PLEASE READ THE NOTICE CAREFULLY AS YOUR LEGAL RIGHTS MAY BE AFFECTED. A CLASS ACTION SETTLEMENT HAS BEEN REACHED UNDER WHICH YOU MAY BE ENTITLED TO A PAYMENT.

This is a court-authorized notice of a proposed settlement in a class action lawsuit, Bachmann, et al. v. Wenzak Heartland, Inc., et al., case number 2021-L-1253 Circuit Court of DuPage County, Illinois (the “Litigation”). The Settlement will resolve a lawsuit brought on behalf of persons who allege Wenzak Heartland, Inc., Wenzak, Inc., and Wenzak QSC Management, Inc. (the “Defendants” or “Wenzak”) required employees to provide their biometric identifiers and/or biometric information without first having a written policy and obtaining a written release. Defendants deny these allegations, deny violations of any law, and deny all liability. If you received a Notice, you have been identified by Defendants as someone who may have enrolled in and/or used a body-part scanning device while working for them. The Court has granted preliminary approval of the Settlement Agreement and has conditionally certified the Settlement Class for purposes of settlement. The Notice explains the nature of the lawsuit, the terms of the Settlement Agreement, and the legal rights and obligations of the Settlement Class Members. Please read the instructions and explanations so you can understand your rights.

This settlement includes all individuals who worked or are currently working for Wenzak Heartland, Inc., Wenzak, Inc., Wenzak QSC Management, Inc., and/or Wenzak Chicago Southland, Inc. in the State of Illinois who enrolled in and/or used a body-part scanning device (e.g., a finger or hand scanning device) while working for these entities within the five-year period preceding the date of the filing of the Litigation. There are approximately 3,149 people who fall within the class definition.

If approved by the Court, a Gross Settlement Amount in the total amount of $1,905,145.00 will be established to pay all claims to the Settlement Class, including all notice and administration expenses, approved attorneys’ fees and costs, and an incentive award to the named plaintiff.