1. Why did I get the Notice?
2. What is this Lawsuit about?
3. Why is this a class action?
4. Why is there a settlement?
5. How do I know if I am part of the Settlement?
6. Are there exceptions to individuals who are included in the Settlement Class?
7. What if I am still not sure whether I am part of the Settlement?
8. What does the Settlement provide?
9. What if there are excess or insufficient funds in the Settlement Fund to pay all Approved Claims?
10. Are there other important terms of the Settlement?
11. What am I giving up in order to receive a Settlement Class Member Benefit or stay in the Settlement Class?
12. What are the Released Claims?
13. How do I make a claim for Settlement Class Member Benefits?
14. Where do I send my completed Claim Form?
15. What happens if my contact information changes after I submit a Claim?
16. When and how will I receive the Settlement Class Member Benefits?
17. Do I have a lawyer in this case?
18. How will Settlement Class Counsel be paid?
19. How do I get out of the Settlement?
20. If I exclude myself, can I still receive Settlement Class Member Benefits?
21. If I do not exclude myself, can I sue Defendants for the same thing later?
22. How do I tell the Court that I do not like the Settlement?
23. What is the difference between objecting and requesting exclusion?
24. When and where will the Court decide whether to approve the Settlement?
25. Do I have to come to the Final Approval Hearing?
26. May I speak at the Final Approval Hearing?
27. What happens if I do nothing at all?
28. How do I get more Information?
The Court authorized Notice because you have the right to know about the proposed Settlement of this class action lawsuit and about all of your rights and options before the Court decides whether to grant final approval of the Settlement. The Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for the benefits, and how to receive those benefits.
The case is known as Morelli v. Rhode Island Public Transit Authority et al., No. PC-2022-6145 (the “Litigation”), in the Providence County, Rhode Island Superior Court. The people who filed this lawsuit and are now moving to settle the Litigation are called the “Plaintiffs,” and the entities they sued (RIPTA and UHC) are called the “Defendants.”
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On or about August 5, 2021, RIPTA discovered a ransomware attack that impacted its network. RIPTA’s investigation of the attack determined that an unauthorized party exfiltrated files containing personal information from RIPTA’s network. Though RIPTA was unable to determine whether the unauthorized actor accessed the contents of these exfiltrated files, RIPTA notified all individuals whose personal information was contained in the files, out of an abundance of caution.
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In a class action, one or more people called the “Plaintiffs,” or “Representative Plaintiffs,” sue on behalf of all people who have similar claims. Together, all of these people are called a “class” or “class members.” One court resolves the issues for all class members, except for those class members who exclude themselves from the class.
The Representative Plaintiffs in this case are Alexandra Morelli, David Novasam, Audrey Snow, Betty J. Potenza, Norman R. Plante, Eileen Botelho, Gary Ruo, David A. Rosa, Caronah Cassell-Johnson, Sheila M. Galamaga, Caitlyn Lamarre and Diane M. Cappalli.
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Plaintiffs and Defendants disagree over the legal claims made in this Litigation. Defendants deny the claims alleged in the Litigation or that they did anything wrong, but have agreed to this Settlement because succeeding in the Litigation would be protracted and expensive. The Litigation has not proceeded to trial, and the Court has not decided in favor of Plaintiffs or Defendants (collectively referred to as the “Parties”). Further, no court or other judicial entity has made any judgment or other determination that Defendants have done anything wrong. Instead, the Parties have agreed to settle the Litigation and agree that the Settlement Agreement offers significant benefits to all Settlement Class members and is fair, reasonable, adequate, and in the best interest of Plaintiffs and all Settlement Class Members.
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The Settlement Class includes all individuals residing in the United States to whom Defendant RIPTA sent notification that their personal information may have been compromised as a result of a ransomware attack discovered by RIPTA on or about August 5, 2021.
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Yes, the Settlement does not include the Court, members of the Court’s staff, or persons who timely and validly request exclusion from the Settlement Class.
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If you are still not sure whether you are a Settlement Class member, you may call toll-free at 1-833-296-0884. You may also email the Claims Administrator at info@CyberIncidentSettlement.com.
