Frequently Asked Questions

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 give final approval to the Settlement. This Notice explains the lawsuit, the Settlement, and your legal rights.

The Plaintiffs and Defendant have reached a proposed Settlement of this matter that will affect your rights. The people who sued are called the Plaintiffs. The company they are suing, Lytx, is called the Defendant.

Chief Judge Nancy J. Rosenstengel of the United States District Court for the Southern District of Illinois is overseeing this case. The class action is called Lewis v. Lytx Inc., et al., Case No. 3:22-cv00046-NJR. The judge has authorized this notice to explain all of your options before the Court decides whether to approve the Settlement. If the Court approves the Settlement and if such approval is final with respect to appeal(s), if any, an administrator appointed by the Court will make the payments and take other actions that the Settlement allows. Because your rights will be affected by this Settlement, it is extremely important that you read this Notice carefully.

In a class action, one or more people called the class representatives (in this case, Plaintiffs Joshua Lewis, James Cavanaugh, and Nathaniel Timmons) sue on behalf of a group or a “class” of people who have similar claims. In a class action, the court resolves the issues for all class members, except for those who exclude themselves from the class.

This lawsuit alleges that Lytx violated the Illinois Biometric Information Privacy Act by collecting and storing Settlement Class Members’ biometric data through dash cams and using its MV+AI technology. Lytx denies these allegations, any wrongdoing, or that it violated any laws. The Settlement does not establish who is right or wrong, but rather is a compromise to end the lawsuit and avoid the uncertainties and expense of continuing on in court.

The Court has not decided whether the Plaintiffs or Defendant should win this case. Instead, both sides agreed to a Settlement. That way, they avoid the uncertainties and expenses associated with ongoing litigation, and Settlement Class Members will get compensation.

The Settlement Class is defined as:
All individuals who, while present in the State of Illinois, operated a vehicle equipped with a Lytx DriveCam, and for whom MV+AI was used to predict distracted driving behaviors between October 12, 2016 and January 1, 2025.

Monetary Relief: Lytx will pay $4,250,000 into a Settlement Fund for the benefit of the Settlement Class to make payments to Settlement Class Members, pay the costs of administration of the settlement, and pay attorneys’ fees, expenses, and any service award to the Class Representatives, as approved by the Court. The Settlement will provide Settlement Class Members residing in Illinois with 50% of the Settlement Fund that remains after subtracting the costs of administration, attorneys’ fees, expenses, and service awards. The remaining 50% of the Settlement Fund that remains after subtracting the costs of administration, attorneys’ fees, expenses, and service awards will go to non-Illinois residents.

To get a payment, you must submit a Claim Form, which can be found here, postmarked or submitted electronically by June 25, 2025. Claim Forms may be submitted online here or by U.S. mail to the following address: LYTX Settlement Administrator, P.O. Box 709, Baton Rouge, LA 70821. You can also elect to receive your payment by check or electronically by Venmo, Zelle, PayPal, etc.

The amount in the Settlement Fund will be distributed to Settlement Class Members who do not opt out of the Settlement on a pro rata basis depending on their state of residence, after deducting any Court-approved attorneys’ fees and expenses, service awards for the class representatives, and costs of settlement notice and administration. Payments to Settlement Class Members will come by check unless you elect to receive payment electronically by Venmo, Zelle, PayPal, etc.

The Court will hold a hearing to consider the fairness of the Settlement on July 24th, 2025. If the Court approves the Settlement, Settlement Class Members will receive their payment within 90 days after the Settlement has been finally approved and/or any appeals process is complete.

If the Settlement becomes final, you will give up (or “release”) your rights to sue Lytx and certain of its affiliates (Released Parties) regarding the Released Claims, which are described and defined in the Settlement Agreement. Unless you exclude yourself (see Question 10), you will release the Released Claims. You may access the Settlement Agreement through the “Court Documents” tab here.

The Settlement Agreement describes the Released Claims with specific descriptions, so read it carefully. If you have any questions you may speak to the lawyers listed in Question 15 for free or you may, of course, speak to your own lawyer.

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

a. The name and number of this case, Lewis v. Lytx Inc., et al., Case No. 3:22-cv-00046-NJR;
b. Your full name, address, and current telephone number;
c. The entity or entities for whom you drove and when;
d. All grounds for the request to be excluded, with factual and legal support for the stated request, including any supporting materials;
e. The identification of any other exclusion requests you have filed, or had filed on your behalf, in any other class action cases in the last five years; and
f. Your handwritten or electronically imaged written signature.

