Frequently Asked Questions

Basic Information

1. Why was the Notice issued?

A court authorized this Notice because you have a right to know about a proposed Settlement of this class action lawsuit and about all of your options before the Court decides whether to grant final approval to the Settlement. The Notice explains the lawsuit, the Settlement, and your legal rights.

The Honorable Carlos Augusto Rodriguez of the Circuit Court of the 17th Judicial Circuit, in and for Broward County, Florida, is overseeing this lawsuit. The lawsuit is called Jeffries v. Derick Dermatology, PLLC, Case No. CACE-26-003864. The person who has sued is called the Plaintiff. The entity being sued, Derick Dermatology, PLLC, is called the Defendant.

2. What is a class action?

In a class action, one or more people called the class representative (in this case, Plaintiff Jennifer Jeffries) sue on behalf of a group or a class of people whom the Plaintiff alleges to have similar legal claims. In a class action, the Court resolves the issues for all class members, except for those who exclude themselves from the class.

3. What is this lawsuit about?

The material allegations of the complaint center on Defendant’s alleged disclosure of information to third parties via pixels, cookies, code, and/or tracking or analytics tools on Defendant’s website for which Plaintiff asserts claims for violation of the Federal Wiretap Act, 18 U.S.C. § 2510, et seq., breach of fiduciary duty/confidentiality, invasion of privacy, breach of implied contract, unjust enrichment, and negligence.

At all times, Defendant has denied and continues to deny any wrongdoing whatsoever and has denied and continues to deny that it committed, or threatened or attempted to commit, any wrongful act or violation of law or duty alleged in the Action. Nonetheless, taking into account the costs, distraction to business operations, and uncertainty inherent in any litigation, Defendant has concluded it is desirable and beneficial that the Action be fully and finally settled and terminated in the manner and upon the terms and conditions set forth in this Agreement. This Agreement is a compromise, and the Agreement, any related documents, and any negotiations resulting in it shall not be construed as or deemed to be evidence of or an admission or concession of liability or wrongdoing on the part of Defendant, or any of the Released Parties, with respect to any claim of any fault or liability or wrongdoing or damage whatsoever.

The Court has not decided who is right. Rather, the parties have agreed to settle the lawsuit to avoid the uncertainties and expenses associated with ongoing litigation.

4. Why is there a settlement?

The Court has not decided whether the Plaintiff or Defendant should win this lawsuit. Instead, both the Plaintiff and Defendant have agreed to a settlement. The Plaintiff and the lawyers for the Settlement Class (“Class Counsel”) believe the Settlement is best for all Settlement Class Members because of the benefits of the Settlement and the risks and uncertainty associated with continued litigation.

Who's Included in the Settlement?

5. How do I know if I am in the Settlement Class?

The Settlement Class is defined as: “all persons from November 21, 2023, through November 27, 2025, who made an appointment on www.derickdermatology.com or a subdomain thereof.”

6. Are there exceptions to being included in the Settlement?

Yes. Excluded from the Settlement Class are (1) any Judge or Magistrate presiding over this Action and members of their families; (2) the Defendant, its subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendant or its parents have a controlling interest and their current or former officers, directors, agents, attorneys, and employees; (3) persons who properly execute and file a timely request for exclusion from the class; and (4) the legal representatives, successors or assigns of any such excluded persons.

7. What if I am still not sure whether I am part of the Settlement?

If you are still not sure whether you are a Settlement Class Member, you may email the Settlement Administrator at info@DermatologyPixelSettlement.com or call toll-free (833) 386-6576.

The Settlement Benefits

8. What does the Settlement provide?

Cash Payment

Settlement Class Members who submit a valid Claim Form may receive a cash payment of up to $12.50.

One-Year Subscription for Identity Theft Protection

In addition to a cash payment, each Settlement Class Member will automatically receive a code for redeeming the Privacy Shield Pro identity theft protection product. Enrollment must be completed within ninety (95) days of the Effective Date, and the enrollment codes will become active within five (5) days after the Effective Date. Settlement Class Members do not need to file a claim to receive their enrollment code for Privacy Shield Pro. After the Effective Date, once the codes have become active, please visit https://privacyshield.cyex.com/enrollment/dermatology to enroll.

