NOTICE OF PROPOSED CLASS ACTION SETTLEMENT
A Settlement has been proposed in a class action lawsuit against Oklahoma Surgical Hospital, LLC (“OSH”). This Lawsuit alleges that certain tracking technology and tools on OSH websites improperly shared with third parties, such as Meta and Google, certain data about patients’ visits to OSH’s online websites and platforms without their knowledge or consent. OSH denies all the allegations made in the Lawsuit, denies that any data traceable to any specific individual was shared, denies any wrongdoing whatsoever, and maintains that its practices were in all respects lawful and proper. However, OSH has agreed to this settlement in order to avoid the costs and burdens of further litigation.
You are included in this Settlement, and your rights may be affected by this Settlement if you are a Settlement Class Member. The Settlement Class Members are “all Persons who were patients of Oklahoma Surgical Hospital and, during the period July 1, 2021, through November 5, 2023, visited any website, patient portal, social media site, or bill payment site of Oklahoma Surgical Hospital. The Settlement Class specifically excludes: (i) OSH and each of its owners, LLC members, officers and directors; (ii) all Settlement Class Members who timely and validly request exclusion from the Settlement Class; and (iii) the presiding judge, and her staff and family.”
This Notice summarizes the proposed Settlement and your legal rights. For the precise terms of the Settlement, see the Settlement Agreement available here.
Under the Settlement, OSH has agreed to provide certain monetary relief, further described below.
The Settlement allows each Settlement Class Member to file a personally signed Claim verifying under oath that he or she visited an OSH website or online platform from July 1, 2021, through November 5, 2023. The “Value of the Settlement” is no less than $1,000,000, comprised of: (a) the estimated $660,000 made available to pay $12 to each of the approximately 55,664 Settlement Class Members who submit a Valid Claim; (b) attorneys’ fees to Class Counsel of $333,333.33 as approved by the Court; and (c) a service award of up to $5,000 awarded to the Class Representative as approved by the Court. The Costs of Claims Administration and notice to be paid by OSH. Persons who submit timely and Valid Claims as specified below and who qualify will receive a settlement benefit of $12. In exchange for the benefits the Settlement provides, Settlement Class Members will release any and all claims they may have (whether known or unknown) regarding the use of tracking technology on OSH websites, the sharing of data concerning Settlement Class Members’ visits to OSH’s websites or online platforms, or the allegations of the complaint, as further set forth in the release contained in the Settlement Agreement that is available here.
The Court will decide whether to approve the proposed Settlement. If approved, the Settlement will resolve the Lawsuit entitled Jane Doe, et al. v. Oklahoma Surgical Hospital, LLC, CIVIL ACTION NO. CJ-2023-03806, which is pending before Judge Caroline Wall in the District Court of Tulsa County, Oklahoma.
The class action settlement approval process may take several months, or more if there is an appeal. Benefits will not be paid unless and until this process is completed and final court approval is obtained. Please be patient.
Please Read This Notice Carefully
| YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT | ||
| FILE A CLAIM FOR COMENSATION | You may file a personally signed Claim in order to receive a monetary payment of $12. Filing a Claim Form is the only way to receive a payment from this Settlement. For detailed information about how to file a Claim, see Question 15. | Deadline to File Claim: December 26, 2025 |
EXCLUDE YOURSELF FROM YHIS SETTLEMENT | You can exclude yourself from the Settlement by informing the Settlement Administrator that you want to “opt out” of the Settlement by sending a personally signed written request for exclusion. If the Settlement becomes Final, this is the only option that allows you to retain your rights to individually sue for claims relating to the allegations in the complaint. You will not receive a payment from the Settlement if you exclude yourself. For detailed information about excluding yourself from the Settlement, see Question 26. |
Deadline to Opt Out: |
| OBJECT TO OR COMMENT ON THE SETTLEMENT | You may object to the Settlement by writing to the Court about why you don’t think the Settlement should be approved. You can also write the Court to provide comments or reasons why you support the Settlement.
| Deadline to Object: September 9, 2025 |
| GO TO THE FINAL FAIRNESS HEARING | You may, but you are not required to, attend the Final Fairness Hearing in the District Court of Tulsa County, Oklahoma, where the Court will hear any oral arguments concerning the approval of the Settlement. If you wish to speak at the Final Fairness Hearing, you must state your intention to do so in your written objection or comment. For detailed information about attending the Final Fairness Hearing, see Question 23. | Date of Final Fairness Hearing: September 26, 2025 at 9:30AM CT |
DO NOTHING | Unless you exclude yourself, you are automatically part of the Settlement. If you do nothing, you will not get a payment from this Settlement and will give up the right to sue, continue to sue, or be part of another suit against OSH related to the legal claims resolved by this Settlement. |
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