Frequently Asked Questions

The Superior Court of California for Los Angeles County authorized this Settlement Website. 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. This Settlement Website explains the lawsuit, your legal rights, what benefits are available, and who can receive them.

The lawsuit is captioned Doe, et al. v. Prime Healthcare Services, Inc., et al., Case No. 23STCV26800, pending in the Superior Court of California for Los Angeles County. The persons that filed this lawsuit are called the “Plaintiffs” (or “Class Representatives”) and the entity they sued, Prime Healthcare Services, Inc., is called the “Defendant.” 

This lawsuit alleges that Prime Healthcare used third-party tracking technologies, called “tracking pixels,” on its website in a way that violates certain state and federal privacy laws.

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 “Settlement Class” or “Settlement Class Members.” One court resolves the lawsuit for all Settlement Class Members, except for those who opt out of the settlement. In this Settlement, the Class Representatives are individuals (Jane Doe, Jan Doe, Janice Doe, Jamie Doe, and R.S.) whose names are under court seal, and everyone included in this Action are the Settlement Class Members.

The Court did not decide whether the Plaintiffs or the Defendant is right. Both sides have agreed to a Settlement to avoid the costs and risks of a trial, and to allow the Settlement Class Members to receive benefits from the Settlement. Plaintiffs and their attorneys think the Settlement is best for all Settlement Class Members. 

Settlement Class is defined to mean all patients of Prime Healthcare and the Relevant Hospitals that accessed and/or utilized any of the Prime Web Properties during the period from November 1, 2019, through the date all tracking pixels were definitively removed from the respective Prime Web Property for each such Relevant Hospital, as reflected in Appendix A. Excluded from the Settlement Class are: (1) any Judge presiding over the Litigation, any members of the Judges’ respective staffs, and immediate members of the Judges’ families; (2) officers and directors of the Defendants, their agents, affiliates, subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendants or their parents have a controlling interest; (3) persons who timely and validly request exclusion from and/or opt-out of the Settlement Class; (4) the legal representatives, successors or assigns of any such excluded persons; and (5) Class Counsel.

The table below contains the list of affected Prime Web Properties from Appendix A.

If you are still not sure whether you are a Settlement Class Member, you can ask for free help any time by contacting the Settlement Administrator at: 
•    Email: [email protected]
•    Call toll free, 24/7: 1-833-319-5511.
•    By mail: Prime Healthcare Pixel Settlement, c/o Kroll Settlement Administration LLC, P.O. Box 225391, New York, NY, 10150.
You may also view the Settlement Agreement at Important Documents page of this Settlement Website.

Prime Healthcare has agreed that Settlement Class Members who accessed one of Prime Healthcare’s patient portals between November 1, 2019, and the Class Period End Date for the relevant Prime Web Property, which you may review at Question 5 (the Patient Portal Subclass) are entitled to a $20 cash payment, upon submission of a valid and timely Claim Form, and a one-year subscription to CyEx Medical Shield Pro, provided automatically with their Notice. Prime Healthcare has further agreed that individuals who were patients at one of Prime Healthcare’s California hospitals between November 1, 2021, and the Class Period End Date for the relevant California hospital, which you may review at Question 5, and who provided Prime Healthcare an email address (the Email Subclass) are entitled to a one-year subscription to CyEx Medical Shield Pro, also provided automatically with their Notice.  In addition, Prime Healthcare has agreed that for a period of five years following final approval of the Settlement that Prime Healthcare will refrain from using certain tracking technologies on its websites. 

No claim is required to receive CyEx Medical Shield Pro: your activation code and enrollment instructions accompany your Notice. To use your CyEx Medical Shield Pro, you must activate your code within 180 days of its issuance, after which it will expire. Patient Portal Subclass Members may file a claim for the $20 cash payment. 

To enroll in Medical Shield Pro, visit https://app.medicalshield.cyex.com/enrollment/activate/prime and enter your activation code (found on your Notice received via email or postcard, if you are a Patient Portal Subclass or Email Subclass Member). Please note this code is unique to you and should not be shared with anyone else for enrollment. In addition to your activation code, you will need to provide your name, address, date of birth, telephone, a valid email, and your Social Security number to complete your enrollment. The provision of this information is necessary to provide you the full benefits of Medical Shield Pro.

The deadline to enroll is April 20, 2027. After April 20, 2027, the enrollment process will close, and your Medical Shield Pro code will no longer be active. If you do not enroll by April 20, 2027, you will not be able to take advantage of Medical Shield Pro, so please enroll before the deadline.

