NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Deyerler, et al. v. HireVue, Inc.,
No. 2026LA00000141 (Cir. Ct. Lake County, Illinois)
For more information, visit www.VideoInterviewBIPASettlement.com.
PLEASE READ THIS NOTICE CAREFULLY. YOU MAY BE ENTITLED TO A CASH
PAYMENT FROM A CLASS ACTION SETTLEMENT IF, WHILE IN ILLINOIS, YOU
COMPLETED AN INTERVIEW THROUGH HIREVUE’S VIDEO INTERVIEW PLATFORM
THAT INVOLVED A MODEL THAT MAY HAVE COLLECTED YOUR “VOICE AND FACIAL
BIOMETRICS” AT ANY TIME BETWEEN JANUARY 27, 2017 AND JUNE 25, 2026.
This is a court-authorized notice of a proposed class action settlement. This is not a
solicitation from a lawyer and is not notice of a lawsuit against you.
WHY DID I GET THIS NOTICE?
This is a court-authorized notice of a proposed settlement in a class action lawsuit, Deyerler, et al. v.
HireVue, Inc., No. 2026LA00000141, pending in the Circuit Court of Lake County, Illinois before the Hon.
Daniel L. Jasica. The Settlement would resolve a lawsuit brought on behalf of persons who allege that
HireVue, Inc. collected individuals’ biometrics in Illinois through its automated interview technology
without first providing the individuals with legally required written disclosures and obtaining written
consent. If you received this notice, you have been identified as someone who may have completed an
interview through HireVue’s video interview platform that involved the collection of a candidate’s “voice
and facial biometrics” while in Illinois between January 27, 2017 and June 25, 2026.The Court has granted
preliminary approval of the Settlement and has conditionally certified the Settlement Class for purposes of
settlement only. This notice explains the nature of the class action lawsuit, the terms of the Settlement, and
the legal rights and obligations of the Settlement Class Members. Please read the instructions and
explanations below so that you can better understand your legal rights.
WHAT IS THIS LAWSUIT ABOUT?
The Illinois Biometric Information Privacy Act (“BIPA”), 740 ILCS 14/1, et seq., prohibits private
companies from capturing, obtaining, storing, transferring, and/or using the biometric identifiers and/or
information, such as voice and facial scans, of another individual for any purpose without first providing
them with certain written disclosures and obtaining written consent. This lawsuit alleges that Defendant
violated BIPA by collecting individuals’ biometrics through voice and facial scanning technology in Illinois
without first providing the requisite disclosures or obtaining the consent required by BIPA. Defendant
contests these claims, denies that it collected or possessed biometrics or any other information subject to
BIPA, and denies that it violated BIPA.
WHY IS THIS A CLASS ACTION?
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 “Class” or “Class
Members.” Once a Class is certified, a class action Settlement finally approved by the Court resolves the
By order of: Hon. Daniel L. Jasica, Circuit Court of Lake County, Illinois
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issues for all Settlement Class Members, except for those who exclude themselves from the Settlement
Class.
WHY IS THERE A SETTLEMENT?
To resolve this matter without the expense, delay, and uncertainties of litigation, the Parties have reached
a Settlement, which resolves all claims against Defendant and its affiliated entities. The Settlement requires
Defendant to pay money to the Settlement Class, as well as pay settlement administration expenses,
attorneys’ fees and costs to Class Counsel, and Service Awards to the Class Representatives, if approved
by the Court. The Settlement is not an admission of wrongdoing by Defendant and does not imply that there
has been, or would be, any finding that Defendant violated the law.
The Court has already preliminarily approved the Settlement. Nevertheless, because the settlement of a
class action determines the rights of all members of the class, the Court overseeing this lawsuit must give
final approval to the Settlement before it can be effective. The Court has conditionally certified the
Settlement Class for settlement purposes only, so that members of the Settlement Class can be given this
notice and the opportunity to exclude themselves from the Settlement Class, to voice their support or
opposition to final approval of the Settlement, and to submit a Claim Form to receive the relief offered by
the Settlement. If the Court does not give final approval to the Settlement, or if it is terminated by the
Parties, the Settlement will be void, and the lawsuit will proceed as if there had been no settlement and no
certification of the Settlement Class.
WHO IS IN THE SETTLEMENT CLASS?
You are a member of the Settlement Class if, while within the state of Illinois, you completed a HireVue
interview that involved the relevant technology between January 27, 2017 and June 25, 2026. If you are a
member of the Settlement Class, then you may visit the settlement website,
www.VideoInterviewBIPASettlement.com, to submit a claim for cash benefits.
WHAT DOES THE SETTLEMENT PROVIDE?
Cash Payments. Defendant has agreed to create a $3,750,000 Settlement Fund for the Class Members.
