Frequently Asked Questions

Basic Information

1. Why did I get the Notice?

You received the Notice because your PII may have been affected in the Data Incident. A group of similarly situated individuals brought a proposed class action lawsuit against QTC in 2023, alleging that QTC was negligent due to its data security practices. QTC denies the allegations and denies that it would be found liable. The parties have now reached a proposed settlement of the lawsuit.

A court authorized the Notice because you have a right to know about your rights under the proposed class action Settlement before the Court decides whether to approve the Settlement. If the Court approves the Settlement, and after objections and appeals are resolved, a Settlement Administrator appointed by the Court will make the payments that the Settlement allows, and the pending legal claims against QTC will be released and dismissed.

This website and the Notice explain the lawsuit, the Settlement, your rights, what benefits are available, who is eligible for them, and how to get them. Judge Joel H. Slomsky of the United States District Court for the Eastern District of Pennsylvania is in charge of this case. The case is In re: QTC Commercial Services, LLC d/b/a IMX Medical Management Services, LLP Data Breach Litigation, No. 2:23-cv-03214-JHS (E.D. Pa.).

2. What is this lawsuit about?

This matter is a putative class action (the “Litigation”) arising from a Data Incident whereby a cybercriminal gained unauthorized access to QTC’s data environment between June and October of 2022, resulting in potential access to certain PII. The lawsuit asserts claims against QTC for alleged negligent data security practices.

Defendant denies any and all allegations of wrongdoing.

3. What is a class action?

In a class action, one or more individuals called “Class Representatives” sue on behalf of themselves and others who have similar claims. This group of individuals is called the “class,” and the individuals in the class are called “Settlement Class Members” or the “Settlement Class.” One court resolves the issues for all Settlement Class Members, except for those individuals who exclude themselves from the class. The individuals who sued are called the Plaintiffs. The entity they sued—QTC—is called the Defendant.

4. Why is there a Settlement?

The Court did not decide in favor of Plaintiffs or Defendant. Instead, both sides agreed to a Settlement. That way, they avoid the costs and risks of a trial, and Settlement Class Members can receive benefits or compensation. The Class Representatives and Class Counsel believe the Settlement is in the best interest of the Settlement Class.

Who’s Included in the Settlement

5. Who is included in the Settlement?

The Settlement Class is defined as “all natural persons residing in the United States who were provided notice that their personal information was involved in the Data Incident.”

6. Are there exceptions to being included?

Yes, the following are not included in the Settlement Class: (i) QTC and its respective officers and directors; (ii) all members of the Settlement Class who timely and validly submit a Request for Exclusion; (iii) the Judge assigned to evaluate the fairness of the Settlement; and (iv) any other Person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding, or abetting the Data Incident or who pleads nolo contendere to any charge.

7. What should I do if I am not sure whether I am included?

If you are not sure whether you are included in the Settlement Class, you can ask for free help by calling the Settlement Administrator at (833) 296-0962 or you can email info@QTCDataSettlement.com for more information.

The Settlement Benefits

8. What does the Settlement provide?

Under the Settlement, QTC will pay for all valid claims made by Settlement Class Members, subject to a cap of $670,000.00, inclusive of class relief, notice and administration costs, service awards, and attorneys’ fees and costs. If the total cost of the Settlement is more than $670,000.00, approved claims will be decreased, pro rata, to reach $670,000.00.

9. What can I get from the Settlement?

Settlement Class Members may file a claim for one or more of the following settlement benefits:

Alternative Cash Payment: Settlement Class Members can receive a cash payment of $80.00, which does not require any supporting documentation or attestations. Settlement Class Members who elect to receive this Alternative Cash Payment are ineligible to receive payment for Time Spent or Ordinary or Extraordinary Unreimbursed Losses, as listed below.

Time Spent: Settlement Class Members can alternatively receive compensation for time spent dealing with the Data Incident, at a rate of $25.00 per hour for up to four (4) hours (i.e., not to exceed $100.00 per Settlement Class Member). Settlement Class Members will be required to attest to how the time was spent and demonstrate that it was related to the Data Incident.

Ordinary Unreimbursed Losses: Settlement Class Members may file a claim for reimbursement for ordinary unreimbursed losses of up to $1,750.00, supported by sufficient documentation. Ordinary Unreimbursed Losses include (i) documented out-of-pocket expenses related to the Data Incident such as: (a) bank fees, (b) long-distance phone charges, (c) cell phone charges (only if charged by the minute), (d) data charges (only if charged based on the amount of data used), (e) postage, and (f) gasoline for local travel; and (ii) documented fees for credit reports, credit monitoring, or other identity theft insurance products.

Extraordinary Unreimbursed Losses: Settlement Class Members may also file a claim for reimbursement for extraordinary unreimbursed losses of up to $2,000.00. For each claim of an extraordinary unreimbursed loss, the Settlement Class Member must show the following, supported by documentation:

• The loss is an actual and unreimbursed monetary loss, supported by third-party documentation;

• The loss resulted from actual identity theft, fraud, or similar criminal victimization;

• The loss was more likely than not caused by the Data Incident;

• The loss is not already covered by one or more of the other/normal reimbursement categories (i.e., Ordinary Unreimbursed Losses or Time Spent); and

• The Settlement Class Member made reasonable efforts to avoid, mitigate, or seek reimbursement for the loss, including, but not limited to, exhaustion of all available credit monitoring insurance and identity theft insurance.

