Frequently Asked Questions



Basic Information

1. Why was a notice issued?

The Circuit Court for the Nineteenth Judicial District, Lake County, Illinois, 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 Bakale v. Universal Lenders, LLC., Case No. 2025LA00000214. It is pending in the Circuit Court for the Nineteenth Judicial District, Lake County, Illinois. The people that filed this lawsuit are called the “Plaintiffs” (or “Class Representatives”) and the company they sued, Universal Lenders, LLC, is called the “Defendant.”

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2. What is this lawsuit about?

This lawsuit alleges that during the November 2024 targeted cyberattack on UL's computer systems, certain files that contained private information were accessed. These files may have contained personal information such as names; Social Security numbers; financial account numbers; and driver’s license numbers.

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3. What is a class action lawsuit?

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 “Class Members.” One court resolves the lawsuit for all Class Members, except for those who opt out from the settlement. In this Settlement, the Class Representatives are Matthew Bakale, Samantha Krulicki, Akeem Shannon, and Mary Wilson. Everyone included in this Action are the Class Members.

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4. Why is there a settlement?

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 Class Members to receive benefits from the Settlement. The Plaintiffs and their attorney think the Settlement is best for all Class Members.

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Who is in the Settlement?

5. Who is included in the Settlement?

The court has defined the Class this way: “All individuals to whom Defendant mailed notices that their Private Information was potentially compromised in the Data Breach discovered in November 2024.”

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6. Are there any exceptions to being included?

Yes. Excluded from the Class are: (1) UL and its officers, directors, and related companies; (2) anyone who validly excludes themselves from the Settlement; (3) governmental entities; (4) attorneys for the parties; (5) the Judge in this case, and the Judge’s family and staff; and (6) anyone who perpetrated the Data Breach.

You may view the Settlement Agreement here.

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The Settlement Benefits

7. What does the Settlement provide?

All Class Members may claim three years of Credit Monitoringservices and one of two cash payment options:

  • Option 1: Expense Reimbursement: If you have documented out-of-pocket expenses, you can get back up $2,500.00.

  • Option 2: Alternative Cash Payment: Receive a one-time $50.00 cash payment.

The benefits are explained in more detail below.

Credit Monitoring Services. All Class Members are eligible to enroll in three years of single bureau Credit Monitoring Services. This benefit comes with $1 million in identity theft insurance, and includes:

  • real time monitoring of your credit file

  • dark web scanning

  • comprehensive public records monitoring

If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.

Expense Reimbursement. If you incurred actual, documentedout-of-pocket expenses due to the Data Breach, you can get back up to $2,500.00.

This benefit covers the following examples unreimbursed out-of-pocket expenses:

  1. costs to obtain credit reports;

  2. fees relating to a credit freeze;

  3. card replacement fees;

  4. late fees;

  5. over-limit fees;

  6. interest and fees on payday loans taken as a result of the Data Breach;

  7. bank or credit card fees;

  8. postage, mileage, and other incidental expenses; and

  9. costs associated with up to one year of credit monitoring or identity theft insurance (must have been purchased between June 3, 2024, and August 29, 2025)

You need to send proof, like 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. Your proof or notes should show that your expenses were because of the Data Incident.

You cannot claim a payment for expenses that have already been reimbursed by a third party.

Alternative Cash Payment. Instead of Expense Reimbursement, you may claim a one-time $50.00 cash payment. You do not have to provide any proof or explanation to claim this payment.

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8. What claims am I releasing if I stay in the Settlement Class?

If you stay in the class, you won’t be able to be part of any other lawsuit against UL about the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section 6) describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available here.

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Submitting a Claim Form for a Settlement Payment

9. How do I submit a claim for a Settlement benefit?

The fastest way to submit your Claim Form is online here. Your Unique ID and PIN can be found on the Postcard you might have received. If you prefer, you can download a printable Claim Form from here and mail it to the Settlement Administrator at:

UL Data Breach Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958

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10. Are there any important Settlement payment deadlines?

If you are submitting a Claim Form online, you must do so by April 13, 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 April 13, 2026.

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11. When will the Settlement benefits be issued?