9. How will the amount of the cash payment be determined?

According to the Settlement Agreement, Defendant and/or its insurers will pay up to $1 million for the following: (1) Notice and Other Settlement Administration Expenses (2) the Fee Award for attorneys’ fees, costs, and expenses for Class Counsel, as may be approved by the Court; (3) a Service Award to the Class Representative; (4) up to an $12.50 cash payment to each Settlement Class Member who submits an Approved Claim, and (5) the costs of the one-year subscriptions to Privacy Shield. The cash payment may be reduced pro rata (a legal term meaning equal share) if the total value of all Approved Claims exceeds the funds available for distribution to Settlement Class Members depending on the number of Approved Claims received.

10. How do I get a payment?

If you are a Settlement Class Member and you want to receive a cash payment, you must complete and submit a Claim Form. The Claim Form must be postmarked or submitted online by July 21, 2026. Claim Forms can be submitted online here, or by printing and mailing a paper Claim Form, copies of which are available for download here.

*Settlement Class Members are encouraged to submit their claim online.

11. When will I get my payment?

The Court will hold a hearing to consider the fairness of the Settlement. If the Court approves the Settlement, eligible Settlement Class Members whose claims are approved by the Settlement Administrator will receive their payment after the Settlement is finally approved and/or any appeals process is complete.

Remaining in the Settlement

12. What am I giving up if I stay in the Settlement Class?

If the Settlement becomes final, you will give up (or “release”) your rights to sue Defendant and Released Parties regarding the Released Claims, which are described and defined the Settlement Agreement. Unless you exclude yourself, you will release the Released Claims, regardless of whether you submit a Claim Form or not. You may review the Settlement Agreement.

The Settlement Agreement describes the Released Claims in necessary legal terminology, so please read this information carefully. If you have any questions you may speak to Class Counsel for free or you may, speak to your own lawyer at your own expense.

If you remain in the Settlement Class, you will be bound by all of the Court’s orders and judgments.

13. What happens if I do nothing at all?

If you do nothing, you will not receive a cash payment. Also, if you do not exclude yourself, you will be unable to start a lawsuit or be part of any other lawsuit brought against Defendant or Released Parties regarding the Released Claims in this lawsuit.

The Lawyers Representing You

14. Do I have a lawyer in the case?

The Court has appointed Mariya Weekes of Milberg PLLC and Albert Plawinski of Plawinski, PLLC to be the lawyers representing the Settlement Class. They are called “Class Counsel.” After conducting an extensive investigation, they believe the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your own expense.

15. How will the lawyers be paid?

Class Counsel’s attorneys’ fees, costs, and expenses will be paid by Defendant and/or its insurers in an amount determined and awarded by the Court. Class Counsel will ask for no more than $350,000.00 in combined attorneys’ fees, costs, and expenses, but the Court may award less than this amount. Class Counsel may also seek a Service Award of up to $1,500.00 for the Class Representative for her service in helping to bring and settle the case. The Service Award will be paid by Defendant and/or its insurers, but the Court may award less than this amount.

Excluding Yourself from the Settlement

16. How do I get out of the Settlement?

To exclude yourself from the Class, you must mail or otherwise deliver a written request stating that you want to be excluded. Your letter must include:

• Your name;
• Your address;
• Your signature;
• The name and number of the case (Jeffries v. Derick Dermatology, PLLC, Case No. CACE-26-003864); and
• A statement that you wish to be excluded from the Settlement Class for the purposes of this Settlement.

You must mail or deliver your exclusion letter, postmarked or received by June 22, 2026, to:

Derick Dermatology Pixel Settlement
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799

*No “mass” or “class” opt-outs will be allowed.

17. If I don't exclude myself, can I sue the Defendant for the same thing later?

No. Unless you exclude yourself, you give up any right to sue Defendant and Released Parties for the Released Claims being resolved by this Settlement.

18. If I exclude myself, can I get anything from this Settlement?

No. If you exclude yourself, you may not submit a Claim Form to receive a cash payment and will not receive a one-year Privacy Shield subscription with no subscription fee.

