Frequently Asked Questions

The Court authorized a Notice of a proposed Settlement (the “Settlement”) of a class action lawsuit (the “Litigation”), Doe v. Workit Health, Inc., Case No. 2:23-cv-11691-LVP-DRG, pending in the U.S. District Court for the Eastern District of Michigan (the “Court”). The Settlement would resolve the Litigation alleging that Workit Health, Inc.’s (“Workit”) implementation and use of certain third-party website technologies (“Third-Party Technologies”), including the Meta Pixel and Google Analytics, on its website at www.workithealth.com, and a web-based app webform at https://app.workithealth.com (collectively, “Website”), as well as mobile applications (“Applications”), may have led to the disclosure of certain personal or health-related information to third-party vendors (the “Third-Party Disclosure”). The Court has granted Preliminary Approval of the Settlement Agreement and has conditionally certified the Settlement Class for purposes of Settlement only. The Long-Form Notice explains the nature of the Litigation, the terms of the Settlement Agreement, and the legal rights and obligations of members of the Settlement Class. Please read the instructions and explanations below carefully so that you can better understand your legal rights. The Settlement Administrator in this case is EisnerAmper LLP.

You were identified as a person who may have used Workit’s Website or Applications, and thus, Plaintiff alleges in this Litigation that information about your actions on those digital platforms may have been accessible or disclosed to third parties, like Google.

The Litigation arises out of Workit’s alleged implementation and use of the Third-Party Technologies on its Website and Applications, which Plaintiff contends resulted in certain information being shared with Google, allegedly resulting in an invasion of Plaintiff’s and Settlement Class Members’ privacy.

A class action is a lawsuit in which an individual called a “Class Representative” brings a single lawsuit on behalf of other people who have similar claims. In a class action settlement, all of these people together are a “Settlement Class” or “Settlement Class Members.” When a class action is settled, the Settlement, which must be approved by the Court, resolves the claims for all Settlement Class Members, except for those who exclude themselves from the Settlement.

To resolve this matter without the expense, delay, and uncertainties of protracted litigation, the Parties reached a Settlement that, if approved by the Court, would resolve all claims brought on behalf of the Settlement Class related to Workit’s use of Third-Party Technologies on its Website and Applications. If approved by the Court, the Settlement Agreement provides for cash compensation from Workit to Settlement Class Members who submit valid and timely Claim Forms. Workit denies that it did anything wrong or that any personal or health-related information was actually disclosed to third-parties, and the Settlement is not an admission of wrongdoing by Workit and does not imply that there has been, or would be, any finding that Workit violated the law. Further, the Court overseeing the Litigation has not determined that Workit did anything wrong.

The Court already has preliminarily approved the Settlement Agreement. Nevertheless, because the settlement of a class action determines the rights of all members of the Settlement Class, the Court overseeing this Litigation must give final approval to the Settlement Agreement before it can be effective. The Court has conditionally certified the Settlement Class for settlement purposes only, so that members of the Settlement Class may be given notice and the opportunity to exclude themselves from the Settlement Class or to voice their support or opposition to final approval of the Settlement Agreement. If the Court does not grant final approval to the Settlement Agreement, or if it is terminated by the Parties, then the Settlement Agreement will be void, and the Litigation will proceed as if there had been no settlement and no certification of the Settlement Class.

You are a member of the Settlement Class if you used Defendant’s Website or Application (both web-based and mobile) to search for medical information, services or physicians, fill out forms, schedule appointments, sign-up for membership, register for programs or support groups, or pay for medical services between June 1, 2017 and November 23, 2022.

Excluded from the Settlement Class are: (i) Workit, any entity in which Workit has a controlling interest, and Workit’s affiliates, parents, subsidiaries, officers, directors, legal representatives, successors, subsidiaries, and assigns; (ii) any judge, justice, or judicial officer presiding over the Litigation and the members of their immediate families and judicial staff; and (iii) any individual who timely and validly excludes themselves from the Settlement.

Settlement Class Members who file a valid and timely Claim Form may receive a pro rata cash payment from the Net Settlement Fund. The Net Settlement Fund is what remains of the $578,680 Settlement Fund following the payment of Notice and Settlement Administration Costs, Class Representative Service Award ($2,500 per Class Representative), and Attorneys’ Fees and Expenses Award (fees up to one third of the Settlement Fund or $192,893 plus expenses up to $15,000), subject to the Court’s approval.

***To receive Settlement benefits, you must submit a Claim Form by December 23, 2024***

If you timely submit a valid Claim Form for a cash payment, you will receive payment in the amount approved by the Settlement Administrator once the Settlement is Final and has become effective.

All Settlement Class Members are part of the Settlement unless they request to be excluded from it. To submit a claim for cash compensation, you must timely submit the Claim Form on the Settlement Website at www.WHPrivacySettlement.com, or by mail to In re: Workit Health, Inc. c/o EisnerAmper LLP, P.O. Box 591, Baton Rouge, LA 70821.

