for objecting you will waive and forfeit any and all rights you
may have to appear separately and/or to object to the Settlement, and will be bound by all the terms of the
Settlement and by all proceedings, orders and judgments in the Litigation.
17. What is the difference between objecting and excluding yourself?
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 hearing on November 5, 2026 at 2:00 PM Eastern Time, in the
United States District Court, Middle District of North Carolina, 324 W. Market Street Greensboro, NC
27401.
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At the final approval hearing, the Court will consider whether to approve the Settlement, how much
attorneys’ fees and costs to award to Class Counsel for representing the Settlement Class, and whether to
award a Service Award to the Class Representative who brought this Action on behalf of the Settlement
Class. The Court will also consider any objections to the Settlement.
If you are a Class Member, you or your attorney may ask permission to speak at the hearing at your own
cost. The date and time of this hearing may change without further notice. Please check
www.ConePixelSettlement.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. If you file an objection, you do not have to come to the Final Approval Hearing to talk about
it. If you file your written objection on time, the Court will consider it. You may also pay your own lawyer
to attend, but such attendance is not necessary for the Court to consider an objection that was filed on
time.
GETTING MORE INFORMATION
20. How do I get more information?
This Notice summarizes the proposed Settlement. Complete details are provided in the Settlement
Agreement. The Settlement Agreement and other related documents are available at the Settlement
Website, www.ConePixelSettlement.com.
If you have additional questions, you can ask for free help by contacting the Settlement Administrator at:
• Email: [email protected]
• Call toll free, 24/7: 1-833-421-7350
• By mail:
Cone Health Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Publicly filed documents can also be obtained by visiting the office of the Clerk of the Court, U.S. District
Court for the Middle District of North Carolina, 324 W. Market Street, Greensboro, NC 27401-2544.
DO NOT CONTACT THE COURT OR CLERK OF COURT, CONE HEALTH, OR CONE
HEALTH’S COUNSEL REGARDING THIS SETTLEMENT. ALL QUESTIONS ABOUT THE
SETTLEMENT SHOULD BE REFERRED TO THE SETTLEMENT ADMINISTRATOR OR
CLASS COUNSEL.
For complete information and to file a
claim, scan this QR code to go directly
to the Settlement website:
www.ConePixelSettlement.com
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Questions? Call 1-833-421-7350 Toll-Free or Visit www.ConePixelSettlement.com