BENEFITS

CyEx Medical Shield Pro: All Patient Portal Subclass and Email Subclass Members receive a code for one (1) year of CyEx Medical Shield Pro privacy monitoring services, transmitted with their Notice; no Claim Form is required. Medical Shield Pro provides a comprehensive solution to help restore and protect consumers’ online medical information privacy. Medical Shield Pro offers numerous benefits, including:

1. Dark Web Monitoring: Medical Shield’s Dark Web Monitoring tracks and alerts when personal information is listed for sale on the dark web, such as black-market websites, secret chat rooms, and underground forums. 

2. National Provider Identifier Monitoring: An exclusive monitoring service for healthcare providers. Tracks NPI and informs users if registered licensing credentials are found on the dark web.

3. $1,000,000 Identity Theft Insurance: No-deductible insurance for covering expenses due to an identity theft incident.

4. Medical Record Number Monitoring: Alerts when a Medical Record Number has been detected on the dark web, which could potentially expose permanent medical and health records from providers, hospitals, and urgent care centers to bad actors.

5. Real-Time Authentication Alerts: Provides notification when a creditor receives a request for certain types of account transactions using the customer’s Social Security Number (SSN).

6. Security Freeze Assist: Helps freeze credit files instantly from up to ten (10) consumer reporting agencies, including the three (3) major credit bureaus.

7. Victim Assistance: A team of Identity Theft Recovery Specialists offers immediate remediation assistance if identity theft is suspected.

More information about CyEx Medical Shield Pro can be found at https://cyex.com/medical-shield. 

All Patient Portal Subclass and Email Subclass Members receive one year of this service automatically.

Cash Payment: All Patient Portal Subclass Members may claim a one-time $20 cash payment by submitting a valid and timely Claim Form.

Injunctive Relief: Prime Healthcare shall not use Google Analytics or the Meta Pixel on the Prime Web Properties for a period of five years following final approval of the Settlement, and Prime Healthcare agrees to create a Web Governance Committee that will conduct annual audits of all Prime Healthcare websites to ascertain compliance with the above requirements, including, if applicable, requiring business associate agreements with third-party providers of tracking pixel technologies.

If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at: 

If you are a Settlement Class Member but not a member of the Patient Portal Subclass or the Email Subclass, you are automatically included in the Settlement without filing anything. You will not receive a cash payment or a CyEx Medical Shield Pro code, but you benefit from the injunctive relief described above: for five years, Prime Healthcare must keep the challenged tracking technologies off the Prime Web Properties and prove its compliance through annual audits and sworn declarations. You have the same rights as every other Settlement Class Member to exclude yourself from the Settlement (see Question 15) or to object to it (see Question 16). If you do nothing, you will remain in the Settlement Class and will be bound by the release described in Question 8.

Unless you opt out of the Settlement, you won’t be able to sue, continue to sue, or be part of any other lawsuit against the Defendants about any of the legal claims this Settlement resolves. The paragraphs below describe the legal claims that you give up if you remain in the Settlement Class (“Released Claims”), the entities and people you are releasing (“Released Parties”), and who is releasing claims (“Releasing Parties”). The complete Settlement Agreement is available at Documents section of this website. 

“Released Claims” means any and all claims, causes of action, or rights to relief—asserted or unasserted, at law or in equity—that were asserted in the operative complaint in the Litigation or that reasonably could have been asserted based on the facts alleged in the operative complaint in the Litigation, including without limitation claims arising under CIPA (Cal. Penal Code §§ 630, 631(a), 632, 637.2, 638.51), the CMIA (Cal. Civ. Code § 56 et seq.), the UCL (Bus. & Prof. Code § 17200), the CDAFA (Cal. Penal Code § 502), the California Constitutional right to privacy, the ECPA (18 U.S.C. § 2511 et seq.), the California Customer Records Act (Cal. Civ. Code § 1798.82), or any analogous federal, state, or common-law claim. The Released Claims do not include claims that do not arise out of or relate to the facts alleged in the operative complaints in the Litigation.

“Released Parties” means Prime Healthcare Services, Inc., Prime Healthcare Foundation, Inc., and their respective hospitals, including, but not limited to the Relevant Hospitals listed in Appendix A, and any and all of Prime Healthcare Services, Inc. and Prime Healthcare Foundation, Inc.’s respective present or past heirs, executors, estates, administrators, predecessors, successors, assigns, parent companies, subsidiaries, licensors, licensees, associates, affiliates, employers, employees, agents, consultants, independent contractors, insurers, reinsurers, directors, managing directors, officers, partners, principals, members, attorneys, accountants, financial and other advisors, underwriters, shareholders, lenders, auditors, investment advisors, legal representatives, successors in interest, assigns and companies, firms, trusts, and corporations.

“Releasing Parties” means (i) the Plaintiffs and Class Representatives, (ii) all Settlement Class Members who do not validly request exclusion, and (iii) each of the foregoing’s spouses, heirs, executors, administrators, successors, and assigns to the extent claiming through or on behalf of any of the foregoing.

