SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN DIEGO
JENNIFER MCCALL and JOELLEN Case No. 25CU041352N
BARRACLOUGH, on behalf of themselves
and all others similarly situated,
Plaintiffs,
v.
MICHAEL KORS (USA), INC., a Delaware
corporation,
Defendant.
IF YOU MADE A PURCHASE AT A MICHAEL KORS OUTLET STORE
BETWEEN MAY 10, 2019, AND NOVEMBER 14, 2025, YOU MAY BE
ELIGIBLE TO RECEIVE A MERCHANDISE CERTIFICATE FOR UP TO
$30 OFF A SINGLE FUTURE IN-STORE PURCHASE AT A MICHAEL
KORS OUTLET STORE.
A STATE COURT AUTHORIZED THIS NOTICE. THIS IS NOT A SOLICITATION FROM A LAWYER.
A settlement (“Settlement”) has been proposed in the class action lawsuit referenced above
pending in the Superior Court of California, County of San Diego (the “Action”). If the Court
gives final approval to the Settlement, Michael Kors (USA), Inc. (“Michael Kors”) will provide,
for each Settlement Class Member 1 who made a Qualifying Purchase during the Class Period:
(1) for Settlement Class Members who are KORSVIP account holders at the time of receipt of
this Notice and have a California or Oregon mailing address on file with Michael Kors and who
do nothing, a Merchandise Certificate for up to $30.00; and (2) for Settlement Class Members
who do not have a California or Oregon mailing address on file with Michael Kors, and who
timely complete and submit a valid Claim form, a Merchandise Certificate for up to $30.00. All
Merchandise Certificates may be applied toward any single in-store purchase at a Michael Kors
Outlet Store for up to $30.00.
YOUR LEGAL RIGHTS ARE AFFECTED WHETHER YOU ACT OR DON’T ACT.
READ THIS NOTICE CAREFULLY.
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Capitalized terms not otherwise defined herein shall have the same meaning ascribed to them in
the Settlement Agreement, available HERE.
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YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
SUBMIT A If you do not have a California or Oregon mailing address Deadline:
CLAIM on file with Michael Kors, and you made one or more March 06,
FORM Qualifying Purchase(s) between May 10, 2019, and 2026
November 14, 2025 (the “Class Period”): if the Court
approves the Settlement, you will receive one (1) Merchandise
Certificate after completion and submission of a valid Claim
Form. You will also give up your right to object to the
Settlement, and you will not be able to be part of any other
lawsuit about the legal claims in this Action. Visit the
Settlement Website, located at
www.MichaelKorsOutletSettlement2026.com, to obtain a
Claim Form.
WHEN A If you: (1) received direct Email Notice of this Settlement; N/A
CLAIM (2) you are a KORSVIP account holder with a California or
FORM IS Oregon mailing address; and (3) you made one or more
NOT Qualifying Purchase(s) at a California or Oregon Michael
NECESSARY Kors Outlet store during the Class Period: if you do nothing,
and the Court approves the Settlement, you will receive one
(1) Merchandise Certificate in the amount of $30.00. You will
also give up your right to object to the Settlement, and you will
not be able to be part of any other lawsuit about the legal claims
in this Action.
EXCLUDE If you exclude yourself from the Settlement, you will not receive Deadline:
YOURSELF a Merchandise Certificate under the Settlement. Excluding March 06,
yourself is the only option that allows you to bring or maintain 2026
your own lawsuit against Michael Kors for the allegations in the
Action ever again.
OBJECT You may file a written objection telling the Court why you Deadline:
object to (i.e., don’t like) the Settlement and think it shouldn’t March 06,
be approved. Submitting an objection does not exclude you 2026
from the Settlement.
GO TO THE The Court will hold a “Fairness Hearing” to consider the Hearing
“FAIRNESS Settlement, the request for attorneys’ fees and costs of the Date and
HEARING” lawyers who brought the Action, and the Named Plaintiffs’ Time:
request for a service award for bringing the Action. March 27,
You may, but are not required to, speak at the Fairness Hearing 2026, at
about any objection you filed to the Settlement. If you intend to 1:30 P.M.
speak at the Fairness Hearing, you must also submit a “Notice Pacific
of Intention to Appear” indicating your intent to do so. Time
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YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
DO If you do not have a California or Oregon mailing address on N/A
NOTHING file with Michael Kors, and you made one or more Qualifying
Purchase(s) during the Class Period: if you do nothing, you will
not receive a Merchandise Certificate but will be bound by the
Settlement and you will not be able to be part of any other
lawsuit about the legal claims in this Action.