All Settlement Class Members are entitled to submit a Claim Form to receive a payment out of the
Settlement Fund. If the Settlement is approved, each Settlement Class Member who submits a timely Claim
Form that is deemed valid will be entitled to an equal payment paid out of the Settlement Fund after payment
is made for administrative expenses, attorneys’ fees and expenses, and Class Representatives’ service
awards. The amount of each valid claimant’s payment is estimated to be $150, but the exact amount is
unknown at this time and depends on several factors, including how many valid claims are submitted. The
Settlement Administrator will issue a check or electronic payment to each Class Member who submits a
valid Claim Form following the final approval of the Settlement. All checks issued to Settlement Class
Members will expire and become void 75 days after they are issued. Additionally, the attorneys who brought
this lawsuit (listed below) will ask the Court to award them attorneys’ fees of up to one-third of the Gross
Settlement Fund, plus reasonable expenses, for the substantial time, expense, and effort spent investigating
the facts, litigating the case, and negotiating the Settlement. The three Class Representatives also will apply
to the Court for a payment of up to $6,000.00 each for their time, effort, and service in this matter. Class
Counsel will file with the Court their request for attorneys’ fees, expenses, and service awards on
September 7, 2026, and will post their request on the Settlement Website.
By order of: Hon. Daniel L. Jasica, Circuit Court of Lake County, Illinois
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WHAT ARE MY OPTIONS?
(1) Submit a Claim for Money.
To obtain money from the Settlement, you must submit a Claim Form by October 13, 2026. You may
obtain a Claim Form at www.VideoInterviewBIPASettlement.com, and you may submit your Claim Form
online at the same website. You may also submit a Claim Form to the Settlement Administrator by U.S.
Mail, postmarked by October 13, 2026, at HireVue BIPA Settlement, c/o Simpluris, P.O. Box 25226, Santa
Ana, CA 92799. If the Settlement is approved and your claim is deemed valid, a check will be mailed to
you or, if you choose, the money will be electronically transferred. Submitting a valid and timely Claim
Form is the only way to receive a payment from this Settlement and is the only thing you need to do to
receive a payment.
(2) Exclude yourself.
You may exclude yourself from the Settlement on an individual basis. If you do so, you will not receive
any cash payment, but you will release any claims you may have against Defendant and the Released Parties
(as that term is defined in the Settlement Agreement) and are free to pursue whatever legal rights you may
have at your own risk and expense. To exclude yourself from the Settlement, you must mail a signed letter
to the Settlement Administrator at HireVue BIPA Settlement, c/o Simpluris, P.O. Box 25226, Santa Ana,
CA 92799, postmarked by September 28, 2026, or send an email to
[email protected] on or by September 28, 2026. Your request for exclusion must
include the name and case number of this litigation, as well as your full name, home address, email address,
telephone number, the name and number of the Action, a statement that you wish to be excluded, and your
signature. So-called “mass” or “class” exclusion requests are not permitted.
(3) Object to the Settlement.
If you wish to object to the Settlement, you must submit your objection in writing to the Clerk of the Court
of the Circuit Court of Lake County, Illinois, 18 N. County Street, Waukegan, IL 60085 and the Settlement
Administrator. The objection must be received by the Court no later than September 28, 2026. Any
objection to the proposed Settlement must include (1) the objector’s name, address, and email; (2) the case
name and number of this Action; (3) an explanation of the basis upon which the objector claims to be a
Class Member; (4) whether the objection applies only to the objector, a subset of the Settlement Class, or
the entire Settlement Class; (5) all grounds for the objection, including all citations to legal authority and
evidence supporting the objection; (6) 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 five years; (7) the name and contact
information of any and all attorneys representing, advising, or in any way assisting the objector in
connection with the preparation or submission of the objection or who may profit from the pursuit of the
objection, who must enter an appearance with the Court in accordance with the Court’s local rules; and (8)
a statement indicating whether the objector intends to appear at the Final Approval Hearing (either
personally or through counsel). If you hire an attorney in connection with making an objection, that attorney
must also file with the court a notice of appearance by the objection deadline of September 28, 2026. If
you do hire your own attorney, you will be solely responsible for payment of any fees and expenses the
attorney incurs on your behalf. If you exclude yourself from the Settlement, you cannot file an objection.
You may appear at the Final Approval Hearing, which will be held on October 28, 2026 at 9:00 a.m., in
person or through counsel at the Circuit Court of Lake County, Illinois, 18 N. County Street, Waukegan, IL
60085, Courtroom 202 (remote access: https://19thcircuitcourt.state.il.us/2187/Daily-Remote-Court-
Session-Schedule-C302), to show cause why the proposed Settlement should not be approved as fair,
reasonable, and adequate. Attendance at the hearing is not necessary; however, persons wishing to be heard
By order of: Hon. Daniel L. Jasica, Circuit Court of Lake County, Illinois
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orally in opposition to the Final Approval of the Settlement, the request for attorneys’ fees and expenses,
and/or the request for a Service Award to each of the Class Representatives are required to indicate in their
written objection their intention to appear at the hearing on their own behalf or through counsel and to
identify the names of any witnesses they intend to call to testify at the Final Approval Hearing, as well as
any exhibits they intend to introduce at the Final Approval Hearing.
