Frequently Asked Questions

Basic Information

1. Why did I get the Notice?

You are receiving the Notice because your Private Information was potentially impacted in the Data Incident. A group of similarly situated individuals brought a proposed class action lawsuit against CQT in 2025, alleging that CQT was negligent due to its data security practices. CQT denies the allegations and denies any liability or wrongdoing. The parties have now reached a proposed Settlement of the lawsuit.

A court authorized the Notice because you have a right to know about your rights under the proposed class action Settlement before the Court decides whether to approve the Settlement. If the Court approves the Settlement, and after objections and appeals are resolved, the Settlement Administrator appointed by the Court will make the payments that the Settlement allows, and the pending legal claims against CQT will be released and dismissed.

The Notice explains the lawsuit, the Settlement, your rights, what benefits are available, who is eligible for them, and how to get them. Judge William F. Hutson of the Court of Common Pleas, Medina County, Ohio, is in charge of this case. The case is Cox, et al. v. The Cornwell Quality Tools Company, Medina C.P. No. 2026CIV0649.

2. What is this lawsuit about?

This matter is a putative class action (the “Litigation”) arising from the Data Incident whereby Plaintiffs allege that an unauthorized third party gained access to certain of CQT’s computer systems between December 11, 2024, and December 22, 2024, which included certain Private Information of Plaintiffs and Settlement Class Members. The lawsuit asserts claims against CQT for alleged negligent data security practices.

Defendant denies any and all allegations of wrongdoing.

3. What is a class action?

In a class action, one or more individuals called “Class Representatives” sue on behalf of themselves and others who have similar claims. This group of individuals is called the “Class,” and the individuals in the Class are called “Settlement Class Members” or the “Settlement Class.” One court resolves the issues for all Settlement Class Members, except for those individuals who exclude themselves from the Class. The individuals who sued are called the Plaintiffs. The entity they sued—CQT—is called the Defendant.

4. Why is there a settlement?

The Court did not decide in favor of Plaintiffs or Defendant. Instead, both sides agreed to a settlement. That way, they avoid the costs and risks of a trial, and Settlement Class Members can receive Settlement Benefits. The Class Representatives and Class Counsel believe the Settlement is in the best interest of the Settlement Class.

Who is in the Settlement?

5. Who is included in the Settlement?

The Settlement Class is defined as “all individuals within the United States whose Private Information was potentially impacted by the Data Incident publicly announced by Defendant in September 2025, including all those who were sent a notice letter.”

6. Are there exceptions to being included?

Yes, the following are not included in the Settlement Class: (i) CQT, the Related Entities, and their respective officers and directors, and any entity in which Defendant has a controlling interest; (ii) all members of the Settlement Class who timely and validly submit an Opt-Out Request in conformity with Paragraph 4 [of the Settlement Agreement]; (iii) and all judges assigned to hear any aspect of this litigation, as well as their immediate family members; (iv) any and all federal, state or local governments, including but not limited to their departments, agencies, divisions, bureaus, boards, sections, groups, counsels and/or subdivisions; and (v) any other Person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the criminal activity occurrence of the Data Incident or who pleads nolo contendere to any such charge.

7. What should I do if I am not sure whether I am included?

If you are not sure whether you are included in the Settlement Class, you can ask for free help by calling the Settlement Administrator at (833) 296-0950 or via email at info@CQTDataIncidentSettlement.com to get more information.

The Settlement Benefits

8. What does the Settlement provide?

Under the Settlement, CQT will pay for all Valid Claims made by Settlement Class Members. The Settlement also ensures that CQT will implement certain business practice enhancements aimed at further strengthening CQT’s cybersecurity network.

9. What can I get from the Settlement?

Settlement Class Members may file a claim for one or more of the following Settlement Benefits:

• Identity Monitoring: Settlement Class Members may submit a claim for two (2) years of three-bureau CyEx Financial Shield monitoring and fraud protection with $1 million identity theft insurance (“Identity Monitoring”).

• Reimbursement for Documented Losses and Lost Time: In addition to Identity Monitoring, Settlement Class Members may submit a claim for reimbursement up to an individual aggregate cap of $5,000.00 for: (1) documented (excluding self-prepared documents), unreimbursed out-of-pocket losses that are fairly traceable to the Data Incident (“Out-of-Pocket Losses”), and (2) lost time spent addressing the Data Incident at a rate of $20.00 per hour for up to three hours (i.e., not to exceed $60.00 per Settlement Class Member), subject to an attestation by signature under penalty of perjury from the Settlement Class Member, as to how the time was spent, demonstrating that it was related to the Data Incident (“Time Spent”).

Out-of-Pocket Losses include: (i) documented out-of-pocket expenses such as: (a) bank fees, (b) long-distance phone charges, (c) cell phone charges (only if charged by the minute), (d) data charges (only if charged based on the amount of data used), (e) postage, and (f) gasoline for local travel; and (ii) documented expenses for credit reports, credit monitoring, or other identity theft insurance products.

