Superior Court for the State of California
County of Los Angeles
Winzig v. Stockpile, Inc. and Stockpile Investments, Inc.
Case No. 21STCV45067
This is an important notice about a class action lawsuit.
Class Action Notice
Authorized by the Superior Court of the State of California
If your personal There is a $600,000 To receive a
information was settlement of a lawsuit. Settlement
compromised in the payment, submit a
You may be entitled to
2020 Data Breach Claim Form by
money.
perpetrated against October 6, 2026.
Stockpile Inc. and Visit
To Opt Out of, or
Stockpile StockpileDataSettlement.com
Object to the
Investments, Inc. to learn more.
Settlement, you
must take action by
October 6, 2026.
Important things to know:
• If you are a Settlement Class Member and you take no action, any ruling from
the Court will apply to you, and you will not be able to sue the Defendants for
the same issues.
• The Court will hold a hearing on November 10, 2026 at 10:00 a.m. to decide
whether to approve the Settlement.
• This notice is only a summary. You can learn more by scanning the QR code,
visiting www.StockpileDataSettlement.com or calling toll-free 1-844-747-4126.
{289649.1}
Table of Contents
Table of Contents ....................................................................................................... 2
About This Notice ...................................................................................................... 3
Why did I get this notice? ................................................................................................. 3
What do I do next? ............................................................................................................ 3
What are the most important dates? ............................................................................. 3
Learning About the Lawsuit ..................................................................................... 4
What is this lawsuit about? .............................................................................................. 4
Why is there a settlement in this lawsuit? ..................................................................... 4
What happens next? ......................................................................................................... 4
Learning About the Settlement ............................................................................... 5
What does the settlement provide? ............................................................................... 5
How do I know if I am part of this settlement? ............................................................. 5
Tell me more about the Settlement Benefits ................................................................ 6
Deciding What to Do .................................................................................................. 6
How do I weigh my options? ........................................................................................... 7
What is the best path for me? ......................................................................................... 8
Submitting a Claim .................................................................................................... 8
How do I get a Settlement payment if I am a class member? ..................................... 9
Do I have a lawyer in this lawsuit? .................................................................................. 9
Do I have to pay the lawyers in this lawsuit? ................................................................. 9
Opting Out ................................................................................................................ 10
What if I don't want to be part of this settlement? .....................................................10
How do I opt out? ............................................................................................................10
Objecting ................................................................................................................... 10
What if I disagree with the Settlement? .......................................................................10
Doing Nothing .......................................................................................................... 11
What are the consequences of doing nothing? ..........................................................11
Key Resources .......................................................................................................... 12
How do I get more information? ...................................................................................12
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About This Notice
Why did I get this notice?
This notice is to tell you about a proposed settlement that has been reached in a
lawsuit entitled Winzig v. Stockpile, Inc. and Stockpile Investments, Inc., Case
No. 21STCV45067, pending in the Superior Court of the State of California,
County of Los Angeles. This notice gives you a summary of the terms of the
proposed settlement agreement, explains what rights class members have, and
helps class members make informed decisions about what action to take.
What do I do next?
Read this notice to understand the settlement and to determine if you are a
class member. Then, decide if you want to:
Options More information about each option
Submit a Claim You must submit a claim to receive a Settlement
Form payment. You will be bound by the Settlement.
Do Nothing Get no payment. Give up rights resolved by Settlement.
Opt Out Get no payment. This allows you to bring another lawsuit
against the Defendants about the same legal issues
resolved by this Settlement.
Object Tell the Court why you don’t like the settlement.
Read on to understand the specific options under the Settlement and what
each choice would mean for you.
What are the most important dates?
Your deadline to object or opt out: October 6, 2026
Your deadline to submit a claim form: October 6, 2026
Settlement Final Approval Hearing: November 10, 2026 at 10:00 a.m.
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Learning About the Lawsuit
What is this lawsuit about?