• These rights and options—and the deadlines to exercise them—are explained in more detail
below.
• The Court in charge of this Action has preliminarily approved the Settlement and must decide
whether to give final approval to the Settlement. The relief provided to Settlement Class
Members will be provided only if the Court gives final approval to the Settlement and, if there
are any appeals, after the appeals are resolved in favor of the Settlement. Please be patient.
WHAT THIS NOTICE CONTAINS
BACKGROUND INFORMATION ...........................................................................................................04
1. Why did I get this notice?
2. What is this lawsuit about?
3. Why is this a class action?
4. Why is there a Settlement?
5. How do I know if I am part of the Settlement?
6. I’m still not sure if I am included.
THE PROPOSED SETTLEMENT ............................................................................................................06
7. What relief does the Settlement provide to the Settlement Class Members?
HOW TO RECEIVE A MERCHANDISE CERTIFICATE – SUBMITTING A
CLAIM FORM 06
8. How can I get a Merchandise Certificate?
9 When will I get my Merchandise Certificate?
THE LAWYERS IN THIS CASE AND THE NAMED PLAINTIFFS .......................................07
10. Do I have a lawyer in this case?
11. How will the lawyers be paid?
12. Will the Named Plaintiffs receive any compensation for their efforts in bringing
this Action?
DISMISSAL OF ACTION AND RELEASE OF ALL CLAIMS ...................................................07
13. What am I giving up to obtain relief under the Settlement?
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HOW TO EXCLUDE YOURSELF FROM THE SETTLEMENT ..............................................08
14. How do I exclude myself from the Settlement?
HOW TO OBJECT TO THE SETTLEMENT .....................................................................................09
15. How do I tell the Court that I disagree with the Settlement?
16. What is the difference between excluding myself and objecting to the
Settlement?
FAIRNESS HEARING ...................................................................................................................................09
17. What is the Fairness Hearing?
18. When and where is the Fairness Hearing?
19. May I speak at the hearing?
ADDITIONAL INFORMATION ...............................................................................................................10
20. How do I get more information?
21. What if my address or other information has changed or changes after I submit
a Claim Form?
I. BACKGROUND INFORMATION
1. Why did I get this Notice?
You received this Notice because a Settlement has been reached in this Action. You might
be a member of the Settlement Class and may be eligible for the relief detailed below.
This Notice explains the nature of the Action, the general terms of the proposed Settlement,
and your legal rights and obligations. To obtain more information about the Settlement,
including information about how you can see a copy of the Settlement Agreement (which
defines certain capitalized terms used in this Notice), see Section 20 below.
2. What is this lawsuit about?
Plaintiffs JoEllen Barraclough, Jennifer McCall, and Angela Waldner (the “Named
Plaintiffs”) filed a lawsuit (the “Action”) against Michael Kors (USA), Inc. (“Michael
Kors”), on behalf of themselves and all others similarly situated. The Action alleges that
Michael Kors engaged in misleading advertising by advertising purportedly improper
discounts on merchandise sold in its Michael Kors Outlet stores.
Michael Kors denies any and all allegations of wrongdoing or unlawful conduct and any
resulting liability whatsoever, and no court or other entity has made any judgment or other
determination of any liability. Michael Kors further denies that any Settlement Class
Member is entitled to any relief and, other than for Settlement purposes, that this Action
is appropriate for certification as a class action.
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The issuance of this Notice is not an expression of the Court’s opinion on the merits or
the lack of merits of the Named Plaintiffs’ claims in the Action.
For information about how to learn about what has happened in the Action to date, please see
Section 20 below.
3. Why is this a class action?
In a class action lawsuit, one or more people called “Named Plaintiff(s)” (in this Action,
JoEllen Barraclough, Jennifer McCall, and Angela Waldner) sue on behalf of other
people who allegedly have similar claims. For purposes of this proposed Settlement, one
court will resolve the issues for all Settlement Class Members. The company sued in this
Action, Michael Kors (USA), Inc., is called the Defendant.
4. Why is there a Settlement?
The Named Plaintiffs have made claims against Michael Kors. Michael Kors denies that
it has done anything wrong or illegal and admits no liability. The Court has not decided
that the Named Plaintiffs or Michael Kors should win this Action. Instead, both sides
agreed to the Settlement. That way, they avoid the cost and uncertainty of a trial, and the
Settlement Class Members will receive relief now rather than years from now, if at all.
