NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
Maricopa County Superior Court
Feathers et al. v. On Q Financial, LLC, No. CV2025-037770
Were you notified that your Private Information may have been potentially
compromised by a Data Security Incident at On Q Financial? You may be
eligible for benefits from a class action settlement.
A Court authorized this Notice. You are not being sued. This is not a solicitation from a lawyer.
• A settlement has been reached with On Q Financial, LLC (“On Q” or “Defendant”) in a class action about a data
breach on or around February 20, 2024, that allowed unauthorized access to certain files containing clients’ Private
Information (the “Data Security Incident”). This Private Information included names and Social Security numbers.
The Defendant denies all of the Plaintiffs’ claims and maintains that it did not do anything wrong.
• You are included in this Settlement as a Class Member if your Private Information may have been compromised in
the Data Security Incident on or around February 20, 2024.
• Under the proposed Settlement, the Defendant will pay $1,250,000 into a Settlement Fund to resolve the case. The
Settlement Fund will provide Settlement Payments and Expanded Identity Theft and Fraud Monitoring Services for
Class Members, as well as Administrative Expenses, the attorneys’ Fee Award and Costs, expenses of counsel, and
Service Awards.
• Your rights are affected whether you do or do not act. Please read this Notice carefully.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT DEADLINE
SUBMIT A CLAIM The only way to receive Settlement Benefits is to submit a valid and
FORM timely Claim Form. October 28, 2026
OPT OUT OF THE If you opt out, you will not be bound by the terms of the Settlement
SETTLEMENT and you keep the right to sue the Defendant about the claims
resolved by this Settlement. You will not receive any Settlement September 28, 2026
Benefits.
OBJECT TO THE If you do not opt out of the Settlement, you may object to it and tell
SETTLEMENT the Court what you do not like about it. You may also ask the Court
AND/OR ATTEND A for permission to speak about your objection at the Final Approval September 28, 2026
HEARING Hearing. If you object, you can still submit a Claim Form for
Settlement Benefits.
DO NOTHING If you do nothing, you will not receive any Settlement Benefits and
you give up the right to sue the Defendant about the claims resolved No Deadline
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 must decide whether to approve the Settlement.
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WHAT THIS NOTICE CONTAINS
Basic Information
1. Why was this Notice issued?............................................................................................................................ 3
2. What is this Action about?................................................................................................................................ 3
3. What is a class action?...................................................................................................................................... 3
4. Why is there a Settlement?............................................................................................................................... 3
Who is in the Settlement?
5. Who is included in the Settlement?.................................................................................................................. 3
6. Are there exceptions to being included? ......................................................................................................... 4
The Settlement Benefits
7. What can I get from this Settlement?................................................................................................................ 4
8. Tell me more about the Documented Loss Payment........................................................................................ 4
9. Tell me more about the Alternative Cash Payment …………......................................................................... 4
10. Tell me more about the Expanded Identity Theft and Fraud Monitoring Services………….………………. 4
11. What claims am I releasing if I stay in the Settlement Class?.......................................................................... 5
How to get Settlement Benefits – Making a Claim
12. How do I submit a Claim Form to get Settlement Benefits?........................................................................... 5
13. When will I get my Settlement Benefits?........................................................................................................ 5
The Lawyers Representing You
14. Do I have a lawyer in this case?....................................................................................................................... 5
15. Should I get my own lawyer?........................................................................................................................... 5
16. How will the lawyers be paid?......................................................................................................................... 5
Excluding Yourself from the Settlement
17. How do I opt out of the Settlement?................................................................................................................. 6
Objecting to the Settlement
18. How do I tell the Court if I do not like the Settlement?................................................................................... 6
19. What is the difference between objecting and opting out?............................................................................... 7
The Court’s Final Approval Hearing
20. When is the Court’s Final Approval Hearing?................................................................................................. 7
21. Do I have to come to the Final Approval Hearing?.......................................................................................... 7
If You Do Nothing
22. What happens if I do nothing at all?................................................................................................................. 8
Getting More Information
23. How do I get more information?....................................................................................................................... 8
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BASIC INFORMATION
1. Why was this Notice issued?
A Court authorized this Notice because you have a right to know about the proposed Settlement of this class action
and about all of your options before the Court decides whether to grant Final Approval of the Settlement. This
Notice explains the Action, your legal rights, what benefits are available, and who can receive them.
