1. Why was a notice issued?
2. What is this lawsuit about?
3. What is a class action?
4. Why is there a settlement?
5. Who is included in the Settlement?
6. Are there exceptions to being included?
7. What does the Settlement provide?
8. What claims am I releasing if I stay in the Class?
9. How do I submit a claim for a Settlement benefit?
10. Are there any important Settlement payment deadlines?
11. When will the Settlement benefits be issued?
12. Do I have a lawyer in the case?
13. Should I get my own lawyer?
14. How will Class Counsel be paid?
15. How do I opt-out of the Settlement?
16. How do I tell the Court if I like or do not like the Settlement?
17. What is the difference between objecting and excluding?
18. When is the Court’s Final Approval Hearing?
19. Do I have to come to the Final Approval Hearing?
20. What happens if I do nothing at all?
21. How do I get more information?
The District Court for Yellowstone County, Montana, authorized a notice. You have a right to know about the proposed Settlement of this class action lawsuit, and about all of your options, before the Court decides whether to grant Final Approval of the Settlement. The Notice explains the lawsuit, your legal rights, what benefits are available, and who can receive them.
The lawsuit is called Nicole Downey & Sarah Suzanne Sullivan v. Intermountain Planned Parenthood, Inc. d/b/a Planned Parenthood of Montana, Case No. DV-56-2025-0000836-OC. It is pending in the Thirteen Judicial District Court for Yellowstone County, Montana. The people that filed the Action are called the “Plaintiffs” and the company they sued, Intermountain Planned Parenthood, Inc. d/b/a Planned Parenthood of Montana, is called the “Defendant.”
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This lawsuit alleges that in September 2024, Defendant became aware of a cybersecurity incident that occurred on or around August 28, 2024, involving a criminal third party gaining unauthorized access to Defendant’s network. The Data Incident may have impacted Settlement Class Members’ Private Information. This information may include names, addresses, dates of birth, medical record numbers, health insurance information, provider names, dates of service, diagnosis information, treatment information, and prescription information.
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In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are called the “Plaintiffs” or “Class Representatives.” Together, the people included in the class action are called a “Class” or “Settlement Class Members.” One court resolves the lawsuit for all Settlement Class Members, except for those who opt-out of the settlement. In this Settlement, the Class Representatives are Nicole Downey and Sarah Sullivan, and everyone included in this Action are the Settlement Class Members.
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The Court did not decide whether the Plaintiffs or the Defendant are right. Both sides have agreed to a Settlement to avoid the costs and risks of a trial, and to allow the Settlement Class Members to receive benefits from the Settlement. The Plaintiffs and their attorney think the Settlement is best for all Settlement Class Members.
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The Court has defined the Settlement Class this way: “All living individuals in the United States who received Notice, including notice of this Settlement, that their Private Information may have been impacted in the Data Incident.”
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Yes. Excluded from the Settlement Class are: (1) the Judge in this case, and the Judge’s family and staff, (2) PPMT and its officers and directors; (3) anyone who validly excludes themselves from the Settlement; (3) government entities; and (4) anyone who perpetrated the Data Incident.
If you are not sure whether you are a Settlement Class Member, you can ask for free help any time by contacting the Settlement Administrator at:
PPMT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
(833) 417-4890
info@PPMTSettlement.com
You may also view the Settlement Agreement here.
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All Settlement Class Members may submit a claim to receive 1) Medical Data Monitoring; and 2) reimbursement for documented out-of-pocket losses and/or lost time.
Medical Data Monitoring. All Settlement Class Members are eligible to enroll in two years of CyEx Medical Shield Pro. This comprehensive service comes with $1 million of medical identity theft insurance, and includes monitoring for:
healthcare insurance ID exposure
Medical Record Number (MRN) exposure
unauthorized Health Savings Account (HSA) spending
If you suffer medical identity fraud, a dedicated case manager will help you fix it.
Documented Out-of-Pocket Losses. If you incurred actual, documented out-of-pocket losses traceable to the Data Incident, you may submit a claim, not to exceed $5,000.00. The losses must have occurred between September 6, 2024, and January 12, 2026.
This benefit covers out-of-pocket expenses like:
losses because of identity theft or fraud
fees for credit reports, credit monitoring, or freezing and unfreezing your credit
cost to replace your IDs
postage to contact banks by mail
You need to send documented proof, like bank statements or receipts, to show how much you spent or lost. You can also send notes or papers you made yourself to explain or support other proof, but those notes or papers alone are not enough to make a valid claim.
Lost Time. If you spent time responding to the Data Incident, you may claim up to four hours of your lost time, at $20.00 per hour, for a maximum of $80.00.
You must have spent the time on tasks related to the Data Incident. Some examples include things like:
changing your passwords
investigating suspicious activity in your accounts
researching the Data Incident
If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at:
PPMT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
(833) 417-4890
info@PPMTSettlement.com
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If you stay in the Settlement Class, you won’t be able to be part of any other lawsuit against Defendant or the Released Parties for any of the Released Claims. The “Releases” section of the Settlement Agreement (Section XI) describes the legal claims that you give up if you remain in the Settlement Class. The Settlement Agreement is available here.
