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A Court authorized this Settlement Website because you have a right to know about the proposed Settlement of this Action and about all your options before the Court decides whether to grant final approval of the Settlement. This Settlement Website explains the Action, your legal rights, what Settlement Benefits are available, and who can receive them.
The Action is called In re Lemonade, Inc. Data Disclosure Litigation, Case No. 1:25-cv-04106-JHR-KHP and is pending in the United States District Court for the Southern District of New York. The people who filed this Action are called the “Plaintiffs” and the companies they sued, Lemonade, Inc. and Lemonade Insurance Agency, LLC, are called the “Defendants.”
This Action alleges that Personal Information (e.g., driver’s license numbers) was potentially disclosed and/or accessed between April 2023 and September 18, 2024, when cybercriminals entered unauthorized information into the Defendants’ online insurance quote system. Among other things, the Action asserts claims against the Defendants for negligence, violation of the Driver’s Privacy Protection Act, and violation of the New York General Business Law Section 349.
The Defendants deny they did anything wrong and dispute they have any liability, but have agreed to settle this lawsuit on a class-wide basis.
In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals who sue are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class action are called a “Settlement Class” or “Settlement Class Members.” One court resolves the lawsuit for all Settlement Class Members, except for those who exclude themselves (sometimes called, “opting out”) from a settlement. In this Settlement, the Class Representatives are Brian Murray and Leslie Linwood Rich.
The Court did not decide in favor of the Plaintiffs or Defendants. The Defendants deny all claims and contend that they have not violated any laws. The Plaintiffs and Defendants agreed to a Settlement to avoid the costs and risks of a trial, and through the Settlement, Settlement Class Members are eligible to claim a payment and other benefits. The Plaintiffs and their attorneys, who also represent Settlement Class Members, think the Settlement is best for all Settlement Class Members.
The Settlement Class consists of all living, natural persons residing in the United States whose Personal Information was compromised in the Data Exposure, including all persons who were sent notice of the Data Exposure. The Settlement Class consists of approximately 190,000 individuals.
Yes, excluded from the Settlement Class are: (1) the Judge(s) presiding over the Action and members of their immediate families and their staff; (2) Lemonade, its subsidiaries, parent companies, successors, predecessors, and any entity in which Lemonade or its parents, have a controlling interest, and its current or former officers and directors; (3) natural persons who properly execute and submit a Request for Exclusion prior to the expiration of the Opt-Out Period; and (4) the successors or assigns of any such excluded natural person.
If approved by the Court, the Defendants will pay $10,500,000 into a Settlement Fund to resolve the Settlement. In addition to the cash benefits below, all Settlement Class Members have been provided with a unique code to activate three years of Credit Monitoring and Insurance Services (“CMIS”). This is an automatic benefit to all Settlement Class Members except those who submit a Request for Exclusion from the Settlement. Once the Settlement receives final approval, Settlement Class Members will be able to enroll in the CMIS product provided under this Settlement using their CMIS code (see FAQ 10). Enrollment and activation of CMIS services will be available only after the Court grants final approval of the Settlement. Instructions on how to activate the code will be provided on this Settlement Website after the Settlement has been approved by the Court.
Settlement Class Members may choose to receive one or both of the following benefit payments in addition to the CMIS services:
- Documented Loss Payment: Reimbursement of up to $10,000 for Documented Losses on or after April 1, 2023, that are more likely than not traceable to the Data Exposure; and
- Cash Fund Payment: A pro rata (proportional) cash payment.
- Documented Loss Payment: Reimbursement of up to $10,000 for Documented Losses on or after April 1, 2023, that are more likely than not traceable to the Data Exposure; and
Settlement Class Members may submit a claim for a Settlement Payment of up to $10,000 for reimbursement of a Documented Loss. To receive a Documented Loss Payment, a Settlement Class Member must submit a valid Claim Form choosing to receive the Documented Loss Payment, including an attestation regarding any actual and unreimbursed Documented Loss made under penalty of perjury; and provide Reasonable Documentation that demonstrates the Documented Loss to be reimbursed is more likely than not traceable to the Data Exposure. Compensable Documented Losses must have occurred on or after April 1, 2023. “Self-prepared” documents such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but can be considered to add clarity to or support other submitted Reasonable Documentation.
