IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR THE COUNTY OF KING
NOTICE OF CLASS ACTION SETTLEMENT
You are eligible for a class action settlement payment in relation to your employment application with
Talkdesk, Inc. The King County Superior Court authorized this notice. You are not being sued. This is not
a solicitation. Please read carefully.
• John Milito (“Plaintiff”) filed a lawsuit against Talkdesk, Inc. (“Defendant”) on behalf of himself and a
class of similarly situated applicants for employment for alleged violations of the Washington Equal Pay
and Opportunities Act, chapter 49.58 RCW. The lawsuit, John Milito v. Talkdesk, Inc., is currently pending
in King County Superior Court as Case Number 25-2-21719-1 SEA (the “Lawsuit”). The Court has not
made any determinations regarding the merits of the Lawsuit. Defendant denies the allegations in the
Lawsuit and also denies that Plaintiff’s claims would have been appropriate for certification as a class
action in the absence of a settlement.
• The Parties have reached a proposed settlement which includes a payment by Defendant of $1,828,288 to
$2,785,000, depending on how many Settlement Class Members submit claims. On June 17, 2026, the
Court issued an order preliminarily approving the settlement and authorizing the Settlement Administrator,
Simpluris, Inc. (“Settlement Administrator”), to issue this Notice and Claim Form.
• You are receiving this Notice because Defendant’s records indicate you are a settlement class member.
“Settlement Class Members” are defined as “Plaintiff and all individuals who, from January 1, 2023, to
July 26, 2025, either – (a) applied from any location for a job opening with Defendant, where the position
required the successful candidate to work in person in the State of Washington; and/or (b) are Washington-
based and applied for a job opening with Defendant where the State of Washington was identified as one
of the locations from which the successful candidate could work for Defendant – through a job posting on
Defendant’s website or its authorized third-party recruiting channels, where the job posting did not
disclose a wage scale or salary range to be provided to the hired applicant.”
• The Court still has to decide whether to approve the settlement. No settlement benefits or payments will
be provided unless the Court approves the settlement and it becomes final. Read this Notice carefully.
Your legal rights are affected regardless of whether you act or not. For more information, visit
www.EPOASettlementTDI.com.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
This is the only way you are eligible to receive a payment from this settlement. The
deadline to submit a Claim Form is October 13, 2026.
SUBMIT A CLAIM FORM
You may submit your claim online by visiting www.EPOASettlementTDI.com. You
may also send your Claim Form to the Settlement Administrator by mail or email.
If you request exclusion, you will no longer be in the Settlement Class and will not
EXCLUDE YOURSELF FROM receive a settlement payment. This is the only option that allows you to keep any right to
THE SETTLEMENT sue Defendant about the legal claims in this Lawsuit. The deadline to request exclusion
is October 13, 2026.
You may submit written notice to the Court explaining why you do not agree with the
OBJECT TO THE
settlement. You must not exclude yourself from the settlement if you wish to object. The
SETTLEMENT
deadline to object is October 13, 2026.
Page 1 of 7
Notice of Class Action Settlement
SIMID «SIMID»
You may ask the Court for permission for you or your attorney to speak about your
objection at the Final Approval Hearing. The Final Approval Hearing will be held before
ATTEND THE FINAL Judge Janet Helson on November 20, 2026, at 8:30 A.M. To attend this hearing remotely
APPROVAL HEARING please use the following link:
Zoom Link: https://kingcounty.zoom.us/j/82191528556
Meeting ID: 821 9152 8556
If you do nothing, you will remain in the Settlement Class but will forfeit the opportunity
DO NOTHING to receive a settlement payment and give up any right to sue Defendant, and certain
parties related to Defendant, about the claims that have been alleged in this Lawsuit.
BASIC INFORMATION
1. What is this Notice and why should I read it?
The Court authorized this Notice to inform you about a proposed settlement with Defendant. You have legal rights and
options you may act on before the Court decides whether to approve the proposed settlement. You may be eligible to receive
a cash payment as part of the settlement. This Notice explains the Lawsuit, the Class Action Settlement Agreement
(“Settlement Agreement”), and your legal rights.
The Honorable Janet Helson of King County Superior Court is overseeing this Lawsuit, which is titled John Milito v.
Talkdesk, Inc., Case No. 25-2-21719-1 SEA. John Milito is the Plaintiff or Class Representative. The company he sued,
Talkdesk, Inc., is the Defendant.
2. What is a class action lawsuit?
A class action is a lawsuit in which one or more plaintiffs sue on behalf of a group of people who have similar claims.
Together, this group is called a “Settlement Class” and consists of “Settlement Class Members.” In a class action, the court
resolves the issues for all class members, except those who exclude themselves from the class.