You must mail or deliver your exclusion letter, postmarked no later than May 28, 2025 to:

LYTX Settlement Administrator
P.O. Box 709
Baton Rouge, LA 70821

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

No. If you exclude yourself, you are not eligible to receive a settlement payment from the Settlement Fund Account.

If you’re a Settlement Class Member, you may ask the Court to deny approval of the Settlement by filing an objection. You may object to any aspect of the Settlement, Class Counsel’s request for attorneys’ fees and expenses, or the request for Service Awards. You can give reasons why you think the Court should not give its approval. The Court will consider your views.

If you choose to make an objection, you must mail or file with the Court a letter or brief stating that you object to the Settlement and the basis for your objection. Your letter or brief must include the name and number of this case, Lewis v. Lytx Inc., et al., Case No. 3:22-cv-00046-NJR, as well as the following information:

a. Your full name and mailing address;
b. An explanation of the basis upon which you claim to be a Settlement Class Member;
c. All grounds for the objection, including all citations to legal authority and evidence supporting the objection;
d. The name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with your objection or who may profit from the pursuit of your objection (the “Objecting Attorneys”);
e. A statement indicating whether you or your attorney intends to appear at the Final Approval Hearing;
f. A list of all class action settlements to which the objector has lodged an objection in the last five years;
g. Your handwritten or electronically imaged written signature; and
h. If you or any of the Objecting Attorneys have objected to any class action settlement where you or the Objecting Attorney asked for or received any payment in exchange for dismissal of the objection, or any related appeal, without any modification to the settlement, then you must include a statement identifying each such case by full case caption and amount of payment received. 

You must mail or deliver your written objection, postmarked no later than May 28, 2025 to:

LYTX Settlement Administrator
P.O. Box 709
Baton Rouge, LA 70821

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

Class Counsel: 
Randall K. Pulliam
Carney Bates & Pulliam, PLLC
One Allied Dr., Ste. 1400
Little Rock, AR 72202
Email: rpulliam@cbplaw.com

Defendant’s Counsel:
Max E. Kaplan
Cozen O’Connor
1650 Market St., Ste. 2800
Philadelphia, PA 19130
Email: mkaplan@cozen.com

Objecting simply means telling the Court that you don’t 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 don’t want to be part of the Settlement Class. If you exclude yourself, you have no right to object or receive a monetary benefit because the case no longer affects you.

The Court has appointed the law firms of Carney Bates & Pulliam PLLC; Lieff Cabraser Heimann & Bernstein LLP; Milberg Coleman Bryson Phillips Grossman PLLC; Workplace Law Partners, P.C.; Werman Salas P.C.; and Nick Larry Law LLC to represent the Settlement Class. They are called “Class Counsel.” After conducting an extensive investigation, they believe that the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You will not be charged out-of-pocket for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your own expense.

Class Counsel’s attorneys’ fees, costs, and expenses will be paid from the Settlement Fund in an amount determined and awarded by the Court. Class Counsel is entitled to seek attorneys’ fees up to one-third of the $4.25 million Settlement Fund plus reasonable expenses, but the Court may award less than this amount.

Class Counsel may also seek a Service Award of up to $10,000.00 for each of the Class Representatives for their service in helping to bring and settle the case. Any court-awarded Service Award will be paid out of the Settlement Fund, but the Court may award less than this amount.

The Court will hold a Final Approval Hearing at 1:30 PM on July 24, 2025 at the Federal Building and U.S. Courthouse, 750 Missouri Ave, East St. Louis, IL 62201. 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 Class Counsel’s request for attorneys’ fees and expenses; and to consider the request for Service Awards to the Class Representatives. At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement.

The hearing may be postponed to a different date or time without notice, so check this website for any updates. 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 such Final Approval Hearing.

No. Class Counsel will answer any questions the Court may have. But you are welcome to come at your own expense. If you send an objection or comment, you don’t have to attend the hearing to talk about it. As long as you filed and mailed your written objection on time, the Court will consider it. You may also retain your own lawyer (at your own expense) to attend, but it’s not required.

Yes. You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must include in your letter or brief objecting to the Settlement a statement saying that you or your attorney intends to appear at the Final Approval Hearing.

This Notice contains only a summary of the Settlement and the proceedings to date. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement here. You may also write with questions to the LYTX Settlement Administrator, P.O. Box 709, Baton Rouge, LA 70821. You can also call the Settlement Administrator at 1-844-789-9500 or Class Counsel, if you have any questions. Before doing so, however, please read this full Notice carefully.