If a Claimant does not submit Reasonable Documentation supporting a Documented Loss claim, or if a claim for a Documented Loss payment is entirely rejected for any reason, and the Claimant fails to cure their claim, the Documented Loss claim will be rejected and Claimant will instead be automatically placed into the Cash Fund Payment category to receive a pro rata cash Settlement Payment at the discretion of the Settlement Administrator.In addition to the Documented Loss Payment, Settlement Class Members may also submit a claim to receive a pro rata (proportional) Settlement Payment in cash (i.e., a “Cash Fund Payment”).
After deducting Administrative Expenses, Fee Award and Costs, Service Awards, Escrow fees, and Taxes, the balance of the Settlement Fund or Net Settlement Fund (the "Net Settlement Fund") will be used to pay the cost of CMIS and Approved Claims for Documented Loss Payments. The amount of the Net Settlement Fund remaining after these deductions (the “Post CM/DL Net Settlement Fund”) will be used to make Cash Fund Payments to Settlement Class Members who submit a valid claim selecting this Settlement Benefit. The description of the Cash Fund Payment calculation can be found in Section 3.10 of the Settlement Agreement. A copy of the Settlement Agreement is available on the Documents page of this Settlement Website.
In addition to selecting one or both of the Settlement Payment options, all Settlement Class Members will receive a unique code to activate three years of the CMIS product. The CMIS product will include at least the following services: (1) up to $1 million dollars of identity theft insurance coverage; and (2) three bureau credit monitoring.
CMIS codes have been provided to all Settlement Class Members in the Notice (i.e., in the postcard Notice). Settlement Class Members who do not know their CMIS code should use the Contact Us form on this Settlement Website or mail the Settlement Administrator at the address below to request that information:
In re Lemonade, Inc. Data Disclosure Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
Once the Settlement receives final approval, Settlement Class Members will be able to activate the CMIS product using their unique CMIS code. Enrollment and activation of CMIS services will be available only after the Court grants final approval of the Settlement.
Settlement Class Members are not required to submit a Claim Form to receive this Settlement Benefit. It is being distributed automatically as part of the Notice.
Unless you opt out of the Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against the Defendants about any of the legal claims this Settlement resolves. The Releases section in the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The Settlement Agreement can be found on the Documents page of this Settlement Website.
You must submit a Claim Form by September 8, 2026. Claim Forms may be submitted online by clicking here and completing the Claim Form by 11:59 p.m. ET, or mailed postmarked by September 8, 2026, to the Settlement Administrator at:
In re Lemonade, Inc. Data Disclosure Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391The short answer is – after the Settlement is “finally approved” and any challenges to that approval are finally resolved. The Court is scheduled to hold a Final Approval Hearing on September 10, 2026, at 10:00 a.m. ET, at the Daniel Patrick Moynihan U.S. Courthouse, 500 Pearl Street, New York, NY 10007-1312, Courtroom 17D, to decide whether to approve the Settlement and consider the amount of the attorneys’ Fee Award and Costs to award Class Counsel for representing the Settlement Class and the Service Award payments to the Class Representatives who brought this Action on behalf of the Settlement Class.
If the Court approves the Settlement, there may be appeals. It is always uncertain whether appeals will be filed and, if so, how long it will take to resolve them. Settlement Benefits will be distributed as soon as possible, if and when the Court grants final approval of the Settlement and after any appeals are resolved.
Yes, the Court appointed Melissa R. Clark and Andrew W. Ferich of Ahdoot & Wolfson, PC, Mark B. DeSanto and E. Michelle Drake of Berger Montague PC, and John A. Yanchunis and Ronald Podolny of Morgan & Morgan Complex Litigation Group, to represent you and other members of the Settlement Class as "Class Counsel." You will not be charged directly for these lawyers; instead, they will receive compensation from the Settlement Fund (subject to Court approval).