To receive compensation for Out-of-Pocket Losses, you must enclose or upload documentation sufficient to show: (a) the amount of unreimbursed loss that you suffered, and (b) why you believe that the loss is related to the Data Incident in the case. Documents for financial expenses may include credit card or bank statements, emails, invoices, receipts, or telephone records, including photographs of the same. Personal statements or declarations are not considered reasonable documentation, but may be used to provide clarification, context, or support for other documentation. Self-prepared documents are not sufficient documentation to support your claim.

• Alternative Cash Payment: In addition to Identity Monitoring, but in lieu of submitting a claim for reimbursement of Out-of-Pocket Losses and Lost Time, Settlement Class Members may submit a claim for an alternative cash payment in the amount of $50.00 (“Alternative Cash Payment”). Settlement Class Members do not need to submit any supporting documentation or attestations to receive this Alternative Cash Payment.

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

If you are a Settlement Class Member and you do not exclude yourself from the Settlement, you will give up your right to sue, continue to sue, or be part of any other lawsuit against Defendant or other Released Persons concerning the Released Claims resolved by this Settlement. The “Releases” section of the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The entire text of the Settlement Agreement is available here.

How to get a Payment – Making a Claim

11. How can I receive a payment?

You must complete and submit a Claim Form by January 25, 2027. Claim Forms may be submitted online here or downloaded here and mailed to the Settlement Administrator at:

CQT Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958

Be sure to read the Claim Form instructions carefully, include all required information, and add your signature.

The Settlement Administrator will review your claim to determine the validity and amount of your payment.

12. How much will my payment be?

All Settlement Class Members are entitled to request Identity Monitoring plus an Alternative Cash Payment of $50.00 or Reimbursement for Documented Losses and Lost Time. If you request Reimbursement for Documented Losses and Lost Time, the amount of your cash payment will depend on the approved amount of your claim (up to a total maximum of $5,000.00).

13. When will I receive my payment?

The Court will hold a Final Approval Hearing on January 28, 2027, at 9:00 a.m. to decide whether to approve the Settlement. Payments will be made after the Settlement is approved and becomes Final (meaning there is no appeal from the order approving the Settlement). Updates regarding the Settlement or Final Approval Hearing will be posted on this website.

The Lawyers Representing You

14. Do I have a lawyer in this case?

The Court appointed Terence R. Coates of Markovits, Stock & DeMarco, LLC as the attorney to represent the Settlement Class. This lawyer is called Class Counsel.

15. Should I get my own lawyer?

If you want your own lawyer, you may hire one, but you will be responsible for any payment for that lawyer’s services. For example, you can ask your own lawyer to appear in court for you if you want someone other than Class Counsel to speak for you. You may also appear for yourself without a lawyer.

16. How will the lawyers and Class Representatives be paid?

Class Counsel has not yet received any payment for legal services or any reimbursement of the costs or out-of-pocket expenses incurred. Class Counsel plans to ask the Court to award attorneys’ fees, costs, and expenses, as defined by the Settlement Agreement, not to exceed $500,000.00.

The Settlement Class is represented by eight named individuals (the “Class Representatives”). In addition to the Settlement Benefits that the Class Representatives will receive as members of the Settlement Class—and subject to the approval of the Court—CQT has agreed to pay Service Awards of $2,000.00 to each of the Class Representatives (in the aggregate $16,000.00) for the efforts they have expended on behalf of the Settlement Class.

The Court will determine whether to approve the Fee Award and Costs requested by Class Counsel and the proposed Service Awards to the Class Representatives. Class Counsel will file an application for Fee Award and Costs, and Service Awards no later than December 14, 2027. The application will be available on this website or you can request a copy by contacting the Settlement Administrator.

Excluding Yourself from the Settlement

17. How do I get out of the Settlement?

If you are a Settlement Class Member and you do not want the Settlement Benefits, and you want to keep your right, if any, to sue Defendant or the Released Persons on your own about the Released Claims resolved by the Settlement, then you must take steps to get out of the Settlement. This is called excluding yourself from— or “opting out” of—the Settlement Class.

You may opt out of the Settlement by December 28, 2026. To opt out, you must send a letter or postcard via U.S. mail to the address below. You must include the following in your letter or postcard:

1. The name of this Litigation, or a decipherable approximation Cox, et al. v. The Cornwell Quality Tools Company, Medina C.P. No. 2026CIV0649;

2. Your full name, mailing address, telephone number, and email address;

3. The words “Requests for Exclusion” at the top of the document or a statement that you want to opt out of the Settlement; and

4. Your personal signature.

You must mail your opt-out request via first-class U.S. mail, postmarked no later than December 28, 2026, to:

CQT Data Incident Settlement
ATTN: Exclusion Request
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958

If you fail to include the required information, your request will be deemed invalid and you will remain a Settlement Class Member and be bound by the Settlement, including all Releases.

18. If I am a Settlement Class Member and don’t opt out, can I sue the Defendant for the same thing later?

No. You must opt out of the Settlement to keep your right to sue the Defendant or other Released Persons for any of the Released Claims resolved by the Settlement, as set out in full in the Settlement Agreement.

