NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
In re Highlands Oncology Group Data Breach Litigation
Case No. 72CV-25-3420
Circuit Court for Washington County, Arkansas
IF YOUR PRIVATE INFORMATION WAS COMPROMISED IN THE JUNE 2025 HIGHLANDS
ONCOLOGY GROUP DATA INCIDENT, A PROPOSED CLASS ACTION SETTLEMENT MAY
AFFECT YOUR RIGHTS, AND 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 Highlands Oncology Group (“Highlands Oncology” or
“Defendant”) in a class action lawsuit. This case is about the targeted cyberattack on Highlands
Oncology's computer systems that occurred in June 2025 (the “Data Incident”). Certain files that
contained private information were accessed. These files may have contained personal information
such as names; dates of birth; Social Security numbers; driver’s license/state identification
numbers; passport numbers; credit/debit card numbers; financial account numbers; medical
treatment information; medical record numbers; patient account numbers; and/or health insurance
policy information.
• The lawsuit is called In re Highlands Oncology Group Data Breach Litigation, Case No. 72CV-25-
3420. It is pending in the Circuit Court for Washington County, Arkansas (the “Action”).
• Highlands Oncology 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 Action.
• Highlands Oncology's records indicate that you are a Class Member and entitled to benefits under
the Settlement. You may have received a previous notice directly from Highlands Oncology.
• 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 22, 2026
is by submitting a valid and timely Claim Form.
The fastest way to submit your Claim Form is online at
www.HighlandsOncologySettlement.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 October 7, 2026
SETTLEMENT or payment. This option allows you to sue, continue to sue, or be
part of another lawsuit against the Defendants 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 October 7, 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. If you object, you may also
file a claim for Settlement benefits.
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.
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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 ................................................ 5
THE LAWYERS REPRESENTING YOU ............................................................................... 6
EXCLUDING YOURSELF FROM THE SETTLEMENT ............................................................ 6
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 Circuit Court for Washington County, Arkansas, 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 Highlands Oncology Group Data Breach Litigation, Case No. 72CV-25-3420. It is
pending in the Circuit Court for Washington County, Arkansas. The people that filed this lawsuit are called
the “Plaintiffs” (or “Class Representatives”) and the company they sued, Highlands Oncology Group, is
called the “Defendant.”
2. What is this lawsuit about?
This lawsuit alleges that during the June 2025 targeted cyberattack on Highlands Oncology's computer
systems, certain files that contained private information were accessed. These files may have contained
personal information such as names; dates of birth; Social Security numbers; driver’s license/state
identification numbers; passport numbers; credit/debit card numbers; financial account numbers; medical
treatment information; medical record numbers; patient account numbers; and/or health insurance policy
information.
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 Jim Davis; Nathan Stewart;
Michael Plunkentt; Michael Crawford; Keely Boman; Dasha Nichols; Renetta Frisque; Michelle Nalley; Stacye
Peebles; Julie Rae Gonzalez; and Matthew Prunty, III. Everyone included in this Action are the Class Members.
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4. Why is there a Settlement?
The Court did not decide whether the Plaintiffs or the Defendant are right. Both sides have agreed to a
Settlement to avoid the costs and risks of a trial, and to allow the Class Members to receive benefits from the
Settlement. 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 residing in the United States whose Private
Information was compromised in the Data Breach on or around June 2025.”
6. Are there exceptions to being included?
Yes. Excluded from the Class are: (1) all persons who are directors and officers of Highlands Oncology; (2)
governmental entities; and (3) the Judge assigned to this case, that Judge’s immediate family, and Court staff.
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: (833) 421-7336
• By mail: Highlands Oncology Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also view the Settlement Agreement at www.HighlandsOncologySettlement.com.
The Settlement Benefits
7. What does the Settlement provide?
All Settlement Class Members may claim Medical Data Monitoring and one of two Cash Payment options.
The benefits are explained in more detail below.
MEDICAL DATA MONITORING. All Class Members are eligible to enroll in three years of CyEx Medical Shield
Complete. 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, documented out-of-pocket losses
related to fraud and/or identity theft as a result of the Data Incident, you can get back up to $4,250.00.