(1) The lawsuit alleges that Stockpile, Inc. and
Stockpile Investments, Inc.’s (“Stockpile” or
Where can I learn
“Defendants”) inadequate cybersecurity
resulted in a 2020 data breach that exposed more?
You can get a complete copy
and compromised the sensitive personal
of the Settlement Agreement
information of the Plaintiff and members of
and other key documents in
the Class. The Defendants deny all claims this lawsuit at:
alleged against them and deny all charges of StockpileDataSettlement.com
wrongdoing or liability. The settlement is not
an admission of wrongdoing or an indication
that the Defendants have violated any laws, but rather the resolution
of disputed claims.
Why is there a settlement in this lawsuit?
The Court did not decide in favor of the Plaintiff
or the Defendants. Instead, a settlement was What is a class action
negotiated that allows the Plaintiff, the settlement?
members of the Class, and the Defendants to A class action settlement is
avoid the risks and costs of lengthy and an agreement between
uncertain litigation and the uncertainty of a trial the parties to resolve and
and appeals. The Settlement provides benefits end the case. Settlements
and allows Class Members to obtain a payment can provide money or
without further delay. Plaintiff and Class Counsel other negotiated benefits
think the Settlement is in the best interest of all to class members.
Class Members.
This Settlement does not mean that the Defendants did anything wrong.
What happens next?
The Court will hold a Final Approval Hearing to decide whether to approve the
settlement. The hearing will be held at:
Where: Los Angeles Superior Court, Spring Street Courthouse,
Department 7 at 312 North Spring Street, Los Angeles, CA 90012
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When: 10:00 a.m. on November 10, 2026.
At the hearing, the Court will consider whether the proposed Settlement is fair,
reasonable, and adequate. The Court may also consider Class Counsel’s request
for an award of attorneys’ fees and reimbursement of litigation expenses and the
request for a Service Payment for the Plaintiff.
The Court will take into consideration any timely submitted written objections and
may also listen to anyone who has requested to speak at the hearing (see
Objecting section below).
You don’t have to attend, but you may at your own expense. You may also ask the
Court for permission to speak and express your opinion about the Settlement. If
the Court does not approve the Settlement or the parties decide to end it, it will be
void and the lawsuit will continue. The date of the hearing may change without
further notice to members of the Class. To learn more and confirm the hearing
date, go to www.StockpileDataSettlement.com.
Learning About the Settlement
What does the settlement provide?
The Settlement provides for the creation of a Settlement Fund in the amount of
$600,000.00 to pay for: (1) Individual Class Payments for Participating Class
Members; (2) Class Counsel Fees Payment and Class Counsel Litigation Expenses
Payment; (3) Administration Expenses Payment (up to $47,500); and (4) Class
Representative Service Payment.
How do I know if I am part of this settlement?
You are a part of the Settlement and eligible to submit a Claim Form if you are a
member of the Class.
The Class includes all individuals whose personal information was compromised in
the 2020 Data Breach perpetrated against the Defendants.
The Class specifically excludes: (a) Defendants and their employees, principals,
officers, directors, agents, affiliated entities, legal representatives, successors and
assigns; (b) the judges to whom this lawsuit has been or is assigned and any
members of their immediate families; and (c) all persons who have filed a timely
Request for Exclusion from the Class.
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Tell me more about the Settlement Benefits
Class Members who submit a complete and valid claim form on time are eligible
to receive a pro rata share of the Net Settlement Amount.* Those funds will then
be divided equally amongst the Participating Class Members who submit a timely
and valid Claim Form, capped at $90 (“Individual Class Payments”).
*The Net Settlement Amount means the Gross Settlement Amount ($600,000), less any
amount approved by the Court for: Class Counsel Fees Payment, Class Counsel Litigation
Expenses Payment, Class Representative Service Payment, and the Administration Expenses
Payment.