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Under the Settlement, Defendants have agreed to establish a $350,000 Settlement Fund to reimburse Settlement Class Members for Valid Claims and pay for Class Notice, Claims Administration, and Service Awards. If there are more than $350,000 in Valid Claims, Defendants have agreed to pay up to $25,000 more into the Settlement Fund. Defendants also have agreed to pay for Credit Monitoring and Attorneys’ Fees and Costs awarded to Settlement Class Counsel.
Monetary Settlement Benefits: Includes reimbursement for Lost Time, Ordinary Losses, and/or Extraordinary Losses.
Attested Lost Time: Settlement Class members with time spent remedying issues related to the Data Incident may receive reimbursement of $15.00 per hour up to four hours (for a total of $60.00) with an attestation including a brief description of the action(s) taken in response to the Data Incident.
Documented Ordinary Losses: Reimbursement for unreimbursed Ordinary Losses fairly traceable to the Data Incident, may be up to a total of $1,000.00 per person, and may include the following:
Out of pocket expenses incurred as a result of the Data Incident, including unreimbursed bank fees, long distance phone charges, cell phone charges (only if charged by the minute), data charges (only if charged based on the amount of data used), postage, or gasoline for local travel; and
Fees for credit reports, credit monitoring, or other identity theft insurance product purchased between August 5, 2021, and the date of the Court’s entry of the preliminary approval order.
Documented Extraordinary Losses: Reimbursement for Extraordinary Losses resulting from the Data Incident, up to $7,500 per person if the extraordinary loss: (i) is an actual, documented and unreimbursed cost, expense, loss or charge incurred as a result of identity theft or identity fraud, falsified tax returns or other possible misuse of the Settlement Class Member’s personal information; (ii) occurred between August 5, 2021 and the date of the Court’s entry of the preliminary approval order; (iii) is not already covered by one or more of the ordinary loss categories, and (iv) the Settlement Class Member made reasonable efforts to avoid, or seek reimbursement for, the loss, including but not limited to exhaustion of all available credit monitoring insurance and identity theft insurance.
Settlement Class Members must submit documentation supporting their Claims for Ordinary Losses and/or Extraordinary Losses. This documentation may include receipts or other documentation not “self-prepared” by the claimant that documents the costs incurred.
Settlement Class Members shall not be reimbursed for expenses if they have been reimbursed for the same expenses by another source, including compensation provided in connection with the credit monitoring and identity theft protection product offered as part of the notification letter provided by RIPTA.
Complimentary Credit Monitoring: In addition to the above monetary settlement benefits, Settlement Class Members may also make a Claim for free Credit Monitoring for 5 years of 1-bureau credit monitoring.
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If the total dollar value of Approved Claims exceeds the amount in remaining in the Settlement Fund necessary to cover Approved Claims, Service Awards, Class Notice and Claims Administration costs, the payment amount for Approved Claims shall be reduced pro rata among all Settlement Class Members who submitted Approved Claims. Alternatively, if there is a portion of the Settlement Fund remaining after payments, this amount will be distributed pro rata among all Settlement Class Members who timely submitted Approved Claims, unless the cost of doing so would be prohibitive, in which case the Court will decide where to distribute those excess funds. Any pro rata increases or decreases to Approved Claims will be on an equal percentage basis.
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Declaration Regarding Remedial Actions. During the confidential Mediation, RIPTA provided satisfactory information relating to RIPTA’s changes of its policies, procedures, and practices since the Data Incident (“RIPTA Mediation Material”). Representative Plaintiffs have deemed the RIPTA Mediation Material to be sufficient under relevant cybersecurity standards.
Reasonable Due Diligence. The Settling Parties exchanged information that permitted them to conclude that the settlement is fair, reasonable, and adequate. To the extent that a Settling Party receives a request for information from a putative class member, counsel for the Representative Plaintiffs and Defendants will confer in good faith about what information, if any, should be provided in response to that request.
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Unless you exclude yourself, you are choosing to remain in the Settlement Class. If the Settlement is approved and becomes final, all of the Court’s orders will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against Defendants and the other Released Parties about the legal issues in this Litigation, resolved by this Settlement, and released by the Settlement Agreement and Releases. The specific rights you are giving up are called Released Claims (see FAQ 12).