3. What is this Lawsuit about?
Plaintiff claims Defendant violated Washington law, RCW 49.58.110, when it allegedly did not disclose the pay and benefits
information on job postings for open Washington positions. Defendant denies that it is or can be held liable for the claims
made in the Lawsuit. More information about the Lawsuit can be found in the “Important Documents” section of the
Settlement Website at www.EPOASettlementTDI.com.
4. Why is there a settlement?
The Court has not decided who should win this case. Instead, the parties agreed to this settlement to avoid the uncertainty,
risks, and expense of ongoing litigation, and Settlement Class Members will get compensation now rather than years later—
if ever. Plaintiff and Class Counsel (attorneys for the Settlement Class Members) agree that the settlement is in the best
interests of the Settlement Class. The settlement is not an admission of wrongdoing by Defendant. Defendant denies the
allegations in the Lawsuit.
5. How do I know if I am in the Settlement Class?
Defendant’s records show you are part of the Settlement Class because you applied for a job opening in Washington with
Defendant between January 1, 2023, and July 26, 2025 (the “Settlement Class Period”), where the job posting arguably did
not properly disclose pay or benefits information. If you are not sure whether you are included, you can contact the
Settlement Administrator by calling toll-free at 1-833-421-7314, emailing [email protected], or by visiting
the Settlement Website at www.EPOASettlementTDI.com.
Page 2 of 7
Notice of Class Action Settlement
SIMID «SIMID»
THE SETTLEMENT BENEFITS
6. What does the settlement provide?
All Settlement Class Members who submit a timely and valid Claim Form are eligible to receive an equal share of the Class
Fund up to a maximum of $5,000. Your estimated payment amount is on the Claim Form you received with this Notice.
Settlement payments will be characterized as non-wage damages (1099).
7. How do I receive a payment?
To qualify for a settlement payment, you must complete the enclosed Claim Form and submit it by mail, email or online
submission, postmarked on or before October 13, 2026, to the Settlement Administrator:
John Milito v. Talkdesk, Inc.
c/o Simpluris, Inc.
P.O Box 26170
Santa Ana, CA 92799
[email protected]
(833) 421-7314
You can also complete your claim form online at www.EPOASettlementTDI.com. Claims will be subject to verification,
and the Settlement Administrator may request additional information. All Claim Forms must be submitted or
postmarked on or before October 13, 2026. To ensure you receive your payment, you must contact the Settlement
Administrator if your address or phone number changes at any time.
8. When will I get my payment?
The Final Approval Hearing (the hearing to consider the fairness of the settlement) is scheduled for November 20, 2026, at
8:30 A.M. If the Court approves the settlement, Settlement Class Members who submitted a timely, valid Claim Form will
be sent an individual settlement payment after all appeals and other reviews, if any, are completed. Please be patient. All
individual settlement payments will expire and become void 120 calendar days after the date of issuance.
9. Will Defendant retaliate against me if I participate in the settlement?
No. Defendant supports the settlement and will not retaliate in any way against any Settlement Class Member for
participating. Your decision to participate, not participate, or object to the settlement will not affect any application for
employment with Defendant or Defendant’s treatment of you as a prospective, current, or former employee.
THE ATTORNEYS REPRESENTING YOU
10. Do I have an attorney in this case?
Yes, the Court appointed Timothy W. Emery, Patrick B. Reddy, and Paul Cipriani of Emery Reddy, PC as Class Counsel
to represent the Settlement Class. Their contact information is:
Emery Reddy, PC
600 Stewart Street, Suite 1100
Seattle, WA 98101
Phone: (206) 442-9106
Should I get my own attorney? You don’t need to hire your own attorney because Class Counsel are working on your
behalf. These attorneys and their firm are experienced in handling similar cases. You will not be charged for these attorneys.
You can ask your own attorney to appear in Court for you, at your own cost, if you want someone other than Class Counsel
to represent you.
Page 3 of 7
Notice of Class Action Settlement
SIMID «SIMID»
11. How will Class Counsel and the Class Representative be paid?
Class Counsel will ask the Court to approve, and Defendant agrees not to oppose, an award of attorneys’ fees in the amount
of $821,575, plus costs and expenses of up to $5,000, to be paid from the Settlement Fund. Class Counsel will also request
a service award for Plaintiff in the amount of $20,000, to be paid from the Settlement Fund. The Court will determine the
proper amount of any attorneys’ fees, costs, and expenses to award Class Counsel and the proper amount of any service
award to Plaintiff. The Court may award less than the amounts requested. Whether the settlement will be finally approved
does not depend on whether or how much the Court awards in attorneys’ fees, costs, and expenses or service award.