The losses must have occurred between June 2, 2025, and October 22, 2026.
This benefit covers out-of-pocket expenses like:
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• 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
You need to send proof, like bank statements or receipts, to show how much you spent or lost. You
can also send notes or papers you made yourself to explain or support other proof, but those notes
or papers alone are not enough to make a valid claim. Your proof or notes should show that your
expenses were because of the Data Incident.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Cash Payment B – Alternate Cash. Instead of Cash Payment A, you may claim a one-time cash
payment of $50.00.
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: (833) 421-7336
By mail: Highlands Oncology Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
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 Highlands Oncology about
the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section XI)
describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available
at www.HighlandsOncologySettlement.com.
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.HighlandsOncologySettlement.com. If you
prefer, you can download a printable Claim Form from the website and mail it to the Settlement Administrator
at:
Highlands Oncology Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free,
(833) 421-7336, by email [email protected], or by U.S. mail at the address above.
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10. Are there any important Settlement payment deadlines?
If you are submitting a Claim Form online, you must do so by October 22, 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 22, 2026.
11. When will the Settlement benefits be issued?
The Court will hold a final approval hearing on November 6, 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 Mariya Weekes of Milberg PLLC and J. Gerard Stranch, IV of Stranch,
Jennings & Garvey, PLLC, 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 your own lawyer, you may hire one at your
expense.
14. How will Class Counsel be paid?
Class Counsel will ask the court to approve $400,000.00 as reasonable attorneys' fees and reimbursement
of litigation costs. This amount will be paid by Highlands Oncology.
Class Counsel will also ask for Service Award payments of $1,500.00 for each of the Class Representatives.
Service Award payments will also be paid by Highlands Oncology.
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 Highlands Oncology
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 October 7, 2026.
To be valid, your Request for Exclusion must have the following information:
(1) the name of the Action: In re Highlands Oncology Group Data Breach Litigation, Case No. 72CV-25-
3420, pending in the Circuit Court for Washington County, Arkansas;
(2) your full name, mailing address, telephone number, and email address;
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(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:
Highlands Oncology Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Your Request for Exclusion must be submitted and postmarked by October 7, 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)
You must provide the following information for the Court to consider your objection:
(1) the name of the Action: In re Highlands Oncology Group Data Breach Litigation, Case No. 72CV-25-
3420, pending in the Circuit Court for Washington County, Arkansas;
(2) your full name, mailing address, telephone number, and email address;
(3) a clear description of all the reasons you object; include any legal support, such as documents, you
may have for your objection;
(4) if you have hired your own lawyer to represent you for this objection, provide their name, bar
number, and contact information;
(5) 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;
(6) if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a
full list of both;
(7) whether or not you or your lawyer would like to speak at the Final Approval Hearing; and
(8) 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 October 7,
2026. You must also send a copy via U.S. Mail of the objection to the Settlement Administrator, Class
Counsel, and counsel for Defendants.
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Clerk of the Court Settlement Administrator
Clerk of the Court Highlands Oncology Data Incident Settlement
280 N College Ave. c/o Settlement Administrator
Fayetteville, AR 72701 P.O. Box 25226
Santa Ana, CA 92799
Class Counsel Counsel for Defendants
J. Gerard Stranch, Adam C. Smith
STRANCH, JENNINGS & GARVEY, PLLC McDonald Hopkins LLC
223 Rosa L. Parks Avenue, Suite 200 600 Superior Avenue E, Suite 2100
Nashville, TN 37203 Cleveland, OH 44114
Mariya Weekes
MILBERG, PLLC
333 SE 2nd Avenue, Suite 2000
Miami, FL, 33131
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 hearing on November 6, 2026 at 9:00 a.m. Central Time, at the Circuit
Court for Washington County, Arkansas, at 280 N College Ave, Fayetteville, AR 72701.
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.HighlandsOncologySettlement.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. You may also pay your own lawyer to attend, but you do not have to.
In re Highlands Oncology Group Data Breach Litigation Page 8 of 9
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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
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.HighlandsOncologySettlement.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: (833) 421-7336
• By mail: Highlands Oncology Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 280 N College
Ave, Fayetteville, AR 72701.
DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT
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