Objecting to the Settlement

19. How do I object to the Settlement?

If you are a Settlement Class Member, you may comment upon and/or object to the Settlement Agreement or any of its terms. If you choose to make an objection, you must mail or file with the Court your written objection stating that you object to the Settlement Agreement. Your written objection must include:

• Your name and address;
• An explanation of the basis upon which you claim to be a Settlement Class Member;
• All grounds for your objection, including all citations to legal authority and evidence supporting the objection;
• The name and contact information of any and all lawyers representing, advising, or in any way assisting you in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection (the “Objecting Lawyers”); and
• A statement indicating whether you intend to appear at the Final Approval Hearing (either personally or through a lawyer who files an appearance with the Court in compliance with the Local Rules of the Court).
• If you or any of the Objecting Lawyers have objected to any class action settlement where the you or the Objecting Lawyers asked for or received any payment in exchange for dismissal of the objection, or any related appeal, without any modification to the settlement, then the objection must include a statement identifying each such case by full case caption and amount of payment received. Any challenge to the Settlement Agreement, the Final Order, or the Final Judgment will be pursuant to appeal under the applicable rules of appellate procedure and not through a collateral attack.

You must mail or deliver your written objection, so that it is received no later than June 22, 2026, to:

Clerk of the Court
Circuit Court of the 17th Judicial Circuit, in and for Broward County, Florida
201 SE 6th St.
Fort Lauderdale, FL 33301

You must also mail, email, or otherwise deliver a copy of your written objection to Class Counsel and Defendant’s counsel at the following addresses:

*No “mass” or “class” objections will be allowed.

Objections will be considered by the Court at the Final Approval Hearing only if, on or before the Objection Deadline, the Person making the objection files a notice of an intention to do so and at the same time (a) files copies of such papers he or she proposes to be submitted at the Final Approval Hearing with the Clerk of the Court, or alternatively, if the objection is from a Class Member represented by counsel, files any objection through the Court’s E-Filing Portal, and (b) sends copies of such papers by mail, hand, or overnight delivery service to Class Counsel and Defendant’s Counsel.

20. What is the difference between objecting and excluding myself from the Settlement?

Objecting simply means telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself from the Settlement Class is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself, you have no right to object or file a Claim Form because the lawsuit no longer affects you.

21. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Approval Hearing at 10:30 a.m. EST on August 17, 2026, via Zoom (instructions below). The purpose of the hearing will be for the Court to determine whether to approve the Settlement as fair, reasonable, adequate, and in the best interests of the Settlement Class; to consider the Class Counsel’s request for attorneys’ fees and expenses; and to consider the request for a Service Award to the Class Representative. At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement.

Join Zoom Meeting
https://17thflcourts.zoom.us/j/111475745
Meeting ID: 111 475 745

The hearing may be postponed to a different date or time without notice, so it is a good idea to check this website or call (833) 386-6576 to confirm the date and time. If, however, you timely objected to the Settlement and advised the Court that you intend to appear and speak at the Final Approval Hearing, you will receive notice of any change in the date of the Final Approval Hearing.

The Court's Final Approval Hearing

22. Do I have to attend the hearing?

No. Class Counsel will answer any questions the Court may have. You are welcome to attend at your own expense. If you send an objection or comment, you do not have to attend the hearing to talk about it. If you file and mail your written objection on time, the Court will consider it. You may also hire your own lawyer (at your own expense) to attend the hearing, but it is not required.

23. May I speak at the hearing?

Yes. You may ask the Court for permission to speak at the Final Approval Hearing. If you objected to the Settlement and intend to appear at the Final Approval Hearing (at your own expense and either with or without counsel), you must file notice of an intention to appear with the Clerk of the Court and at the same time file copies of any papers you propose to be submitted at the Final Approval Hearing. Alternatively, if you object and are represented by your own lawyer, you may file your objection and intent to appear at the Final Approval Hearing through the Court’s E-Filing Portal, and send copies of your papers by mail or otherwise deliver to Class Counsel and Defendant’s Counsel.

Information

24. Where do I get more information?

This website and the Notice summarize the Settlement. More details are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available on the Important Documents page, or by calling toll-free (833) 386-6576, or by writing to:

Derick Dermatology Pixel Settlement
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799

Please do not telephone the Court or the Court's Clerk Office.