The Court will hold a final approval hearing on April 21, 2026 (see FAQ 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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The Lawyers Representing You

12. Do I have a lawyer in the case?

Yes, the Court has appointed attorney Gary Klinger, Esq. of Milberg Coleman Bryson Phillips Grossman, LLC, to represent you and other Class Members (“Class Counsel”).

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13. Should I get my own lawyer?

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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14. How will the Class Counsel be paid?

Class Counsel will ask the court to approve $200,000.00 as reasonable attorney's fees and costs of litigation. This amount will be paid by UL.

Class Counsel will also ask for Service Award payments of $1,500.00 for each of the Class Representatives. Service Award payments will also be paid by UL.

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Excluding Yourself From The Settlement

15. How do I opt out of the Settlement?

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 Settlement benefits or payment. However, you will keep any rights you may have to sue UL 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 March 14, 2026.

To be valid, your Request for Exclusion must have the following information:

  1. the name of the Litigation: Bakale v. Universal Lenders, LLC, Case No. 2025LA00000214, pending in the Circuit Court for the Nineteenth Judicial District, Lake County, Illinois;

  2. your full name, mailing address, telephone number, and email address;

  3. personal signature; and

  4. 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:

UL Data Breach Settlement
ATTN: Exclusion Request
P.O. Box 25226
Santa Ana, CA 92799-9958

Your Request for Exclusion must be postmarked or emailed by March 14, 2026.

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Commenting Or Objecting To The Settlement

16. How do I tell the Court if I like or do not like the Settlement?

If you are a Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons for 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 FAQ 15).

You must provide the following information for the Court to consider your objection:

  1. the name of the Litigation: Bakale v. Universal Lenders, LLC, Case No. 2025LA00000214, pending in the Circuit Court for the Nineteenth Judicial District, Lake County, Illinois;

  2. your full name, mailing address, telephone number, and email address;

  3. information that proves that you are a Class Member (such as a notice you have received, or a statement explaining why you believe you are a Class Member);

  4. a clear description of all the reasons you object; include any legal support, such as documents, you may have for your objection;

  5. if you have hired your own lawyer to represent you for this objection, provide their name, bar number, and contact information;

  6. whether you and/or your attorney will appear at the Final Approval Hearing;

  7. your signature (or, if you have hired your own lawyer, your lawyer’s signature);

For your objection to be considered, it must meet each of these requirements.

To be considered by the Court, you must file your complete objection with the Clerk of Court by March 14, 2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and counsel for Defendants.

Clerk of the Court

Settlement Administrator

Clerk of the Court
Lake County Courthouse
18 N County Street
Waukegan, IL 60085

UL Data Breach Settlement
ATTN: Objections
P.O. Box 25226
Santa Ana, CA 92799-9958

Class Counsel

Counsel for Defendants

Gary M. Klinger
Milberg Coleman Bryson Phillips Grossman PLLC
227 W. Monroe Street, Suite 2100
Chicago, IL 60606

Jon P. Kardassakis
Lewis Brisbois
633 W. 5th Street, Suite 4000
Los Angeles, CA 90071

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17. What’s the difference between objecting and excluding?

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’s Final Approval Hearing

18. When is the Court’s Final Approval Hearing?

The Court will hold a final approval on April 21, 2026, at 9:00 a.m. Central Time, in Courtroom C-204 of the Circuit Court for the Nineteenth Judicial District, Lake County, Illinois, at 18 N County Street, Waukegan, IL 60085.

At the final approval hearing, the Court will decide whether to approve the Settlement. The court will also decide how Class Counsel should be paid, and whether to award Service Award payments to the Class Representatives. The Court will also consider any objections to the Settlement.

If you are a Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see FAQ 16). The date and time of this hearing may change without further notice. Please check this website for updates.

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19. Do I have to come to the Final Approval Hearing?

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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Getting More Information

20. What happens if I do nothing at all?

If you do nothing, you will not receive a benefit from this Settlement. You will also give up the rights described in FAQ 8.

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21. Where can I get additional information?

This website and the Notice are a summary of the proposed Settlement. The full Settlement Agreement and other related documents are available on the Important Documents page.

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 Court regarding this Settlement.

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