Notice of Settlement

A  Settlement  has  been  proposed   in  a  class  action  lawsuit  against  Sincera  Reproductive   Medicine   (“Defendant”   or “Sincera”). The  Settlement  resolves  claims  brought  by patients  impacted by the data  incident which occurred  between August  10, 2020  and September  13, 2020 and resulted  in the potential compromise  of patients’  Personally  Identifying Information (‘‘PII”) and Protected Health Information (“PHI”) (the “Data Incident”).  Defendant  denies any allegation  of wrongdoing.

Who’s Included? You are included in the Settlement as a “Settlement Class Member” if you received a notice from Sincera in or around May 2021  that your PII and/or PHI may have been accessed or exposed during the Data Incident.

What does the Settlement provide? Under the Settlement,  Sincera will pay all valid claims made by Settlement Class Members,  notice and administration  costs,  service awards,  and attorneys’  fees and costs. Sincera will not pay less than $800,000 or more than $1,200,000. Settlement Class Members may file a claim to receive a $150 cash payment, as well as reimbursement  for out-of-pocket expenses of up to $2,000 (inclusive of the $150 cash payment).

How do I get a Payment? You must complete and submit a Claim Form by July 24, 2023. Claim Forms may be submitted online at wwww.SinceraSettlement.com or printed from the website and mailed to the address on the form.

What are my other options? If you do nothing, your rights will be affected  and you won’t get a payment. If you don’t want to be legally bound by the Settlement,  you must exclude yourself from it by June 23, 2023. Unless you exclude yourself, you won’t be able to sue or continue to sue Sincera for any claim made in this lawsuit or released by the Settlement Agreement.  If you stay in the Settlement  (i.e., don’t exclude yourself),  you may object to it or ask for permission  for you or your  lawyer to appear  and speak at the hearing—at your own cost—but you don’t have to. Objections and requests to appear are due by June 23, 2023. More information about these options is available at www.SinceraSettlement.com.

The Court’s hearing. The Court will hold a Fairness Hearing in this case (Opris, et al. v. Sincera Reproductive Medicine, No.  2:21-cv-03072-JHS) on September 6, 2023. At  the  hearing,  the  Court  will  decide  whether  to  approve  the Settlement;  Class Counsel’s request for attorneys’  fees and costs (up to 1/3  of $800,000-$1,200,000); and service awards to the Class Representatives  (up to $8,000 total). You or your lawyer may appear at the hearing at your own expense.

Questions? Go to www.SinceraSettlement.com, or call 1-855-663-1852.

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