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Released Claims include any and all claims, defenses, demands, actions, causes of action, rights, offsets, setoffs, suits, remedies, damages, lawsuits, costs, relief for contempt, losses, attorneys’ fees, expenses, or liabilities of any kind whatsoever, in law or in equity, for any relief whatsoever, including but not limited to monetary sanctions or damages for contempt, injunctive or declaratory relief, mandamus, rescission, general, direct, compensatory, special, liquidated, indirect, incidental, consequential, or punitive damages, as well as any and all claims for treble damages, statutory damages, penalties, interest, attorneys’ fees, costs, or expenses, whether a known or unknown (including Unknown Claims), suspected or unsuspected, existing or potential, contingent or vested, accrued or not accrued, liquidated or unliquidated, matured or unmatured, that in any way concern, arise out of, or relate to the Data Incident, any legal, factual, or other allegations in the Litigation, or any theories of recovery that were, or could have been, raised at any point in the Litigation.
More information is provided in the Settlement Agreement.
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You may submit your claim online here or you may download a full Claim Form here to complete and return it by mail. Claim Forms must be submitted online by August 25, 2025. Claim Forms submitted by mail must be postmarked no later than August 25, 2025.
Settlement Class Members can also request a Claim Form by calling toll-free 1-833-296-0884 or by writing to the Claims Administrator.
RIPTA/UHC Data Incident Settlement
c/o Claims Administrator
Attn: Claim Request
P.O. Box 25226
Santa Ana, CA 92799
info@CyberIncidentSettlement.com
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Completed Claim Forms, along with supporting documentation, may be mailed to the Claims Administrator at: RIPTA/UHC Data Incident Settlement, c/o Claims Administrator, P.O. Box 25226 Santa Ana, CA 92799. Remember, Claim Forms submitted by mail must be postmarked no later than August 25, 2025.
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If you need to update your contact information after you submit a Claim Form, you may notify the Claims Administrator of any changes by writing to the Claims Administrator via mail or email. Please include your Notice ID number with any written requests to assist the Claims Administrator in identifying you.
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If you submit a Valid Claim for Credit Monitoring, the Claims Administrator will send you an email with instructions on how to activate those services after the Settlement becomes Final.
Monetary Settlement Benefits will be issued by the Claims Administrator after the Settlement is approved and becomes Final. Payments will be issued via the payment selection made on the Claim Form. It is your responsibility to inform the Claims Administrator of any updates to your payment information after the submission of your Claim Form.
The Settlement approval process may take time and there may be appeals that must be resolved before any Settlement Class Member Benefits can be issued. Please be patient and check this website for updates.
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Yes, the Court has appointed Law Offices of Peter N. Wasylyk, Phillips & Garcia, P.C., and Lynette Labinger, Cooperating Counsel, ACLU Foundation of Rhode Island as Settlement Class Counsel to represent you and the Settlement Class for the purposes of this Settlement. You may hire your own lawyer at your own cost and expense if you want someone other than Settlement Class Counsel to represent you in this Litigation.
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Settlement Class Counsel will file a motion asking the Court to award them attorneys’ fees and reasonable costs and expenses not to exceed $237,500.00, to be paid outside of the Settlement Fund. The Representative Plaintiffs may seek a Service Award not to exceed $1,500.00 each, to be paid solely from the Settlement Fund. Attorney’s Fees and Expenses, as well as Service Awards, are subject to Court approval. The Court may award less than these amounts.
If you are a Settlement Class member and want to keep any right you may have to sue or continue to sue Defendants and/or the other Released Parties on your own based on the claims raised in this Litigation or released by the Released Claims, then you must take steps to get out of the Settlement. This is called excluding yourself from—or “opting out” of—the Settlement.
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To exclude yourself from the Settlement, you must complete and sign a Request for Exclusion. The Request for Exclusion must be in writing and identify the case name, Morelli v. Rhode Island Public Transit Authority et al., No. PC-2022-6145 (Providence County Superior Ct.), include the name, address, and telephone number of the individual requesting exclusion, include a statement indicating a request to be excluded from the Settlement Class, and contain the Settlement Class Member’s personal and original signature.
The Request for Exclusion must be postmarked or received by the Claims Administrator at the address below no later than July 25, 2025.