Participating Class Members will have 180 calendar days from the Award Issuance
Date to cash or redeem their Individual Class Payment or it will become void. Any
funds remaining from uncashed or cancelled Individual Class Payments, or from
the Net Settlement Amount after all Class Members’ claims have been paid, will be
transmitted to Privacy Rights Clearinghouse, the Court-approved nonprofit
organization that is dedicated to data privacy education and advocacy, and
therefore furthers the purposes of the lawsuit.
Remedial Measures. Stockpile represents that it has taken several remedial
measures since the 2020 Data Breach occurred to further enhance its security
posture. These include tightening its role-based access protocols; resetting
passwords and rotating security keys; enhancing Secure Shell (“SSH”) connection
protocols; and introducing new password rotation and reset functionalities.
Stockpile also continues to review and enhance its ongoing monitoring of its
environment and applicable third-party environments, as well as to review its
policies and procedures related to data security.
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Deciding What to Do
How do I weigh my options?
If you are a Class Member, you have four options. You can stay in the
Settlement and submit a claim, you can opt out of the Settlement, you can
object to the Settlement, or you can do nothing. This chart shows the effects of
each option:
Submit
Opt Out Object Do Nothing
a Claim
Can I receive a Settlement payment if I … YES NO YES* NO
Am I bound by the terms of this lawsuit if I… YES NO YES YES
Can I pursue my own case if I… NO YES NO NO
Will Class Counsel represent me if I… YES NO NO YES
*IMPORTANT: If you object to the Settlement, you still have to submit a Claim
Form to be eligible to receive a payment from the Settlement.
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What is the best path for me?
Are you satisfied with
the proposed
settlement?
Yes
No
Do you want to
receive a Do you want to
Settlement file your own
benefit? lawsuit or not be
bound by this
lawsuit?
Yes No
Yes No
Do
Submit a
nothing Opt out of
claim form I don't like
the the proposed
settlement settlement
Object in writing
and/or appear in
court to explain why
you don't like it
and/or
Submit a Claim Form
Submitting a Claim
How do I get a Settlement payment if I am a class member?
If you wish to receive a payment from the Settlement, you must submit a
completed claim form online at www.StockpileDataSettlement.com no later than
October 6, 2026. You can also download a claim form at
www.StockpileDataSettlement.com and mail to the Administrator at: Stockpile
Data Settlement Administrator, Attn: Claim Forms, 1650 Arch Street, Suite 2210,
Philadelphia, PA 19103. Claim forms mailed to the Administrator must be
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postmarked no later than October 6, 2026.
Do I have a lawyer in this lawsuit?
In a class action, the Court appoints lawyers to work on the case and represent
the interests of all the class members. For this settlement, the Court has
appointed the lawyers below to represent the Class.
Your lawyers: Jeffrey A. Koncius of Kiesel Law LLP and Dean J. Zipser and Mark
A. Finkelstein of Umberg Zipser LLP.
These are the lawyers who negotiated this settlement on your behalf. If you
want to be represented by your own lawyer, you may hire one at your own
expense.
Do I have to pay the lawyers in this lawsuit?
Class Counsel's fees and expenses will be paid from the Settlement Fund. You
will not have to pay the lawyers directly.
To date, Class Counsel have not been paid any money for their work or the
expenses that they have paid for the case. To pay for some of their time and
risk in bringing this case without any guarantee of payment unless they were
successful, Class Counsel will request an award for Class Counsel Fees Payment
not to exceed 33 1/3 % of the Settlement Fund, which is currently estimated to
be $200,000, and a Class Counsel Litigation Expenses Payment of not more
than $29,000. Class Counsel have agreed to divide any fees awarded based on
set percentages to each firm.
Class Counsel’s payments will only be awarded if approved by the Court as a
fair and reasonable amount. You have the right to object to Class Counsel’s
payments even if you think the Settlement terms are fair.