5. How do I know if I am part of the Settlement?
The Court has decided that everyone who fits this description is a Settlement Class
Member for purposes of the proposed Settlement: All individuals in the United States
who made a Qualifying Purchase, within the Class Period (May 10, 2019, to November
14, 2025) at a Michael Kors Outlet store. Excluded from the Settlement Class are Michael
Kors’ Counsel, Michael Kors’ officers, directors, and employees, as well as the judge
presiding over the Action.
If you are a KORSVIP account holder with a California or Oregon mailing address on
file with Michael Kors and have made a Qualifying Purchase at a California or Oregon
Michael Kors Outlet store during the Class Period, you are a “California or Oregon
KORSVIP Authorized Claimant” per the terms of the Settlement Agreement.
If you otherwise made a Qualifying Purchase during the Class Period but are not a
KORSVIP member with a California or Oregon mailing address on file with Michael
Kors who made a Qualifying Purchase from a California or Oregon Michael Kors Outlet
store during the Class Period, you are a “Nationwide Authorized Claimant” per the terms
of the Settlement Agreement.
6. I’m still not sure if I am included.
If you are still unsure whether you are included, you can contact the Claims
Administrator for free assistance. The email address of the Claims Administrator is
[email protected], and the U.S. postal (mailing) address
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is McCall et al., v. Michael Kors (USA), Inc., Case No. 25CU041352N, c/o Simpluris,
P.O. Box 25226, Santa Ana, CA 92799.
II. THE PROPOSED SETTLEMENT
7. What relief does the Settlement provide to the Settlement Class Members?
Michael Kors has agreed to directly provide each California or Oregon KORSVIP
Authorized Claimant who made a Qualifying Purchase at a Michael Kors Outlet store in
California or Oregon one (1) Merchandise Certificate, which may be applied for up to
$30.00 toward any purchase at Michael Kors outlet stores. These Settlement Class
Members are referred to in the Settlement Agreement as “California or Oregon KORSVIP
Authorized Claimants.” Michael Kors has further agreed to provide to each Settlement
Class Member who is not a California or Oregon KORSVIP Authorized Claimant and
who submits a valid Claim Form by the Response Deadline one (1) Merchandise
Certificate, which may be applied for up to $30.00 toward any purchase at Michael Kors
Outlet stores.
Merchandise Certificates will be applied to the purchase prices offered by Michael Kors
to the general public, and they may be used with any other discount offered to the general
public. Merchandise Certificates are non-transferable, cannot be combined with other
Merchandise Certificates, expire ninety days after issuance, and have no residual value if
the amount redeemed is less than the Merchandise Certificate amount. The Merchandise
Certificates have no cash value, are not usable for cash, and may not be used to purchase
gift cards or gift certificates. Merchandise Certificates will not be replaced if lost or
stolen. Each Settlement Class Member shall not use more than one Merchandise
Certificate.
III. HOW TO RECEIVE A MERCHANDISE CERTIFICATE –
SUBMITTING A CLAIM FORM
8. How can I get a Merchandise Certificate?
If you are a California or Oregon KORSVIP Authorized Claimant and do nothing, and do
not object or exclude yourself from the Settlement, you will receive a Merchandise
Certificate for $30.00 at the email address Michael Kors maintains for you.
If you are not a California or Oregon KORSVIP Authorized Claimant, but you made a
qualifying purchase and wish to receive a Merchandise Certificate for up to $30.00, you
must complete a Claim Form.
A Claim Form is available by clicking HERE or on the Internet at the website
www.MichaelKorsOutletSettlement2026.com. The Claim Form may be submitted
electronically or by postal mail. Read the instructions carefully, fill out the Claim Form,
and postmark it by March 06, 2026, or submit it online on or before 11:59 p.m. (Pacific)
on March 06, 2026.
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9. When will I get my Merchandise Certificate?
As described in Sections 17 and 18 below, the Court will hold a hearing on March 27,
2026, at 1:30 P.M. Pacific Time, to decide whether to approve the Settlement. If the Court
approves the Settlement, Merchandise Certificates will be sent no earlier than April 1,
2026. There may also be appeals, and resolving them can take time, perhaps more than a
year. You can check on the progress of the case on the website dedicated to the Settlement
at www.MichaelKorsOutletSettlement2026.com. Please be patient.