California Class Payment: California Subclass Members may submit a claim for a $100.00 cash payment in addition to the other relief available pursuant to this Settlement Agreement. You must have been resident in California, as shown by records available to Defendant, at the time of the Data Incident to be eligible for this payment.

Credit Monitoring Services: Settlement Class Members may also file a claim for two (2) years of credit monitoring and fraud protection services from Equifax Credit Watch Gold.

10. What am I giving up if I stay in the Class?

If you are a Settlement Class Member and you do not exclude yourself from the Settlement, you will give up your right to sue, continue to sue, or be part of any other lawsuit against Defendant or other released parties concerning the claims released by this Settlement. The “Releases” section in the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The entire text of the Settlement Agreement can be viewed here.

How to Get a Payment – Making a Claim

11. How can I receive a payment?

You must complete and submit a Claim Form by August 21, 2025. Claim Forms may be submitted online here or downloaded here to be printed and mailed to the address on the form.

Be sure to read the Claim Form instructions carefully, include all required information, and add your signature.

The Settlement Administrator will review your claim to determine the validity and amount of your payment.

12. How much will my payment be?

The amount of your payment will depend on the approved amount of your claim and the total value of all approved claims.

Your claim must be reasonably documented—you must enclose or upload documentation sufficient to show (a) the amount of unreimbursed loss that you suffered, and (b) why you believe that the loss is reasonably attributable to the Data Incident in the case. Documents for financial expenses may include credit card or bank statements, emails, invoices, receipts, or telephone records, including photographs of the same. Personal statements or declarations are not considered reasonable documentation, but may be used to provide clarification, context, or support for other documentation.

13. When will I receive my payment?

The Court will hold a hearing on September 5, 2025, at 10:30 a.m. to decide whether to approve the Settlement. Payments will be made after the Settlement is approved and becomes final (meaning there is no appeal from the order approving the Settlement). Updates regarding the Settlement will be posted on this website here.

The Lawyers Representing You

14. Do I have a lawyer in this case?

The Court appointed David K. Lietz of the law firm Milberg Coleman Bryson Phillips Grossman PLLC and William B. Federman of the law firm Federman & Sherwood as attorneys to represent the Settlement Class. These lawyers are called Class Counsel.

15. Should I get my own lawyer?

If you want your own lawyer, you may hire one, but you will be responsible for any payment for that lawyer’s services. For example, you can ask your own lawyer to appear in court for you if you want someone other than Class Counsel to speak for you. You may also appear for yourself without a lawyer.

16. How will the lawyers be paid?

The attorneys representing the Class have not yet received any payment for their legal services or any reimbursement of the costs or out-of-pocket expenses they have incurred. Class Counsel plans to ask the Court to award attorneys’ fees, costs, and expenses from the Total Settlement Compensation, as defined by the Settlement Agreement, not to exceed $233,333.00.

The Settlement Class is represented by two named individuals (the “Class Representatives”). In addition to the benefits that the Class Representatives will receive as members of the Settlement Class—and subject to the approval of the Court—QTC has agreed to pay $2,500.00 to each of the Class Representatives (in the aggregate $5,000.00) for the efforts they have expended on behalf of the Settlement Class.

The Court will determine whether to approve the amount of fees, costs and expenses requested by Class Counsel and the proposed service awards to the Class Representatives. Class Counsel will file an application for fees, expenses, and service awards no later than July 8, 2025. The application will be available for review on this website here.

Excluding Yourself from the Settlement

17. How do I get out of the Settlement?

If you are a Settlement Class Member and you do not want the benefits from the Settlement, and you want to keep your right, if any, to sue Defendant on your own about the legal issues in this case, then you must take steps to get out of the Settlement. This is called excluding yourself from— or “opting out” of—the Settlement Class.

You may opt out of the Settlement by July 22, 2025. To opt out, you must send a letter or postcard via U.S. mail to the address below. You must include the following in your letter or postcard:

1. The name of this Litigation, or a decipherable approximation (In re: QTC Commercial Services, LLC d/b/a IMX Medical Management Services, LLP Data Breach Litigation, Master File No. 2:23-cv-03214 (E.D. Pa.));

2. Your full name, address, telephone number, and signature;

3. The words “Requests for Exclusion” at the top of the document or a statement that you want to opt out of the Settlement; and

4. If you are filing a request for exclusion on behalf of an incapacitated or deceased Settlement Class Member for whom you are legally authorized to act, you must include your name, address, phone number, signature, and relationship to the Settlement Class Member, as well as that person’s name and address.

You must mail your opt out request via first-class U.S. Mail, postmarked no later than July 22, 2025 to:

QTC Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

If you fail to include the required information, your request will be deemed invalid and you will remain a Settlement Class Members and be bound by the Settlement, including all releases.