Only Patient Portal Subclass Members need to submit a Claim Form, and only to receive the $20 cash payment; no claim is required for CyEx Medical Shield Pro. The fastest way to submit your Claim Form is online by using the Submit Claim button on this Settlement Website. If you prefer, you can download a printable Claim Form from the Important Documents page of this Settlement Website and mail it to the Settlement Administrator at: 

Prime Healthcare Pixel Settlement

c/o Kroll Settlement Administration LLC

P.O. Box 225391

New York, NY 10150-5391

You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (833) 319-5511, by email at [email protected], or by U.S. mail at the address above.

If you are submitting a Claim Form online, you must do so by December 21, 2026. If you are submitting a claim by U.S. mail, the completed and signed Claim Form must be postmarked no later than December 21, 2026.

The Court will hold a Final Approval Hearing on March 9, 2027 (see Question 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. 

Your activation code to sign up for CyEx Medical Shield Pro is included with the Notice that you received. Cash payments will be distributed if the Court grants final approval, and after any appeals are resolved. Any settlement funds remaining from uncashed checks after all distributions are complete will be paid, with the Court’s approval, to Privacy Rights Clearinghouse, a nonprofit consumer-privacy organization that the Parties have selected as the cy pres recipient.

Yes, the Court appointed the law firms of Caddell & Chapman, Ahmad, Zavitsanos & Mensing, PLLC, and Almeida Law Group LLC as “Class Counsel” to represent you and other Settlement Class Members in this case. 

You will not be charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense.

Class Counsel will ask the court to approve attorneys’ fees, costs, and expenses of up to $2,000,000, which will be paid directly by Prime Healthcare. Class Counsel will also ask for a Service Award of $3,000 for each of the five Class Representatives. Service Awards will also be paid directly by Prime Healthcare.

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 a Settlement Cash Payment and may not use the CyEx Medical Shield Pro code included with your Notice, but you will keep any rights you may have to sue Prime Healthcare 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 December 21, 2026.

To be valid, your Request for Exclusion must state that you want to be excluded from the Settlement and include your name, address, and email address or phone number.

You may mail or email your Request for Exclusion to the Settlement Administrator at: 

Prime Healthcare Pixel Settlement

c/o Kroll Settlement Administration LLC

ATTN: Request for Exclusion 

P.O. Box 225391 

New York, NY 10150-5391

Email: [email protected] 

Your Request for Exclusion must be submitted, postmarked, or emailed by December 21, 2026. If you do not file a timely Request for Exclusion, as outlined above, you will lose the opportunity to exclude yourself from the Settlement and will be bound by the Settlement.

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

As long as you do not exclude yourself from the Settlement, you may object or comment in support of or in opposition to the Settlement in whole or in part.  Objections may be made in writing and mailed or emailed to the Settlement Administrator by January 20, 2027. You may also object in person at the Final Approval Hearing.

You may mail or email your objections or comments to the Settlement Administrator at:

Prime Healthcare Settlement

c/o Kroll Settlement Administration LLC

ATTN: Objections

P.O. Box 225391

New York, NY 10150-5391

Email: [email protected] 

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 or your legal rights.

The Court will hold a Final Approval Hearing on March 9, 2027 at 10:00 a.m. Pacific Time at the Spring Street Courthouse of the Superior Court of California, County of Los Angeles , at 312 North Spring Street, Dept. 7, Los Angeles, CA 90012.

At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The Court will also decide whether to approve Class Counsel’s request for attorneys’ fees, costs, and expenses of up to $2,000,000, $3,000 Service Awards to each of the five Class Representatives who brought this Action on behalf of the Settlement Class, and Settlement Administration Expenses of $140,000. The Court will also consider any written objections to the Settlement (see Question 16). You may also object in person at the Final Approval Hearing. If the Court approves the Settlement, the Settlement Administrator will post the Final Judgment on the Settlement Website, www.PHSettlement.com, within ten (10) days of its entry, and the posting will remain available through the conclusion of settlement administration.

If you are a Settlement Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see Question 16). 

The date and time of this hearing may change without further notice. Please visit Main Page  for current hearing information in case of any updates.

No. Class Counsel will answer any questions the Court may have. You, and/or your attorney, 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.

If you do nothing, you will not receive a Cash Payment, but you may still use the CyEx Medical Shield Pro code included with your Notice.

You will also give up the rights described in Question 8.

This Settlement Website is a summary of the proposed Settlement. The full Settlement Agreement and other related documents, including the Motion for Preliminary Approval, the Motion for Final Approval, and the Court’s orders are available at the Important Documents page of this Settlement Website.

If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at: 

You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 312 North Spring Street, Los Angeles, CA 90012.

DO NOT CONTACT THE COURT OR CLERK OF COURT REGARDING THIS SETTLEMENT.