IV. THE LAWYERS IN THIS CASE AND THE NAMED PLAINTIFF
10. Do I have a lawyer in this case?
The Court has ordered that the law firm of Lynch Carpenter, LLP (“Class Counsel”) will
represent the interests of all Settlement Class Members. You will not be separately
charged for these lawyers’ services. If you want to be represented by your own lawyer,
you may hire one at your own expense.
11. How will the lawyers be paid?
Michael Kors has agreed to pay Class Counsel’s attorneys’ fees, costs, and Class
administration costs up to $1,985,000, subject to approval by the Court. You will not be
required to pay any attorneys’ fees or costs. Please see section 2.4 of the Settlement
Agreement, available HERE, for additional details.
12. Will the Named Plaintiffs receive any compensation for their efforts in bringing
this Action?
The three Named Plaintiffs will each request a service award of up to $5,000 ($15,000
total) for their service as Class representatives and for their participation in discovery and
in bringing the Action. The Court will make the final decision as to the amount to be paid
to the Named Plaintiffs.
V. DISMISSAL OF ACTION AND RELEASE OF ALL CLAIMS
13. What am I giving up to obtain relief under the Settlement?
If the Court approves the proposed Settlement, unless you exclude yourself from the
Settlement Class, you will be releasing your claims against Michael Kors. This generally
means that you will not be able to file a lawsuit, continue prosecuting a lawsuit, or be part
of any other lawsuit against Michael Kors regarding the claims in the Action. The
Settlement Agreement, available on the Internet at the website
www.MichaelKorsOutletSettlement2026.com contains the full terms of the release.
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14. How do I exclude myself from the Settlement?
You may exclude yourself from the Settlement Class and the Settlement. If you want to be
excluded, you must send a signed letter or postcard stating: (a) the name and case number
of the Action; (b) your full name, address, telephone number, and email address; and (c) a
statement that you do not wish to participate in the Settlement, postmarked no later than
March 06, 2026 to the Claims Administrator at:
McCall et al., v. Michael Kors (USA), Inc., Case No. 25CU041352N
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799
If you timely request exclusion from the Settlement Class, you will be excluded from the
Settlement Class, you will not receive a Merchandise Certificate under the Settlement,
you will not be bound by the Judgment entered in the Action, and you will not be
precluded from prosecuting any timely, individual claim against Michael Kors based on
the conduct complained of in the Action.
15. How do I tell the Court that I disagree with the Settlement?
At the date, time, and location stated in Section 18 below, the Court will hold a Fairness
Hearing to determine if the Settlement is fair, reasonable, and adequate, and to consider Class
Counsel’s request for an award of attorneys’ fees and costs, and the Individual Settlement
Award to the Named Plaintiffs.
If you wish to object to the fairness, reasonableness, or adequacy of the Settlement Agreement
or the proposed Settlement, you must file a written objection with the Court and deliver copies
of the written objection to the Claims Administrator, Class Counsel, and Michael Kors’
Counsel at the address set forth below no later than (i.e., postmarked by) March 06, 2026.
McCall et al., v. Michael Kors (USA), Inc., Case No. 25CU041352N
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799
Any written objections must contain: (a) the name and case number of the Action; (b) the
Settlement Class Member’s full name, address, telephone number, email address, and the
contact information for any attorney retained by the objector in connection with the objection
or otherwise in connection with the Actions; (c) the words “Notice of Objection” or “Formal
Objection”; (d) in clear and concise terms, the legal and factual arguments supporting the
objection; (e) facts supporting the person’s status as a Settlement Class Member (e.g., the date
and location of his/her Qualifying Purchases and description of the item(s) purchased); (f) the
Settlement Class Member’s wet signature and the date; and (g) the following language
immediately above the Settlement Class Member’s signature and date: “I declare under penalty
of perjury under the laws of the State of California that the foregoing statements regarding class
membership are true and correct to the best of my knowledge.” You may, but need not, submit
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your objection through counsel of your choice. If you do make your objection through an
attorney, you will be responsible for your personal attorneys’ fees and costs.
IF YOU DO NOT TIMELY MAKE YOUR OBJECTION, YOU WILL BE
DEEMED TO HAVE WAIVED ALL OBJECTIONS AND WILL NOT BE
ENTITLED TO SPEAK AT THE FAIRNESS HEARING.