RIPTA/UHC Data Incident Settlement
c/o Claims Administrator
Attn: Exclusion Requests
P.O. Box 25226
Santa Ana, CA 92799
You cannot exclude yourself by telephone or by email.
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No. If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You are only eligible to receive Settlement Class Member Benefits if you stay in the Settlement and submit a valid Claim Form.
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No. Unless you exclude yourself, you give up any right to sue Defendants and the other Released Parties for the claims that this Settlement resolves. You must exclude yourself from this Litigation to start or continue with your own lawsuit or be part of any other lawsuit against Defendants or any of the other Released Parties. If you have a pending lawsuit, speak to your lawyer in that case immediately.
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You can ask the Court to deny approval of the Settlement by filing an objection. You cannot ask the Court to order a different Settlement; the Court can only approve or reject the Settlement.
Any objection to the proposed Settlement must be in writing. If you file a timely written objection, you may, but are not required to, appear at the Final Approval Hearing, either in person or through your own attorney. If you appear through your own attorney, you are responsible for hiring and paying that attorney. For an objection to be considered by the Court, the objection must also set forth:
the objector’s full name, mailing address, telephone number, and email address (if any);
the name and number of this case, Morelli, et al. v. Rhode Island Public Transit Authority, et al., No. PC-2022-6145;
information identifying the objector as a Settlement Class Member, including proof that the objector is a member of the Settlement Class;
a statement as to whether the objection applies only to the Settlement Class Member, to a specific subset of the Settlement Class, or to the entire class;
a clear and detailed written statement of the specific legal and factual bases for each and every objection, accompanied by any legal support for the objection the objector believes applicable;
the identity of any counsel representing or advising the objector;
a statement whether the objector intends to appear at the Final Approval Hearing, either in person or through counsel, and, if through counsel, identifying that counsel;
a list of all persons who will be called to testify at the Final Approval Hearing in support of the objections and any documents to be presented or considered; and
the objector’s personal and original signature and the signature of the objector’s duly authorized attorney or other duly authorized representative (if any).
For an objection to be considered, it must be filed with the Court no later than July 25, 2025. Copies of the objection must also be sent to Settlement Class Counsel and Defendants’ Counsel with a postmark date no later than July 25, 2025.
Settlement Class Counsel | Counsel for RIPTA | Counsel for UHC |
Peter N. Wasylyk Esq. | Edward J. McAndrew, Esq. | Gavin Reinke, Esq. |
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Objecting is telling the Court you do not like something about the Settlement. You can object only if you stay in the Settlement Class (that is, do not exclude yourself). Requesting exclusion is telling the Court you do not want to be part of the Settlement Class or the Settlement. If you exclude yourself, you cannot object to the Settlement because it no longer affects you.
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The Court will hold a Final Approval Hearing on September 23, 2025, at 10:00 a.m., at 250 Benefit Street, Providence, Rhode Island.
The date and time of the Final Approval Hearing is subject to change without further notice to the Settlement Class, so please check this website for updates.
At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, and will decide whether to approve the Settlement, Settlement Class Counsel’s Application for Attorneys’ Fees and Costs, and the Service Awards for the Representative Plaintiffs. If there are objections, the Court will consider them. The Court will also listen to people who have asked to speak at the hearing.
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No. Settlement Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you submitted a timely and complete objection, the Court will consider it, and you do not have to come to Court to talk about it.
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Yes. If you wish to attend and speak at the Final Approval Hearing, you must indicate this in your written objection (see FAQ 22). Your objection must state that it is your intention to appear at the Final Approval Hearing and must identify any witnesses you may call to testify or exhibits you intend to introduce into evidence at the Final Approval Hearing. If you plan to have your attorney speak for you at the Final Approval Hearing, your objection must also include your attorney’s name, address, email address, and phone number.
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If you are a Settlement Class member and you do nothing, you will not receive any Settlement Class Member Benefits. You will also give up certain rights, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendants or any of the other Released Parties about the legal issues in this Litigation and released by the Settlement Agreement.
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This website summarizes the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement which is, along with other case relevant documents, available in the Important Documents page. You may also contact the Claims Administrator by mail or email:
RIPTA/UHC Data Incident Settlement
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
info@CyberIncidentSettlement.com
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