The Action is called Feathers et al. v. On Q Financial, LLC, No. CV2025-037770 pending in the Maricopa County
Superior Court. The people who filed this Action are called the “Plaintiffs” and the company they sued, On Q
Financial, LLC (“On Q”), is called the “Defendant.”
2. What is this Action about?
On or around February 20, 2024, the Defendant received notification that a vulnerability was present in the product
of a software and IT management provider and later discovered that a threat actor exploited that vulnerability and
potentially accessed files that included clients’ Private Information (the “Data Security Incident”). This Private
information consisted of clients’ names and Social Security numbers. On or around March 29, 2024, the Defendant
began notifying potentially impacted individuals about the Data Security Incident. The Plaintiffs’ allege injuries
arising from the Data Security Incident. The Defendant denies all of the Plaintiffs’ claims and maintains that it
did not do anything wrong.
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 who
sue are known as “Class Representatives” or Plaintiffs. Together, the people included in the class action are called
a “Settlement Class” or “Class Members.” One court resolves the lawsuit for all Class Members, except for those
who exclude themselves (sometimes called, “opting out”) from a settlement. In this Action, the Class
Representatives are Jack Feathers, Barbara Squier, Brian Eitemiller, and Isaiah Castellaw.
4. Why is there a Settlement?
The Court did not decide in favor of the Plaintiffs or the Defendant. The Defendant denies all claims and contends
that it has not violated any laws. The Plaintiffs and the Defendant agreed to a Settlement to avoid the costs and
risks of a trial, and, through the Settlement, Class Members are eligible to claim benefits. The Plaintiffs and their
attorneys, who also represent Class Members as “Class Counsel,” think the Settlement is best for all Class
Members.
WHO IS IN THE SETTLEMENT?
5. Who is included in the Settlement?
The Settlement Class consists of individuals whose Private Information may have been compromised in the Data
Security Incident on or around February 20, 2024.
6. Are there exceptions to being included?
Yes. Excluded from the Settlement Class are: (1) the Judge(s) presiding over the State Court Lawsuit and members
of their immediate families and their staff; (2) the Defendant and its subsidiaries, parent companies, successors,
predecessors, and any Entity in which the Defendant, has a controlling interest; (3) natural persons who properly
execute and submit a Request for Exclusion by September 28, 2026; and (4) the successors or assigns of any such
excluded natural person.
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THE SETTLEMENT BENEFITS
7. What can I get from this Settlement?
Under the proposed Settlement, the Defendant will pay $1,250,000 into a Settlement Fund to resolve the lawsuit.
The Settlement Fund will provide Settlement Payments and Expanded Identity Theft and Fraud Monitoring
(EITFM) Services for Class Members, as well as Administrative Expenses, the attorneys’ Fee Award and Costs,
expenses of counsel, and Service Awards.
Class Members may choose to receive one or both of the following Settlement Payments:
(1) Documented Loss Payment: Reimbursement of up to $5,000 for documented out-of-pocket losses fairly
attributable from the Data Security Incident and time spent dealing with it; or
(2) Alternative Cash Payment: An alternate cash payment estimated at $50. This payment amount will be
determined by the amount of valid claims and may be adjusted on a pro rata (proportional) basis.
In addition to the Documented Loss Payment and Alternative Cash Payment, you may also make a claim for one
(1) year of Expanded Identity Theft and Fraud Monitoring (EITFM) Services.
8. Tell me more about the Documented Loss Payment.
Class Members may submit a claim for up to $5,000 for actual out-of-pocket unreimbursed losses and
consequential expenses that are more likely than not a result of the Data Security Incident (and time spent dealing
with it) and were incurred on or after February 20, 2024. Reasonable Documentation must be provided. Losses
include, but are not limited to:
• Long-distance telephone charges.
• Cell phone minutes (if charged by the minute).
• Internet usage charges (if either charged by the minute or incurred solely as a result of the Data Security
Incident).
• Costs of credit reports purchased between February 20, 2024, and October 28, 2026.
• Documented costs paid for credit monitoring services and/or fraud resolution services purchased between
February 20, 2024, and October 28, 2026, with a sworn statement that the monitoring or service was
purchased primarily because of the Data Security Incident and not for other purposes.