(4) Do Nothing.
If you do nothing, you will receive no money from the Settlement Fund, but you will still be bound by all
orders and judgments of the court. Unless you exclude yourself from the Settlement, you will not be able
to file or continue a lawsuit against the Released Parties regarding any of the Released Claims.
Submitting a valid and timely Claim Form is the only way to receive a payment from this Settlement. To
submit a Claim Form, or for more information on how to request exclusion from the Class or file an
objection, please visit the Settlement website, www.VideoInterviewBIPASettlement.com, or call 1- (833)
421-7334.
WHAT RIGHTS AM I GIVING UP IN THIS SETTLEMENT?
Unless you exclude yourself from this Settlement, you will be considered a member of the Settlement Class,
which means you give up your right to file or continue a lawsuit against Defendant and the other Released
Parties (as defined in the Settlement Agreement) relating to their alleged collection of biometrics or other
breach of BIPA between January 27, 2017 and June 25, 2026. Giving up your legal claims is called a
release. The precise terms of the release are in the Settlement Agreement, which is available on the
settlement website. Unless you formally exclude yourself from this Settlement, you will release your claims
whether or not you submit a Claim Form and receive payment. 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.
WHEN WILL I BE PAID?
The Parties cannot predict exactly when (or whether) the Court will give final approval to the Settlement,
so please be patient. However, if the Court finally approves the Settlement, you will be paid as soon as
possible after the court order becomes final, which should occur within approximately 60 days after the
Settlement has been finally approved. If there is an appeal of the Settlement, payment may be delayed.
Updated information about the case is available at www.VideoInterviewBIPASettlement.com, or you can
call the Settlement Administrator at 1- (833) 421-7334 or contact Class Counsel at the information provided
below.
WHEN WILL THE COURT RULE ON THE SETTLEMENT?
The Court has already given preliminary approval to the Settlement. A final hearing on the Settlement,
called a Final Approval Hearing, will be held to determine the fairness of the Settlement. At the Final
Approval Hearing, the Court will also consider whether to make final the certification of the Class for
settlement purposes, hear any proper objections and arguments to the Settlement, as well as any requests
for an award of attorneys’ fees, costs, and expenses and Class Representatives’ Service Awards that may
be sought by Class Counsel. The Court will hold the Final Approval Hearing on October 28, 2026, at 9:00
am. The hearing is subject to being changed by the Court, including taking place remotely via
By order of: Hon. Daniel L. Jasica, Circuit Court of Lake County, Illinois
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videoconference (https://19thcircuitcourt.state.il.us/2187/Daily-Remote-Court-Session-Schedule-C302),
so please visit www.VideoInterviewBIPASettlement.com for updates.
If the Settlement is given final approval, the Court will not make any determination as to the merits of the
claims against Defendant or its defenses to those claims. Instead, the Settlement’s terms will take effect and
the lawsuit will be dismissed on the merits with prejudice. Both sides have agreed to the Settlement to
achieve an early and certain resolution to the lawsuit in a manner that provides specific and valuable benefits
to the members of the Settlement Class.
If the Court does not approve the Settlement, if it approves the Settlement and the approval is reversed on
appeal, or if the Settlement does not become final for some other reason, you will not be paid at this time
and Class Members will receive no benefits from the Settlement. Plaintiffs, Defendant, and all of the Class
Members will be in the same position as they were prior to the execution of the Settlement, and the
Settlement will have no legal effect, no class will remain certified (conditionally or otherwise), and the
Plaintiffs and Defendant will continue to litigate the lawsuit. There can be no assurance that if the Settlement
is not approved, the Settlement Class will recover more than is provided in the Settlement, or indeed,
anything at all.
WHO REPRESENTS THE CLASS?
The Court has approved the following attorneys to represent the Settlement Class. They are called “Class
Counsel.” You will not be charged for these lawyers. If you want to be represented by your own lawyer
instead, you may hire one at your own expense.
Evan M. Meyers
David L. Gerbie
Andrew T. Heldut
MCGUIRE LAW, P.C.
55 W. Wacker Drive, 9th Fl.
Chicago, IL 60601
[email protected]
[email protected]
[email protected]
Tel: 312-893-7002
WHERE CAN I GET ADDITIONAL INFORMATION?
This Notice is only a summary of the proposed Settlement of this lawsuit. More details are in the Settlement
Agreement which, along with other documents, can be obtained at
www.VideoInterviewBIPASettlement.com. If you have any questions, you can also call the Settlement
Administrator at 1- (833) 421-7334 or contact Class Counsel at the number or email addresses set forth
above. In addition to the documents available on the settlement website, all pleadings and documents filed
in court may be reviewed or copied in the Office of the Clerk. Please do not call the Judge or the Clerk of
the Court about this case. They will not be able to give you advice on your options.
By order of: Hon. Daniel L. Jasica, Circuit Court of Lake County, Illinois
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