Chapman v. Insight Global, LLC

In response to the COVID-19 pandemic, the Commonwealth of Pennsylvania’s Department of Health entered into a contract with Insight Global. Under that contract, Insight Global agreed to conduct a state-wide, contact-tracing initiative. Plaintiff alleges that Insight Global’s contact tracers input certain information in publicly accessible Google documents for a limited period of time (“the “Data Incident”). The impacted information allegedly may have consisted of names of individuals who may have been exposed to COVID-19, if they experienced symptoms, information about number of members in household, email addresses and telephone numbers, and information to address any social support services needs.

No court or other entity has determined that Insight Global committed any wrongdoing or violated any law. By entering the Settlement, Defendant is not admitting any wrongdoing or liability.

In a class action, a representative plaintiff sues on behalf of all people who have similar claims. Together all these people are called a Settlement Class or Settlement Class Members. One court resolves the issues for all Settlement Class Members, except for those Settlement Class Members who timely exclude themselves from the Settlement Class.

The proposed Representative Plaintiff in this case is the Plaintiff, Lisa Chapman.

Plaintiff and Defendant do not agree about the claims made in this Litigation. The Litigation has not gone to trial, and the Court has not decided in favor of any party. Instead, Plaintiff and Defendant have agreed to settle the Litigation. Plaintiff and the attorneys for the Settlement Class (“Proposed Class Counsel”) believe the Settlement is best for all Settlement Class Members because of the Settlement Benefits and the risks and uncertainty associated with continued litigation and the nature of the defenses raised by the Defendant.

You are a Settlement Class Member if you were one of the individuals residing in the United States whose personal information was or may have been compromised in the Data Incident that is the subject of a Notice of Data Event Related to Pennsylvania Contact Tracing that Insight Global sent to Plaintiff and others in the same form on or around April 29, 2021.

Yes. Excluded from the Settlement Class are

• Insight Global and its officers and directors;
• all Settlement Class Members who timely and validly request exclusion from the Settlement Class;
• the Judge assigned to evaluate the fairness of this Settlement; and
• the attorneys representing the Parties in the Litigation.

If you are still not sure whether you are a Settlement Class Member, you may call the Claims Administrator’s toll-free number at 1-888-279-4405.

If you are a Settlement Class Member and you file a valid and timely Claim Form by February 23, 2023, you may be eligible for the following Settlement Benefits:

Ordinary Expense Reimbursement

All Settlement Class Members who submit a valid claim using the Claim Form are eligible to receive reimbursement for documented out-of-pocket losses, not to exceed $250 per Settlement Class Member, that were incurred between August 1, 2020, and August 16, 2022, if plausibly caused by the Data Incident. Acceptable claims for out-of-pocket reimbursements include:

• The cost to obtain credit reports;
• Fees relating to a credit freeze;
• Card replacement fees;
• Late fees;
• Overlimit fees;
• Interest on payday loans taken as a result of the Data Incident;
• Other bank or credit card fees;
• Postage, mileage, and other incidental expenses resulting from lack of access to an existing account;
• Costs associated with credit monitoring or identity theft insurance purchased prior to the Effective Date of the Settlement if purchased primarily as a result of the Data Incident (You must provide reasonable documentation, including proof of purchase, and an affirmative statement that it was purchased primarily because of the Data Incident); and
• Compensation for attested-to lost time spent monitoring accounts, reversing fraudulent charges, or otherwise dealing with the aftermath/cleanup of the Data Incident, at a rate of $20 per hour for up to 3 hours. (You must provide attestation of at least a narrative description of the activities performed during the time claimed and their connection to the Data Incident to receive this benefit.)

Other Extraordinary Expense Reimbursement

Settlement Class Members who submit a valid claim using the Claim Form are eligible to receive extraordinary expense reimbursement of up to $5,000 per Settlement Class Member for monetary out-of-pocket losses that occurred more likely than not as a result of the Data Incident if:

• It is an actual, documented, and unreimbursed monetary loss;
• Was caused by the Data Incident;
• Occurred during the time period from October 2020, through and including the end of the Claims Deadline;
• Is not an amount already covered by one or more of the categories in ordinary expense reimbursement listed above; and
• You made reasonable efforts to avoid, or seek reimbursement for the loss, including but not limited to exhaustion of all available credit monitoring insurance and identity theft insurance.