• Documented expenses directly associated with dealing with identity theft or identity fraud related to the
Data Security Incident.
• Other Documented Losses incurred by Class Members that are fairly traceable to the Data Security
Incident as determined by the Settlement Administrator.
“Reasonable Documentation” means documentation supporting a claim for Documented Loss including, but not
limited to, credit card statements, bank statements, invoices, telephone records, and receipts. If you do not provide
sufficient documentation and fail to cure your claim for Documented Loss, it will be deemed to be a claim for an
Alternative Cash Payment.
9. Tell me more about the Alternative Cash Payment.
In addition to the Documented Loss Payment, Class Members may submit a claim to receive an alternative cash
payment estimated to be $50. This payment amount may be adjusted on a pro rata (proportional) basis depending
on the amount of money left in the Settlement Fund after all Administrative Costs, Attorneys’ Fees and Costs,
Service Awards, and the costs of Approved Claims for EITFM Services and Documented Loss Payments are
deducted. No documentation is required for an Alternative Cash Payment.
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10. Tell me more about the Expanded Identity Theft and Fraud Monitoring Services.
In addition to the Settlement Payments, all Class Members may also claim a code to enroll in an identity theft and
fraud monitoring program with single bureau credit monitoring, lasting one (1) year, and offering up to $1,000,000
in insurance for any losses due to fraud or identity theft during that time as well as access to a dedicated
fraud/identity theft rehabilitation specialist.
Class Members who accepted the Defendant’s original offer of identity theft and fraud monitoring can receive an
additional one (1) year if they claim this benefit. The cost of the Expanded Identity Theft and Fraud Monitoring
(but not the Defendant’s original offer of monitoring) will be paid from the Settlement Fund. No documentation
is required to select this benefit.
11. 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
Defendant or Released Parties about any of the legal claims this Settlement resolves. The Release section in the
Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The
Settlement Agreement can be found at www.OnQSettlement.com
HOW TO GET SETTLEMENT BENEFITS – MAKING A CLAIM
12. How do I submit a Claim Form to get Settlement Benefits?
To receive Settlement Benefits, you must submit a Claim Form, with any necessary documentation, online by
October 28, 2026, at 11:59 p.m. ET at www.OnQSettlement.com, or by mail, postmarked by October 28, 2026,
to:
Feathers et al. v. On Q Financial, LLC
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
Claim Forms are available on the Settlement Website or by calling (833) 930-0180.
13. When will I get my Settlement Benefits?
The short answer is – after the Settlement is “finally approved” and any challenges to that approval are finally
resolved. The Court is scheduled to hold a Final Approval Hearing on November 16, 2026, at 10:00 a.m. MT,
to decide whether to approve the Settlement, the Fee Award and Costs for Class Counsel for representing the
Settlement Class, and Service Awards to the four Class Representatives who brought this Action on behalf of the
Settlement Class.
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 as soon as possible, if and
when the Court grants Final Approval of the Settlement and after any appeals are resolved.
THE LAWYERS REPRESENTING YOU
14. Do I have a lawyer in this case?
Yes, the Court appointed John J. Nelson of Milberg, PLLC, Daniel Srourian of Srourian Law Firm, P.C., and
Marc Edelson of Edelson Lechtzin LLP as Class Counsel. You will not be charged directly for these lawyers;
instead, they will be paid out of the Settlement Fund (subject to Court approval). If you want to be represented by
your own lawyer, you may hire one at your own expense.
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15. Should I get my own lawyer?
It is not necessary for you to hire your own lawyer because Class Counsel works for you. If you want to be
represented by your own lawyer, you may hire one at your own expense.
16. How will the lawyers be paid?
Class Counsel will ask the Court to approve attorneys’ fees of up to thirty-five (35) percent ($437,500) and
reasonable litigation expenses and costs of up to $30,000 as well as a $2,500 Service Award payment to each of
the four Class Representatives. If approved, these amounts will be paid from the Settlement Fund before making
payments to Class Members who submit Approved Claims.
EXCLUDE YOURSELF FROM THE SETTLEMENT
17. How do I opt out of the Settlement?
If you do not want to receive any benefits from the Settlement, and you want to keep your right to separately sue
the Defendant about the legal issues in this case, you must take steps to exclude yourself from the Settlement
Class. This is called “opting out” of the Settlement Class. The deadline to opt out of the Settlement by submitting
a “Request for Exclusion” is September 28, 2026.