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The fastest way to submit your Claim Form is online here . If you prefer, you can download a printable Claim Form here and mail it to the Settlement Administrator at:
PPMT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (833) 417-4890, by email info@PPMTSettlement.com, or by U.S. mail at the address above.
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If you are submitting a Claim Form online, you must do so by January 12, 2026. If you are submitting a claim by U.S. mail, the completed and signed Claim Form, including supporting documentation, must be postmarked no later than anuary 12, 2026.
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The Court will hold a final approval hearing on December 15, 2025 (see Question 18). If the Court approves the Settlement, there may be appeals. We do not know if appeals will be filed, or how long it will take to resolve them if they are filed. Settlement payments will be distributed if the Court grants final approval, and after any appeals are resolved.
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Yes, the Court has appointed attorney John Heenan of Heenan & Cook, PLLC, to represent you and other Settlement Class Members (“Class Counsel”).
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You will not be charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense.
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Class Counsel will ask the court to approve $400,000.00 for attorney's fees and costs. If approved, these fees and costs will be paid by the Defendant.
Class Counsel will also ask for Service Awards of $2,500.00 for each of the Class Representatives, not to exceed $5,000.00. Any approved Service Awards will be paid by the Defendant.
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If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement. This is called a Request for Exclusion and is sometimes also called “opting-out.” If you opt-out, you will not receive any Settlement Class Member Benefits. However, you will keep any rights you may have to sue PPMT on your own about the legal issues in this case.
If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You will not be eligible to receive any Settlement benefits if you exclude yourself. The deadline to exclude yourself from the Settlement is December 13, 2025.
To be valid, your Request for Exclusion must have the following information:
the name of the Action: Downey & Sullivan v. Intermountain Planned Parenthood, Inc. d/b/a Planned Parenthood of Montana, Cause No. DV-56-2025-0000836-DC, pending in the Thirteenth Judicial District Court for Yellowstone County, Montana;
your full name, mailing address, telephone number, and email address;
personal signature; and
the words "Request for Exclusion" or a clear and similar statement that you do not want to participate in the Settlement.
You may only exclude yourself—not any other person.
Mail your Request for Exclusion to the Settlement Administrator at:
PPMT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be postmarked by December 13, 2025.
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If you are a Settlement Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons why you think the Court should not approve the Settlement. The Court will consider your views.
You cannot object if you have excluded yourself from the Settlement (see Question 15)
You must provide the following information for the Court to consider your objection:
the name of the Action: Downey & Sullivan v. Intermountain Planned Parenthood, Inc. d/b/a Planned Parenthood of Montana, Cause No. DV-56-2025-0000836-OC, pending in the Thirteenth Judicial District Court for Yellowstone County, Montana;
your full name, mailing address, telephone number, and email address;
a clear description of all the reasons you object; include any legal support you may have for your objection;
if you have hired your own lawyer to represent you at the Final Approval Hearing, provide their name and telephone number;
if you or your lawyer have objected in any other cases in the past five years, list the names, courts, civil action numbers, and order that ruled on your objection for each of those cases;
whether or not you or your lawyer would like to speak at the Final Approval Hearing;
if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a full list of both; and
your signature (if you have hired your own lawyer, your lawyer's signature is not sufficient).
For your objection to be valid, it must meet each of these requirements.
Class Counsel or Defendant’s Counsel may take limited discovery of the objector related to the objection, including the taking of the objector’s deposition or requiring the objector to produce documents.
To be considered by the Court, you must file your complete objection with the Clerk of Court by December 13, 2025. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and Counsel for Defendant.
Clerk of the Court | Settlement Administrator |
Clerk of the Court | PPMT Data Incident Settlement |
Class Counsel | Counsel for Defendant |
John Heenan | Casie D. Collignon |
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Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you do not exclude yourself from the Settlement. Excluding yourself from the Settlement is opting out and stating to the Court that you do not want to be part of the Settlement. If you opt-out of the Settlement, you cannot object to it because the Settlement no longer affects you.
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The Court will hold a Final Approval Hearing on December 15, 2025 at 1:30 p.m. Mountain Time, in the District Court of Yellowstone County, Montana or by virtual or telephonic means. At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The Court will also decide whether to approve Class Counsel request for attorneys’ fees and costs and whether to award Service Awards to the Class Representatives. The Court will also consider any objections to the Settlement.
If you are a Settlement Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see Question 16).
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No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish, but you do not have to.
If you file an objection, you do not have to come to the Final Approval Hearing to talk about it; the Court will consider it as long as it was filed on time. You may also pay your own lawyer to attend, but you do not have to.
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If you do nothing, you will not receive any benefits from this Settlement. You will also give up the rights described in Question 8.
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The full Settlement Agreement and other related documents are available on the Important Documents page. If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at:
PPMT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
(833) 417-4890
info@PPMTSettlement.com
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court.
Do not contact the Court or Clerk of the Court regarding this Settlement.
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