Class Counsel will also ask the Court to approve a Class Representative Service
Payment in the amount of $5,000 to the Plaintiff for the time and effort
contributed to the case. If approved by the Court, the award for the Class
Representative Service Payment will be paid from the Settlement Fund.
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Opting Out
What if I don't want to be part of this settlement?
You can opt out. If you do, you will not receive payment and cannot object to
the Settlement. However, you will not be bound or affected by anything that
happens in this lawsuit and may be able to file your own case.
How do I opt out?
To opt out of the Settlement (also called requesting exclusion from the
Settlement), your opt out request must be mailed to the Administrator so it is
postmarked no later than October 6, 2026.
Stockpile Data Settlement Administrator
Attn: Opt Outs
P.O. Box 58220
Philadelphia, PA 19102
A Request for Exclusion is a letter from a Class Member or his/her/their
representative that reasonably communicates the Class Member’s election to
be excluded from the Settlement and includes the Class Member’s name,
address and email address or telephone number.
Objecting
What if I disagree with the Settlement?
If you disagree with any part of the Settlement (including the Class Counsel Fees
Payment, Class Counsel Litigation Expenses Payment and/or the Class
Representative Service Payment) and do not opt out, you may object. You can
give reasons why you think the Court should not approve it. The Court will
consider your views. The Court can only approve or deny the Settlement — it
cannot change the terms of the Settlement. You may, but don’t need to, hire
your own lawyer to help you.
To object, you must send a letter to the Administrator that includes all of the
following information:
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1) Your personal signature as the objector;
2) Your full name and current address;
3) An explanation of the basis upon which you claim to be a Settlement
Class Member;
4) All grounds for the objection, including all citations to legal authority and
evidence supporting the objection;
5) The name and contact information of any and all lawyers representing,
advising, or in any way assisting you in connection with the preparation or
submission of the objection or who may profit from the pursuit of the objection;
6) You may include a statement indicating whether you intend to appear at
the Final Approval Hearing (either personally or through your lawyer who files
an appearance with the Court in accordance with the Local Rules), though the
Court generally will hear from any Class Member who attends the Final
Approval Hearing and asks to speak; and
7) If you or your lawyer has objected to any class action settlement where
you or your lawyer asked for or received any payment in exchange for dismissal
of the objection, or any related appeal, without any modification to the
settlement, then your objection must include a statement identifying each such
case by full case caption and amount of payment received.
Your written objection must be mailed to the Administrator no later than
October 6, 2026.
Stockpile Data Settlement Administrator
Attn: Objections
P.O. Box 58220
Philadelphia, PA 19102
You may appear at the Final Approval Hearing and orally object without first
submitting a written objection or notice of appearance.
Doing Nothing
What are the consequences of doing nothing?
If you do nothing, you will not receive a payment from the Settlement, but you
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will still be bound by the Settlement and its “release” provisions. That means
you won’t be able to start, continue, or be part of any other lawsuit against the
Defendants about the legal issues resolved by the Settlement. A full description
of the claims and persons who will be released if this settlement is approved
can be found in the Settlement Agreement located on the Settlement Website:
www.StockpileDataSettlement.com.
Key Resources
How do I get more information?
This notice is a summary of the proposed Settlement. The complete Settlement
with all its terms can be found at www.StockpileDataSettlement.com. If you
have additional questions, you can visit the Settlement Website, contact the
Administrator or contact Class Counsel.
Resource Contact Information
Case website www.StockpileDataSettlement.com
Settlement Stockpile Data Settlement Administrator
Administrator 1650 Arch Street, Suite 2210
Philadelphia, PA 19103
1-844-747-4126
[email protected]
Your Lawyers Jeffrey A. Koncius
Kiesel Law LLP
8648 Wilshire Blvd.
Beverly Hills, California 90211
Dean J. Zipser
Mark A. Finkelstein
Umberg Zipser LLP
1920 Main Street, Suite 750
Irvine, California 92614
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