If you want to be represented by your own lawyer, you may hire one at your own expense.
It is not necessary for you to hire your own lawyer because Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense.
Class Counsel will ask the Court to approve attorneys’ fees of up to one-third (33 1/3 %) of the Settlement Fund (i.e., $3,500,000), separate reimbursement of litigation expenses and costs incurred as a necessity of prosecuting this matter, as well as a $2,000 Service Award payment to each of the Class Representatives. If approved, these amounts will be paid from the Settlement Fund before making payments to Settlement Class Members who submit valid claims.
If you do not want to receive any benefits from the Settlement, and you want to keep your right to separately sue the Defendants about the legal issues in this Action, you must take steps to exclude yourself from the Settlement Class. This is called “opting out” of the Settlement Class. The Opt-Out Deadline to submit a “Request for Exclusion” from the Settlement is August 7, 2026.
To exclude yourself from the Settlement, you must submit a written Request for Exclusion to the Settlement Administrator that includes the following information:
- the case name “In re Lemonade, Inc. Data Disclosure Litigation”;
- your name, address, telephone number, and Class Member ID;
- a statement indicating that you want to be excluded from the Settlement Class, such as “I hereby request to be excluded from the proposed Settlement Class in ‘In re Lemonade, Inc. Data Disclosure Litigation.’”;
- identify the lawyer representing you (if any); and
- your personal signature or the signature of your legal guardian or representative.
Your Request for Exclusion must be mailed to the Settlement Administrator at the address below, postmarked no later than August 7, 2026.
In re Lemonade, Inc. Data Disclosure Litigation
c/o Kroll Settlement Administration LLC
ATTN: Exclusion Request
P.O. Box 225391
New York, NY 10150-5391
A Request for Exclusion that is sent to an address other than that designated as the Settlement Administrator’s address above, shall be invalid and the person serving such a request shall be considered a member of the Settlement Class and shall be bound by the terms of the Settlement.
If you are a Settlement Class Member, you can choose (but are not required) to object to the Settlement if you do not like it or a portion of it, whether that be to the Settlement Benefits, the request for attorneys’ Fee Award and Costs, or Service Award payments, the Releases provided to the Defendant, or some other aspect of the Settlement. You cannot ask the Court to order a different settlement; the Court can only approve or reject this Settlement. If the Court denies approval, no Settlement Payments will be sent out, and the lawsuit will continue. Through an objection, you give reasons why you think the Court should not approve the Settlement.
For an objection to be considered by the Court, the objection must be in writing and include:
- the case name and number (i.e., In re Lemonade, Inc. Data Disclosure Litigation, Case No. 1:25-cv-04106-JHR-KHP);
- your full name, current mailing address, and telephone number;
- a statement indicating that you believe you are a member of the Settlement Class;
- proof that you are a member of the Settlement Class (e.g., copy of the settlement notice, copy of the original notice of the Data Exposure);
- the specific factual and legal grounds for the objection;
- whether the objection is an objection to the Settlement in part or in whole;
- whether the objection applies only to you, a subset of the Settlement Class, or the entire Settlement Class;
- all counsel representing you, if any;
- a list, including case name, court, and docket number, of all other cases in which you and/or your counsel have filed an objection to any proposed class action settlement in the past five (5) years;
- all documents or writings that you want the Court to consider;
- a statement regarding whether you (or counsel of your choosing) intends to appear at the Final Approval Hearing; and
- your personal signature or the signature of your duly authorized attorney or representative.
Objections must be filed with or mailed to the Court no later than August 7, 2026.
THE COURT Daniel Patrick Moynihan United States Courthouse
500 Pearl Street
New York, NY 10007-1312
A copy of your objection also must be mailed to Class Counsel, Defendants’ Counsel, and the Settlement Administrator at the addresses below, postmarked no later than August 7, 2026.