To exclude yourself from the Settlement, you must submit a written Request for Exclusion that includes:
• Your name, address, telephone number, and Class Member ID number;
• The name of the lawyer representing you (if any);
• A statement indicating that you want to be excluded from the Settlement Class, such as, “I hereby
request to be excluded from the proposed Settlement Class in Jack Feathers et al. v. On Q
Financial, LLC, No. CV2025-037770”; and
• Your physical signature.
All Requests for Exclusion must be submitted mailed at www.OnQSettlement.com or mailed to the Settlement
Administrator at the address below, postmarked on or before, September 28, 2026.
Feathers et al. v. On Q Financial, LLC
c/o Kroll Settlement Administration LLC
ATTN: Request for Exclusion
P.O. Box 225391
New York, NY 10150-5391
Requests for Exclusion may only be done on an individual basis, and no person may request to be excluded from
the Settlement Class through “mass” or “class” opt outs.
OBJECT TO THE SETTLEMENT
18. How do I tell the Court if I do not like the Settlement?
If you are a Class Member, you can choose (but are not required) to object to the Settlement if you do not like it
or a portion of it, whether that be to the Settlement Benefits, the request for attorneys’ fees and costs, the Service
Award payments, the Release provided to the Defendant, or some other aspect of the Settlement. Through an
objection, you give reasons why you think the Court should not approve the Settlement. Objections must be
submitted in writing and must include:
• Your full name, current mailing address, and telephone number;
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• Proof that you are a member of the Settlement Class (e.g., copy of the Settlement Notice, copy of the
original notice of the Data Security Incident);
• All factual and legal grounds for the objection, accompanied by any legal support for the objection
known to you or your counsel;
• The identity of all counsel representing you (if any);
• A list, including case name, court, and docket number, of all other cases in which you and/or your
counsel have filed an objection to any proposed class action settlement in the past five (5) years;
• A list of all persons who will be called to testify at the Final Approval Hearing in support of your
objection (if any);
• A statement whether you or your counsel will appear at the Final Approval hearing; and
• Your signature (an attorney’s signature is not sufficient).
All objections must be mailed to the Settlement Administrator at the address below, postmarked on or before,
September 28, 2026.
Feathers et al. v. On Q Financial, LLC
c/o Kroll Settlement Administration LLC
ATTN: Objections
P.O. Box 225391
New York, NY 10150-5391
19. What is the difference between objecting and opting out?
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 it. Excluding yourself from the Settlement means telling the Court you
do not want to be part of the Settlement. If you exclude yourself or opt out of the Settlement, you cannot object to
it because the Settlement no longer affects you.
THE COURT’S FINAL APPROVAL HEARING
20. When is the Court’s Final Approval Hearing?
The Court is scheduled to hold a Final Approval Hearing on November 16, 2026, at 10:00 a.m. MT, at the
Superior Court of Arizona Maricopa County, Central Court Building, 201 W. Jefferson Street, Phoenix, Arizona
85003, to decide whether to approve the Settlement, Class Counsel’s motion for Attorneys’ Fees and Costs, and
the Service Awards to the four Class Representatives who brought this Action on behalf of the Settlement Class.
The date and time of this hearing may change without further notice. Please check www.OnQSettlement.com for
updates.
21. 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
file an objection, you may, but you do not have to come to the Final Approval Hearing to talk about it. If you file
your written objection on time and in accordance with the requirements above, the Court will consider it. You
may also pay your own lawyer to attend, but it is not necessary.
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IF YOU DO NOTHING
22. What happens if I do nothing at all?
If you are a Class Member and you do nothing, you will give up your right to start a lawsuit, continue a lawsuit,
or be part of any other lawsuit against the Defendant and the Released Parties, as defined in the Settlement
Agreement, about the legal issues resolved by this Settlement. In addition, you will be bound by the Release in
the Settlement Agreement and will not be eligible to receive any Settlement Benefits.
GETTING MORE INFORMATION
23. 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.OnQSettlement.com.
If you have additional questions or need to update your address, you may contact the Settlement Administrator
toll free at (833) 930-0180 or by mail at Jack Feathers et al. v. On Q Financial, LLC, c/o Kroll Settlement
Administration LLC, P.O. Box 225391, New York, NY 10150-5391.
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