19. What happens if I opt out?

If you opt out of the Settlement, you will not have any rights as a member of the Settlement Class. You will not receive any Settlement Benefits. You will not be bound by the Settlement, Releases in the Settlement Agreement, or by any further orders or judgments in this case. You will keep the right, if any, to sue on the claims alleged in the case at your own expense.

In addition, if you opt out of the Settlement, you cannot object to this Settlement because the Settlement no longer affects you. If you object to the Settlement and opt out, your objection will be voided and you will be deemed to have excluded yourself.

Commenting on or Objecting to the Settlement

20. How do I tell the Court if I don’t like the Settlement?

If you are a Settlement Class Member and you do not opt out of the Settlement, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. You can give reasons why you think the Court should not approve it. You can’t ask the Court to change the Settlement or order a different settlement; the Court can only approve or deny this Settlement. If the Court denies approval, no settlement payments or Identity Monitoring will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

You may object to any part of the proposed Settlement in writing. You may also appear at the “Final Approval Hearing,” either in person or through your own attorney. If you appear through your own attorney, you are responsible for paying that attorney.

If you object in writing, you must include:

1. the objector’s full name, mailing address, telephone number, and email address;

2. the case name and docket number Cox, et al. v. The Cornwell Quality Tools Company, Medina C.P. No. 2026CIV0649;

3. documentation sufficient to establish membership in the Settlement Class, such as a copy of the Notice the objector received;

4. a written statement of all grounds for the objection, accompanied by any legal support for the objection that the objector believes applicable and any supporting documents;

5. the identity of any and all counsel representing the objector in connection with the objection;

6. a statement of whether the objector and/or his or her counsel will appear at the Final Approval Hearing;

7. a list of all persons who will be called to testify, including objector, at the Final Approval Hearing in support of the objection (if any);

8. a statement confirming whether the objector and/or objector’s counsel utilized any form of artificial intelligence in preparing the objection; and

9. the objector’s signature or the signature of the objector’s duly authorized attorney or other duly authorized representative (if any) representing him or her in connection with the objection

Any objection must be mailed to the Settlement Administrator or filed with the Court through the Clerk of the Courts:

The objection must be filed or postmarked no later than December 28, 2026.

21. What’s the difference between objecting and opting out?

Objecting is telling the Court that you don’t like something about the Settlement. You can object to the Settlement only if you are a Settlement Class Member and do not opt out of the Settlement.

Opting out of the Settlement is telling the Court that you don’t want to be part of the Settlement. If you opt out of the Settlement, you cannot object to it because it does not affect you.

The Court’s Final Approval Hearing

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

The Court will hold a Final Approval Hearing at 9:00 a.m. on January 28, 2027, at the state courthouse located at Medina County Courthouse, 225 E. Washington Street, Medina, OH 44256 before Judge William F. Hutson. At this hearing, the Court will consider: 1) whether the Settlement is fair, reasonable, and adequate; 2) Class Counsel’s application for the Fee Award and Costs; and 3) whether to approve Service Awards to the Class Representatives. If there are objections, the Court will consider them. The Court may choose to hear from individuals who have asked to speak at the hearing. At or after the hearing, the Court will decide whether to approve the Settlement. There is no deadline by which the Court must make its decision.

The Court may reschedule the Final Approval Hearing or change any of the deadlines described in the Notice. The date of the Final Approval Hearing may change without further notice to the Settlement Class Members. Be sure to check this Settlement Website for updates. You can also access the case docket via the Court’s website: https://medinacountyclerk.org .

Class Counsel will file a motion for final approval of the Settlement by January 14, 2027.

23. Do I have to come to the Final Approval Hearing?

No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish. If you object, you do not have to come to the hearing to talk about it. As long as you mailed or filed your written objection on time, the Court will consider it. You may also pay your own lawyer to attend, but it is not necessary.

24. May I speak at the hearing?

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must include a statement in your written objection (see FAQ 20) that you intend to appear at the hearing. Be sure to include your name, address, telephone number, email address, and signature as well. You cannot speak at the hearing if you opt out from the Settlement Class.

If I Do Nothing

25. What happens if I do nothing at all?

If you are a Settlement Class Member and do nothing, you will not receive any Settlement Benefits, and you will not be able to sue the Defendant or other Released Persons for the Released Claims resolved by the Settlement.

Getting More Information

26. Are more details about the Settlement available?

This website and the Notice summarize the proposed Settlement—more details are in the Settlement Agreement and other case documents available on the Important Documents page.

27. How do I get more information?

On this website you will find more information, including the Claim Form, a copy of the Settlement Agreement, and answers to questions about the Settlement and other information to help you determine whether you are eligible for Settlement Benefits.

You may also contact the Settlement Administrator, Simpluris, or Class Counsel at:

Please do not contact the Court, the Court Clerk’s Office, or Defendant to inquire about this Settlement or the Claims Process.