18. If I am a Settlement Class Member and don’t opt out, can I sue the Defendant for the same thing later?

No. You must opt out of the Settlement to keep your right to sue the Defendant or other released parties for any of the claims released by the Settlement, as set out in full in the Settlement Agreement.

19. What happens if I opt out?

If you opt out of the Settlement, you will not have any rights as a member of the Settlement Class. You will not receive a payment as part of the Settlement. You will not be bound by the Settlement, releases in the Settlement Agreement, or by any further orders or judgments in this case. You will keep the right, if any, to sue on the claims alleged in the case at your own expense.

In addition, if you opt out of the Settlement, you cannot object to this Settlement because the Settlement no longer affects you. If you object to the Settlement and request to exclude yourself, your objection will be voided and you will be deemed to have excluded yourself.

Commenting on or Objecting to the Settlement

20. How do I tell the Court if I don’t like the Settlement?

If you are a Settlement Class Member and you do not opt out of the Settlement, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. You can give reasons why you think the Court should not approve it. You can’t ask the Court to change the Settlement or order a different settlement; the Court can only approve or deny this Settlement. If the Court denies approval, no settlement payments will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

You may object to any part of the proposed Settlement in writing. You may also appear at the “Fairness Hearing,” either in person or through your own attorney. If you appear through your own attorney, you are responsible for paying that attorney.

If you object in writing, you must include:

• the objector’s full name and address;

• the case name and docket number (In re: QTC Commercial Services, LLC d/b/a IMX Medical Management Services, LLP Data Breach Litigation, Master File No. 2:23-cv-03214 (E.D. Pa.));

• a written statement of all grounds for the objection, accompanied by any legal support for the objection that the objector believes applicable and any supporting documents;

• the identity of any and all counsel representing the objector in connection with the objection;

• a statement of whether the objector and/or his or her counsel will appear at the Fairness Hearing; and

• the objector’s signature or the signature of the objector’s duly authorized attorney or other duly authorized representative (if any) representing him or her in connection with the objection.

Any objection must be mailed to the Settlement Administrator at:

QTC Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

The objection must be postmarked no later than July 22, 2025.

21. What’s the difference between objecting and opting out?

Objecting is telling the Court that you don’t like something about the Settlement. You can object to the Settlement only if you are a Settlement Class Member and do not opt out of the Settlement. Opting out of the Settlement is telling the Court that you don’t want to be part of the Settlement. If you opt out of the Settlement, you cannot object to it because it does not affect you.

The Court’s Fairness Hearing

22. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Fairness Hearing at 10:30 a.m. on September 5, 2025, at the federal courthouse located at 601 Market Street, Philadelphia, PA 19106 before Judge Joel H. Slomsky. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate; Class Counsel’s application for attorneys’ fees, costs, and expenses; and whether to approve service awards to the Class Representatives. If there are objections, the Court will consider them. The Court may choose to hear from individuals who have asked to speak at the hearing. At or after the hearing, the Court will decide whether to approve the Settlement. There is no deadline by which the Court must make its decision.

The Court may reschedule the Fairness Hearing or change any of the deadlines described on this website. The date of the Fairness Hearing may change without further notice to the Settlement Class Members. Be sure to check the Important Dates page for updates. You can also access the case docket via the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.paed.uscourts.gov.

Class Counsel will file a motion for final approval of the Settlement by August 22, 2025. Objectors, if any, must file any response to Class Counsel’s motion by August 29, 2025. Responses to any objections and any replies in support of final approval of the Settlement and/or Class Counsel’s application for attorneys’ fees, costs, and expenses, and Service Awards will be filed by September 2, 2025.

23. Do I have to come to the Fairness Hearing?

No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish. If you send an objection, you do not have to come to the hearing to talk about it. As long as you mailed or filed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.

24. May I speak at the hearing?

You may ask the Court for permission to speak at the Fairness Hearing. To do so, you must include a statement in your written objection (see Question 20) that you intend to appear at the hearing. Be sure to include your name, address, and signature as well. You cannot speak at the hearing if you opt out or exclude yourself from the Settlement Class.

If I Do Nothing

25. What happens if I do nothing at all?

If you are a Settlement Class Member and do nothing, you will not receive any money from this Settlement, and you will not be able to sue the Defendant or other released parties for the claims released by the Settlement Agreement.

Getting More Information

26. How do I get more information?

This website summarizes the proposed Settlement. More details are in the Settlement Agreement. A copy of the Settlement Agreement, Claim Form and other case documents are available on the Important Documents page. You may also access the docket in this case through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.paed.uscourts.gov, or visit the office of the Clerk of the Court for the United States District Court for the Eastern District of Pennsylvania, 601 Market Street, Philadelphia, PA 19106 between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.

For additional answers to questions about the Settlement and other information to help you determine whether you are eligible for a payment, contact the Settlement Administrator, Simpluris at (833) 296-0962 or by writing to:

QTC Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
info@QTCDataSettlement.com

You may also Contact Class Counsel at the following:

PLEASE DO NOT CONTACT THE COURT, THE COURT CLERK’S OFFICE, OR DEFENDANT TO INQUIRE ABOUT THIS SETTLEMENT OR THE CLAIM PROCESS.