Senior Director of Business Development
Senior Director of Notice
Counsel needed a nationwide notice plan to effectively reach a large number of unknown class members. While the defendant could provide class data for 126 known class members, the notice plan relied primarily on digital media to reach the unknown class.
The short form notice was mailed to the 126 known settlement class members. Additionally, a multichannel digital notice plan was designed to reach 70% of the estimated settlement class. The notice plan consisted of Facebook, Instagram, Google Search, programmatic website banner ads, and sponsored internet listings. Due to the demographics of the potential class members, notice ads were translated from English to Spanish and the case website featured Spanish translation. Unknown class members were targeted on social media using defined interests related to using the product, such as occupation, hobbies, and brand interests. Website banner ads for the settlement appeared on popular websites to visitors based on their occupation, hobbies, and frequent purchase habits. The Google Search campaign showed ads about the settlement to users searching for the named product, as well as keywords related to the settlement. The Simpluris web team integrated a digital disbursement option into the settlement website to streamline the payment process and improve efficiency for class members. Class members were able to choose how they wanted to receive payment from a variety of methods including Zelle, Venmo, PayPal, or check.
The digital media notice campaign resulted in nearly 9.5 million gross impressions being delivered to potential class members throughout the United States. More than 80% of the class members who filed claims opted to receive a digital payment. On March 18, 2022, the court granted final approval to the class action settlement.