CLASS COUNSEL Melissa R. Clark
Ahdoot & Wolfson, PC
521 5th Avenue, 17th Floor
New York, NY 10175Mark B. DeSanto
Berger Montague PC
1818 Market Street
Suite 3600
Philadelphia, PA 19103John A. Yanchunis
Ronald Podolny
Morgan & Morgan Complex Litigation Group
201 N. Franklin Street
7th Floor
Tampa, FL 33602DEFENDANTS’ COUNSEL SETTLEMENT ADMINISTRATOR Tiana A. Demas
Anne Bigler
Cooley LLP
55 Hudson Yards
New York, NY 10001In re Lemonade, Inc. Data Disclosure Litigation
c/o Kroll Settlement Administration LLC
ATTN: Objections
P.O. Box 225391
New York, NY 10150-5391Objecting 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 it. Excluding yourself from the Settlement means telling the Court you do not want to be part of the Settlement. If you exclude yourself or opt out of the Settlement, you cannot object to it because the Settlement no longer affects you.
The Court is scheduled to hold a Final Approval Hearing on September 10, 2026, at 10:00 a.m. ET, at the Daniel Patrick Moynihan U.S. Courthouse, 500 Pearl Street, New York, NY 10007-1312, Courtroom 17D, to decide whether to approve the Settlement, how much attorneys’ Fee Award and Costs to award to Class Counsel for representing the Settlement Class, and whether to approve Service Awards to the Class Representatives who brought this Action on behalf of the Settlement Class.
The date and time of this hearing may change without further notice. Please check this Settlement Website for updates.No. Class Counsel will answer any questions the Court may have. You may attend at your own expense. If you file an objection, you may, but you do not have to, come to the Final Approval Hearing to talk about it. If you file your written objection on time and in accordance with the requirements in FAQ 18, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.
If you are a Settlement Class Member and you do nothing, you will give up your right to start a lawsuit, continue a lawsuit, or be part of any other lawsuit against the Defendants and the Released Parties, as defined in the Settlement Agreement, about the legal issues resolved by this Settlement. In addition, you will be bound by the Released Claims of the Released Parties in the Settlement and will not be eligible to receive a Settlement Payment, but you will still be able to activate your unique Credit Monitoring and Insurance Services code to receive the CMIS Settlement Benefit. Enrollment and activation of CMIS services will be available only after the Court grants final approval of the Settlement.
This Settlement Website summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available on the Documents page of this Settlement Website.
If you have additional questions, click here or call toll-free (833) 447-6429. If you need to update your address, you may contact the Settlement Administrator using the Contact Us form on this Settlement Website, or by mail:
In re Lemonade, Inc. Data Disclosure Litigation
c/o Kroll Settlement Administration LLC
P.O. Box 225391
New York, NY 10150-5391
PLEASE DO NOT CONTACT THE COURT OR DEFENDANTS.
THEY CANNOT ANSWER ANY QUESTIONS.
This Settlement Website is authorized by the Court, supervised by counsel for the Parties, and controlled by the Settlement Administrator approved by the Court. This is the only authorized Settlement Website for this case.
PLEASE DO NOT CONTACT THE COURT OR DEFENDANTS.
THEY CANNOT ANSWER ANY QUESTIONS.
| For More Information: | |
|---|---|
| Call | (833) 447-6429 |
| Write | Click here to contact us |
| In re Lemonade, Inc. Data Disclosure Litigation c/o Kroll Settlement Administration LLC P.O. Box 225391 New York, NY 10150-5391 | |
This Settlement Website is authorized by the Court, supervised by counsel for the Parties, and controlled by the Settlement Administrator approved by the Court. This is the only authorized Settlement Website for this case.
PLEASE DO NOT CONTACT THE COURT OR DEFENDANTS.
THEY CANNOT ANSWER ANY QUESTIONS.
| For More Information: | |
|---|---|
| Call | (833) 447-6429 |
| Write | Click here to contact us |
| In re Lemonade, Inc. Data Disclosure Litigation c/o Kroll Settlement Administration LLC P.O. Box 225391 New York, NY 10150-5391 | |