YOUR RIGHTS AND OPTIONS
12. What claims do I give up by participating in this settlement?
If the Court approves the settlement, the Court will enter a final judgment dismissing the Lawsuit “with prejudice.” This
means that the claims in the Lawsuit will be permanently dismissed. Specifically, Defendant will be “released” from claims
as described in Paragraph 18 of the Settlement Agreement, which states:
Upon final approval of this Settlement Agreement by the Court, each Settlement Class Member who does
not submit a timely request for exclusion in accordance with the procedures set forth in Paragraph 14(a)
will release, waive, and forever discharge: (i) Defendant, Talkdesk, Inc., and each of its parents,
subsidiaries, affiliates, related companies/corporations and/or partnerships (defined as a
company/corporation and/or partnership that are, directly or indirectly, under common control with
Defendant or any of its parents and/or affiliates), investors, owners, joint ventures, joint employers, alter-
egos, divisions, insurers, insurance policies, and benefit plans, or any other entity with an interest in or
obligation regarding Defendant’s liabilities, (ii) each of the past, present, and future officers, directors,
agents, employees, equity holders (shareholders, holders of membership interests, etc.), representatives,
agents, administrators, fiduciaries and attorneys of the entities and plans described in this sentence; (iii) any
individuals or entities that assisted Defendant or any of the other individuals and entities described in
subsections (i) and (ii) of this Paragraph 18, with creating, publishing, processing, or hosting any of the job
postings used or maintained by Defendant during the Settlement Class Period or otherwise assisted
Defendant with its employee recruitment efforts; and (iv) the predecessors, successors, transferees, and
assigns of each of the persons and entities described in this sentence (the “Released Parties”) of and from
any and all claims that arose during the Settlement Class Period that were asserted against the Released
Parties by Plaintiff and Settlement Class Members in the Complaint or claims that could have been asserted
based on the facts alleged in the Complaint (the “Released Class Claims”). The Released Class Claims will
include any claims based on the Released Parties’ alleged failure to comply with the job posting/pay
transparency requirements of the Washington Equal Pay and Opportunities Act, including, but not limited
to, any alleged liabilities arising out of or relating to a failure to include the wage scale or salary range
and/or a general description of all of the benefits and other compensation to be offered to a hired applicant
or employee in any job postings. The Released Class Claims also specifically include any claims arising
out of or relating to a violation of RCW 49.58.110, and any attendant claims for relief under RCW 49.58.070
and/or RCW 49.58.110, interest, liquidated damages, exemplary damages, statutory damages, minimum
statutory damages, and attorneys’ fees and costs relating to any of the foregoing.
Any potential Settlement Class Member who does not request exclusion by the applicable deadline will be a Settlement
Class Member and will be considered to have accepted the above release and to have waived any and all of the released
claims against the Released Parties. Any potential Settlement Class Member who requests exclusion by the applicable
deadline is not a Settlement Class Member, will not be subject to the release, and will not receive any payment.
13. What happens if I do nothing?
If you do nothing, you will receive no payment under the settlement. You will still be in the Settlement Class, and, if the
Court approves the settlement, you will be bound by all orders and judgments of the Court, the Settlement Agreement, and
its included release. You will be deemed to have participated in the settlement and will be subject to the provisions above.
Unless you exclude yourself, you won’t be able to file a lawsuit or be part of any other lawsuit against Defendant for the
claims or legal issues resolved in this settlement.
Page 4 of 7
Notice of Class Action Settlement
SIMID «SIMID»
14. What happens if I request to be excluded?
If you submit a timely, valid request for exclusion from the settlement, you will receive no benefits or payment under the
settlement. However, you will not be in the Settlement Class, will not release claims against Defendant, and will not be
legally bound by the Court’s judgments in this Lawsuit.
15. How do I request to be excluded?
To request to be excluded from the settlement, you must send a letter, postmarked no later than October 13, 2026, to the
Settlement Administrator at the following address:
John Milito v. Talkdesk, Inc.
c/o Simpluris, Inc.
P.O Box 26170
Santa Ana, CA 92799
To be considered valid, a request for exclusion must include: (i) your full name; (ii) your address; (iii) a statement that you
wish to be excluded from the settlement (for example, “I request to be excluded from the class action settlement in John
Milito v. Talkdesk, Inc.”); and (iv) your (or your attorney’s) signature and date signed. You cannot exclude yourself by
phone or email. Each individual who wants to be excluded from the settlement must submit his or her own request for
exclusion. Group requests for exclusion are not permitted.
16. If I don’t exclude myself, can I sue Defendant for the same thing later?
No. Unless you exclude yourself, you give up any right to sue Defendant for the claims being resolved by this settlement
even if you do not submit a Claim Form.