If you submit a written objection, you may appear at the Fairness Hearing, either in person
or through personal counsel hired at your expense, to object to the fairness, reasonableness,
or adequacy of the Settlement Agreement or the proposed Settlement, or to the award of
attorneys’ fees. You are not required, however, to appear. If you, or your attorney, intend
to make an appearance at the Fairness Hearing, you must include in your timely and valid
objection a statement substantially similar to “Notice of Intention to Appear.”
If you intend to appear at the Fairness Hearing through counsel, you must also identify the
attorney(s) representing you who will appear at the Fairness Hearing and include the
attorney(s) name, address, phone number, email address, and the state bar(s) to which your
counsel is admitted. Also, if you intend to request the Court to allow you to call witnesses at
the Fairness Hearing, such request must be made in your written objection, which must also
contain a list of any such witnesses and a summary of each witness’s expected testimony.
16. What is the difference between excluding myself and objecting to the Settlement?
Objecting is simply telling the Court that you disagree with something about the
Settlement. You can object only if you do not exclude yourself from the Settlement.
Excluding yourself is telling the Court that you don’t want to be part of the Settlement.
If you exclude yourself, you have no basis to object because the Settlement no longer
affects you.
VI. FAIRNESS HEARING
17. What is the Fairness Hearing?
The Court has preliminarily approved the Settlement and will hold a hearing to decide
whether to give final approval to the Settlement. The purpose of the Fairness Hearing will
be for the Court to determine whether the Settlement should be approved as fair,
reasonable, adequate, and in the best interests of the Settlement Class; to consider the
award of attorneys’ fees and expenses to Class Counsel; and to consider the request for a
service award to the Representative Plaintiffs. You may attend, but you do not have to.
18. When and where is the Fairness Hearing?
On March 27, 2026, at 1:30 P.M. Pacific Time, a hearing will be held on the fairness of
the proposed Settlement. At the hearing, the Court will be available to hear any objections
and arguments concerning the proposed Settlement’s fairness. The hearing will take place
before the Hon. William Y. Wood in Courtroom N-29 of the Superior Court of California,
County of San Diego, located at 325 S. Melrose Dr, Vista, CA 92081. The hearing may
be postponed to a different date, time, or location without notice. Please check
www.MichaelKorsOutletSettlement2026.com for any updates about the Settlement
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generally, or the Fairness Hearing specifically. If the date or time of the Fairness Hearing
changes, an update to the Settlement Website will be the only way you will be informed
of the change.
19. May I speak at the hearing?
At that hearing, the Court will be available to hear any objections and arguments
concerning the fairness of the Settlement. As described above in Section 15, you may
speak at the Fairness Hearing only if (a) you have timely submitted an objection, and
(b) you have timely and validly provided a Notice of Intent to Appear.
If you have requested exclusion from the Settlement, you may not speak at the hearing.
VII. ADDITIONAL INFORMATION
20. How do I get more information?
To see a copy of the Settlement Agreement, the Court’s Preliminary Approval Order,
Class Counsel’s application for attorneys’ fees and costs, and the operative Complaint
filed in the Action, please visit the Settlement Website located at:
www.MichaelKorsOutletSettlement2026.com. Alternatively, you may contact the
Claims Administrator at the email address:
[email protected] or the U.S. postal (mailing) address:
McCall et al., v. Michael Kors (USA), Inc., Case No. 25CU041352N, c/o Simpluris,
P.O. Box 25226, Santa Ana, CA 92799.
This description of this Action is general and does not cover all of the issues and
proceedings that have occurred. In order to see the complete file, you should visit
https://roa.sdcourt.ca.gov/roa/ or the Clerk’s office at 325 South Melrose Dr., Vista,
CA 92081. The Clerk will tell you how to obtain the file for inspection and copying at
your own expense.
21. What if my address or other information has changed or changes after I submit
a Claim Form?
It is your responsibility to inform the Claims Administrator of your updated information.
You may do so at the address below:
McCall et al., v. Michael Kors (USA), Inc., Case No. 25CU041352N
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799
****
DO NOT ADDRESS ANY QUESTIONS ABOUT THE SETTLEMENT OR THE
LITIGATION TO THE CLERK OF THE COURT OR THE JUDGE.
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Dated: January 5, 2026 By: Order of the Superior Court of California
HONORABLE WILLIAM Y. WOOD
SUPERIOR COURT JUDGE
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