You must submit any claims by December 23, 2024. There can be only one (1) valid and timely Claim per Settlement Class Member.

By staying in the Settlement Class, you will give Workit a “release,” and all the Court’s orders will apply to you and bind you. A release means you cannot sue or be part of any other lawsuit or other legal action against Workit about or arising from the claims or issues in this Litigation, including Workit’s use of Third-Party Technologies on Website and Applications.

The precise terms of the release are in the Settlement Agreement, which is available on the Settlement Website. Unless you formally exclude yourself from this Settlement, you will release your claims. If you have any questions, you can talk for free to Class Counsel identified below who have been appointed by the Court to represent the Settlement Class, or you are welcome to talk to any other lawyer of your choosing at your own expense.

To exclude yourself from the Settlement, you must send a letter by mail stating that you want to be excluded from Doe v. Workit Health, Inc., Case No. 2:23-cv-11691-LVP-DRG (E.D. Mich.) to the Settlement Administrator. Such notice must include: (1) the case name and number of the Litigation (Doe v. Workit Health, Inc., Case No. 2:23-cv-11691-LVP-DRG (E.D. Mich.); (2) your full name, address, and telephone number; (3) your personal and original signature; and (4) a written statement that you wish to be excluded from the Settlement. You may only request exclusion for yourself, and no one else can request exclusion for you. You must mail your exclusion request so that it is postmarked no later than December 23, 2024, to:

In re: Workit Health, Inc.
c/o EisnerAmper LLP
P.O. Box 591
Baton Rouge, LA 70821

No, if you submit an exclusion request, you will not receive anything from the Settlement, but you retain your right to sue Workit over the claims raised in the Litigation.

The Court has appointed the following attorneys to represent the Settlement Class as Class Counsel:

Class Counsel

David S. Almeida
Almeida Law Group LLC
849 W. Webster Avenue
Chicago, Illinois 60614
Tel: 312.576.3024

Nicholas A. Coulson
Coulson P.C
300 River Place Drive, Suite 1700
Detroit, Michigan 48207
Tel: (313) 644-2685

If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel will be paid from the Settlement Fund. Class Counsel will seek Court approval to be paid reasonable attorneys’ fees up to one-third of the Settlement Fund, plus their expenses incurred in the Litigation up to $15,000. The motion for attorneys’ fees and expenses will be posted on the Settlement Website after it is filed.

If you are a Settlement Class Member, you can object to the Settlement, or some part of it, and the Court will consider your views. In order to object to the Settlement, you must submit a written objection (such as a letter or legal brief) stating that you object and the reasons why you think the Court should not approve some or all of the Settlement. Your objection must include: (i) the case name and number of the Litigation; (ii) set forth the Settlement Class Member’s full name, current address, telephone number, and email address; (iii) contain the Settlement Class Member’s personal and original signature; (iv) if the objecting Settlement Class Member is represented by an attorney, or received assistance from an attorney in drafting his or her objection, the name, address, telephone number, and email address of the attorney; (v) contain a statement indicating the basis for the objecting Settlement Class Member’s belief that he or she is a member of the Settlement Class; (vi) state whether the objection applies only to the Settlement Class Member, to a specific subset of the Settlement Class, or to the entire Settlement Class; (vii) set forth a statement of the legal and/or factual basis for the Objection; and (viii) state whether the objecting Settlement Class Member intends to appear at the Final Approval Hearing, and if so, whether personally or through counsel. 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 attorney.

If you file an objection, you may still receive benefits under the Settlement so long as you timely file a valid claim. To be timely, written notice of an objection in the appropriate form described above must be filed with the Court no later than the Objection Deadline, as noted below:

United States District Court for the Eastern District of Michigan
Clerk’s Office
Theodore Levin U.S. Courthouse
231 W. Lafayette Blvd., Room 599
Detroit, MI 48226

The Court has already given Preliminary Approval to the Settlement Agreement. A final hearing on the Settlement, called a Final Approval Hearing, will be held to determine the fairness of the Settlement Agreement.

The Court will hold a hearing on February 6, 2025, at 2:00 p.m. in the courtroom of the Honorable Linda V. Parker, Courtroom 206, which is located at 231 W. Lafayette Blvd, Detroit, MI 48226. The purpose of the hearing will be for the Court to determine whether the proposed Settlement is fair, reasonable, and adequate and in the best interests of the Settlement Class and to determine the appropriate amount of compensation for Class Counsel and rule on the request for a Service Award for the Class Representative. At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the proposed Settlement. The Court will then decide whether to approve the Settlement.

YOU ARE NOT REQUIRED TO ATTEND THE FINAL APPROVAL HEARING TO RECIEVE BENEFITS FROM THIS SETTLEMENT. Please be aware that the hearing may be postponed to a later date without notice.