17. If I exclude myself, can I get anything from this settlement?
No. If you exclude yourself, do not submit a Claim Form to ask for a payment.
18. How do I object to the settlement?
If you do not exclude yourself from the Settlement Class, you can object to the settlement if you disagree with any part of
it. You can give reasons why you think the Court should deny approval of the settlement by filing an objection. To object,
you must file written notice with the Court stating that you object to the settlement in John Milito v. Talkdesk, Inc., Case
No. 25-2-21719-1 SEA, King County Superior Court, no later than October 13, 2026. Your objection must be filed with
the Court, which you can do by mailing your objection and any supporting documents to King County Superior Court at the
following address:
King County Superior Court
516 Third Avenue, Room C-203
Seattle, WA 98104
If you are represented by an attorney, the attorney may file your objection through the Court’s e-filing system. To be valid,
your objection must be in writing and include: (i) your full name, address, telephone number, and e-mail address; (ii) the
case name and number; (iii) the reasons why you object to the settlement; (iv) the name and address of your attorney, if you
have retained one; (v) a statement confirming whether you and/or your attorney intend to personally appear at the Final
Approval Hearing; (vi) a list, by case name, court, and docket number, of all other cases in which you (directly or through
an attorney) have filed an objection to any proposed class action settlement within the last three years; and (vii) your (or
your attorney’s) signature and date signed.
In addition to filing your objection with the Court, you must also mail copies of your objection and any supporting
documents to both Class Counsel and Defendant’s Counsel at the addresses listed below, postmarked no later than October
13, 2026:
Page 5 of 7
Notice of Class Action Settlement
SIMID «SIMID»
Class Counsel Defendant’s Counsel
Timothy W. Emery Peter H. Nohle
Patrick B. Reddy Jackson Lewis P.C.
Paul Cipriani 520 Pike Street, Suite 2300
Emery Reddy, PC Seattle, Washington 98101
600 Stewart Street, Suite 1100
Seattle, Washington 98101
19. What’s the difference between objecting and excluding myself from the settlement?
Objecting simply means telling the Court that you don’t like something about the settlement. You can object only if you
stay in the Settlement Class. Excluding yourself from the Settlement Class is telling the Court that you don’t want to be part
of the Settlement Class. If you exclude yourself, you have no basis to object because the case no longer affects you.
THE COURT’S FINAL APPROVAL HEARING
20. When and where will the Court hold a hearing on the fairness of the settlement?
The Court will hold the Final Approval Hearing before Judge Janet Helson on November 20, 2026, at 8:30 A.M. in King
County Superior Court, King County Courthouse, 516 Third Avenue, Courtroom W-728, Seattle, WA 98104. To attend
remotely via Zoom, you may use the following link:
Zoom Link: https://kingcounty.zoom.us/j/82191528556
Meeting ID: 821 9152 8556
The purpose of the hearing is for the Court to determine whether the settlement is fair, reasonable, adequate, and in the best
interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness
of the proposed settlement, including those related to the amount requested by Class Counsel for attorneys’ fees, costs, and
expenses and the Plaintiff’s service award.
Note: The date and time of the Final Approval Hearing are subject to change by court order. Any changes will be posted at
the Settlement Website, www.EPOASettlementTDI.com, or through the Court’s publicly available docket. You should check
the Settlement Website or the Court’s docket to confirm the date and time have not been changed.
21. Do I have to come to the hearing?
No. Class Counsel will answer any questions the Court may have, but you are welcome to attend the hearing at your own
expense. If you file an objection, you don’t have to come to the hearing to talk about it. As long as your written objection
was filed or mailed on time and meets the other criteria described in the settlement, the Court will consider it. You may also
hire an attorney to attend on your behalf at your own expense, but you don’t have to.
22. May I speak at the hearing?
Yes. If you do not exclude yourself from the Settlement Class, you may ask the Court for permission to speak at the Final
Approval Hearing concerning any part of the proposed settlement.
GETTING MORE INFORMATION
23. Where can I get additional information?
This Notice summarizes the proposed settlement. More details are in the Settlement Agreement, which is available at
www.EPOASettlementTDI.com.
You may contact the Settlement Administrator by phone, email, or in writing at:
John Milito v. Talkdesk, Inc.
Page 6 of 7
Notice of Class Action Settlement
SIMID «SIMID»
c/o Simpluris, Inc.
P.O Box 26170
Santa Ana, CA 92799
(833) 421-7314
[email protected]
DO NOT CALL THE COURT, THE CLERK OF THE COURT, OR DEFENDANT WITH QUESTIONS
ABOUT THE SETTLEMENT OR CLAIMS PROCESS.
Page 7 of 7
Notice of Class Action Settlement
SIMID «SIMID»