Credit Monitoring and Identity Protection

You are eligible to receive two years of credit monitoring services, and these services include three bureau credit monitoring and alerts. Settlement Class Members must affirmatively request credit monitoring by indicating such request on the Claim Form. Redemption codes will then be sent either to an email or physical mailing address you provide on the Claim Form.

For your request for credit monitoring services to be valid, you must complete a statement on the Claim Form under penalty of perjury that your claim is true and correct to the best of your knowledge and belief. You must reasonably attest that the Data Incident caused you to incur the claimed out-of-pocket expenses and charges. Failure to provide the above statement and documentation as requested on the Claim Form shall result in denial of a claim.

Unless you exclude yourself, you are choosing to remain in the Settlement Class. If the Settlement is approved and becomes final, all of the Court’s orders will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against Insight Global and Released Parties about the legal issues in this Litigation that are released by this Settlement. The specific rights you are giving up are called “Released Claims”.

The Settlement Agreement in Sections 1.20, 1.21, and 6 describe the Release, Released Claims, and the Released Parties in necessary legal terminology, so please read these sections carefully. The Settlement Agreement is available here or in the public court records on file in this lawsuit. For questions regarding the Release and what it means, you can also contact one of the lawyers listed in FAQ 13 for free, or you can talk to your own lawyer at your own expense.

The February 23, 2023 Claim Filing Deadline has passed. We are no longer accepting Claims via online or mail submissions.

If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Claims Administrator of your updated information. You may notify the Claims Administrator of any changes by calling 1-888-279-4405 or by writing to

Insight Global Claims Administrator
P.O. Box 3815
Portland, OR 97208-3815

If you make a valid Claim, payment will be provided by the Claims Administrator after the Settlement is approved by the Court and becomes final.

It may take time for the Settlement to be approved and become final. Please be patient and check the Current Status section located on the Home page for updates.

Yes, the Court has appointed Jonathan Shub and Kevin Laukaitis of Shub Law Firm, LLC, as Proposed Class Counsel to represent you and the Settlement Class for the purposes of this Settlement. You may hire your own lawyer at your own cost and expense if you want someone other than Proposed Class Counsel to represent you in this Litigation.

Proposed Class Counsel will file a motion asking the Court to award them attorneys’ fees and costs of $300,000 to be paid by Insight Global. They will also ask the Court to approve $2,000 service award to the Representative Plaintiff for participating in this Litigation and for their efforts in achieving the Settlement. If awarded by the Court, Defendant will pay fees, costs, expenses, and incentive awards directly. The Court may award less than these amounts.

Proposed Class Counsel’s application for attorneys’ fees, expenses, and service awards will be made available on this website before the deadline for you to comment or object to the Settlement.

The January 24, 2023 Opt-out Deadline has passed. We are no longer accepting submissions for this settlement.

No. If you exclude yourself, you are telling the Court you do not want to be part of the Settlement. You can only get Settlement Benefits if you stay in the Settlement and submit a valid Claim Form.

No. Unless you exclude yourself, you give up any right to sue Defendant and Released Parties for the claims this Settlement resolves relating to the Data Incident. You must exclude yourself from this Litigation to start or continue with your own lawsuit or be part of any other lawsuit against the Defendant or any of the Released Parties. If you have a pending lawsuit, speak to your lawyer in that case immediately.

The January 24, 2023 Objection Deadline has passed. We are no longer accepting submissions for this settlement.

Objecting is simply telling the Court you do not like something about the Settlement or requested attorneys’ fees and expenses. You can object only if you stay in the Settlement Class (that is, do not exclude yourself). Requesting exclusion is telling the Court you do not want to be part of the Settlement Class or the Settlement. If you exclude yourself, you cannot object to the Settlement.

The Court held a Final Fairness Hearing on April 5, 2023, at 10:00 a.m. before Judge Christopher C. Conner.

Note: Any change will be posted on the Current Status section of the Home page.