DG3 Data Breach Litigation

• A $600,000 settlement has been reached in a class action lawsuit against DG3 North America, Inc., John Hancock Investment Management, LLC, and UBS Financial Services, Inc. (together, “Defendants”) involving a Data Incident impacting Defendant DG3 North America, Inc. which was discovered in or around March 2024 (the “Data Incident”).
• The lawsuit is called Daniel Cunningham et al. v. DG3 North America, Inc. et al., Case No. 2:24- cv-07385 (District of New Jersey). Plaintiffs allege that the Data Incident resulted in the unauthorized access to or acquisition of Settlement Class Members’ Private Information. Plaintiffs allege negligence, negligence per se, breach of implied contract, breach of third-party beneficiary contract, breach of fiduciary duty, breach of confidence, unjust enrichment, and violation of the Illinois Consumer Fraud Act by Defendants. Defendants deny all of the claims.
• The Settlement Class includes: all persons residing in the United States whose Private Information was potentially compromised as a result of the Data Incident. You are also a “Group 1 Settlement Subclass member” if your Social Security number was included in the Private Information compromised in the Data Incident or a “Group 2 Settlement Subclass member” if your Social Security number was not included in the Private Information compromised in the Data Incident.
• If you are a member of the Settlement Class, the following Settlement Class Member Benefits are available:

Reimbursement for Documented Losses: You may submit a Claim Form and provide reasonable documentation for losses related to the Data Incident for up to $2,500 per Settlement Class Member; OR

Alternative Cash Payment: In lieu of a claim for reimbursement of Documented Losses, you may file a claim for an Alternative Cash Payment, estimated at $100 for Group 1 Settlement Subclass members and $50 for Group 2 Settlement Subclass Members. Please note that your Alternative Cash Payment may be subject to a pro rata adjustment depending on the total value of claims that are submitted and approved.;AND

Credit Monitoring: In addition to a claim for reimbursement of Documented Losses or an Alternative Cash Payment, you may also submit a Claim Form to receive three years of free Credit Monitoring.

Confirmatory Discovery: Defendant DG3 North America has also agreed to provide documents and information to Class Counsel showing that it has taken data security measures to remedy the issues that led to the Data Incident and implemented other business practices to help ensure information security.

Your legal rights are affected regardless of whether you do or do not act.

Your Legal Rights and Options in this Action
Submit a Claim Form	The deadline has passed to submit a valid claim form.
File an Objection	The deadline has passed to object to the Settlement.
Exclude Yourself	The deadline has passed to exclude yourself from the Settlement.
Do Nothing	Get no Settlement Class Member Benefits. Give up your legal rights.