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Former, current and prospective Volkswagen or Audi customers may be included in a $3.5 million Class Action SettlementfORMER

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MARTINEZ, Calif., Jan. 19, 2023 A settlement has been reached with Volkswagen Group of America, Inc., Audi of America LLC, and Sanctus, LLC d/b/a Shift Digital (collectively, "Defendants") in a class action lawsuit titled Service, et al. v. Volkswagen Group of America, Inc., et al., Case No. MSC22-01841, pending in the Superior Court of California, Contra Costa County. The lawsuit arises from an alleged data security incident (the "Incident") involving the personal information ("PI") and sensitive personal information ("SPI") of certain current, former, and prospective Volkswagen and Audi customers.

Who is included in the settlement? You are included in the settlement and are a Settlement Class Member if you reside in the United States and were sent a notice in June 2021 by Volkswagen and/or Audi that your PI or SPI may have been exposed as a result of the Incident.

What does the settlement provide? As part of the settlement, Defendants have agreed to pay $3.5 million into a Settlement Fund, which will be used to pay (1) cash settlement awards to Settlement Class Members who file valid claims; (2) Settlement Administration expenses; (3) attorneys' fees and costs incurred by Class Counsel; and (4) service awards to the named plaintiffs. Settlement Awards include cash payments ($350 to California SPI Subclass members, $80 to Nationwide SPI Subclass members, and $20 to Nationwide PI Subclass members, subject to upward and downward proration) or reimbursement of out-of-pocket losses fairly traceable to the Incident (California SPI and Nationwide SPI Subclass members only, subject to downward proration). The payment amounts depend on the number of valid claims received. In addition, as part of the settlement, Shift Digital, has agreed to certain business practice changes in the form of data security enhancements.

How do I get an award from the settlement? You must properly complete and timely submit a Claim Form to receive a Settlement Award. You may submit your Claim Form online at or by mail. You can obtain a paper Claim Form at or by calling toll-free 1-866-329-0166. To be timely, the Claim Form must be submitted electronically or postmarked by April 12, 2023.

What are my other options? If you do not wish to submit a claim, you may: (1) do nothing; (2) object to the settlement; or (3) exclude yourself from the Settlement Class. If you object to the settlement or do nothing, you are choosing to stay in the Settlement Class. You will be legally bound by all orders of the Court, and you will not be able to start, continue, or be part of any other lawsuit against Defendants or related parties concerning the Incident. If you choose to object to the settlement, you will have the opportunity to tell the Court why you think that the Court should not finally approve the settlement. To object to the settlement, you must submit a written objection to the Settlement Administrator by March 13, 2023, or appear at the final approval hearing, which is currently set for May 18, 2023 at 9:00 a.m. PT. If you do not want to be bound by the settlement, you must exclude yourself from the Settlement Class by submitting a request for exclusion by March 13, 2023.

For more information, or to view important settlement documents, visit or call 1-866-329-0166.


SOURCE Wolf Haldenstein Adler Freeman & Herz LLP, Casey Gerry Schenk Francavilla Blatt & Penfield, LLP, Clayeo C. Arnold A Professional Law Corp., and Lockridge Grindal Nauen P.L.L.P