Frequently Asked Questions

You have the right to know about a proposed Settlement of a class action lawsuit, and about your options, before the Court decides whether to approve the Settlement.

The Court in charge of this case is the Circuit Court of DuPage County, Illinois (the “Court”). The case is known as Plowman et al. v. Seamless Contacts, Inc., Case No. 2025CH000163 (the “Action”). The individuals who sued are called the Plaintiffs or Class Representatives. Specifically, the Plaintiffs are Carla Plowman, Doug Spindler, Reid Cooper, Karen Evans, and Michael Naessens. The company they sued, Seamless, is called the Defendant in the litigation.

Seamless operates a real-time search engine that displays publicly available professional/business information about individuals to customers with free and paid accounts. Seamless advertises its services primarily to salespeople and marketers.

In their lawsuit, Plaintiffs allege that they did not consent to Seamless using their professional/business information to promote Seamless subscriptions. Nor did they consent to Seamless selling access to their personal information as part of its subscription products. Seamless denies that it displays non-business information, denies using profiles to promote subscriptions, and denies selling any information.

More information about Plaintiffs’ Complaint and Seamless’s defenses can be found in the “Court Documents” section of the settlement website.

In a class action, one or more people called Class Representatives (in this case, Carla Plowman, Doug Spindler, Reid Cooper, Karen Evans, and Michael Naessens) bring a single lawsuit on behalf of people who have similar claims, all of whom are a “Class,” or “Class Members.” Bringing a case, such as this one, as a class action allows the adjudication of many similar claims of class members that might be economically too small to bring in individual actions. One court resolves the issues for all class members, except for those who exclude themselves from the Class.

Seamless denies that it did anything wrong. The parties have agreed to a Settlement, which will allow both sides to avoid the risk and cost of further litigation. The Court has not decided in favor of the Class Representatives or Seamless.

If you received a notice, Seamless’s records indicate that you are a Settlement Class Member.

All individuals with contact addresses in California, Illinois, Indiana, Nevada, and Ohio who were not customers of Seamless.ai, but who were saved to the MyContacts list of someone who had a free account with Seamless.ai and later became a paid customer of Seamless.ai between April 1, 2021 to October 2, 2024, are Settlement Class Members.

More specifically, there are five Settlement Classes that are defined as:

California Settlement Class: all individuals with a California contact address who: (1) are not customers of seamless.ai and (2) have been saved to the MyContacts list of a free customer of seamless.ai who subsequently became a paid customer of seamless.ai from April 1, 2021 to October 2, 2024.

Illinois Settlement Class: all individuals with an Illinois contact address who: (1) are not customers of seamless.ai and (2) have been saved to the MyContacts list of a free customer of seamless.ai who subsequently became a paid customer of seamless.ai from April 1, 2021 to October 2, 2024.

Indiana Settlement Class: all individuals with an Indiana contact address who: (1) are not customers of seamless.ai and (2) have been saved to the MyContacts list of a free customer of seamless.ai who subsequently became a paid customer of seamless.ai from April 1, 2021 to October 2, 2024.

Nevada Settlement Class: all individuals with a Nevada contact address who: (1) are not customers of seamless.ai and (2) have been saved to the MyContacts list of a free customer of seamless.ai who subsequently became a paid customer of seamless.ai from April 1, 2021 to October 2, 2024.

Ohio Settlement Class: all individuals with an Ohio contact address who: (1) are not customers of seamless.ai and (2) have been saved to the MyContacts list of a free customer of seamless.ai who subsequently became a paid customer of seamless.ai from April 1, 2021 to October 2, 2024.

If you are not sure whether you are a Class Member, or have any other questions about the Settlement, you should visit the Settlement Website, www.SeamlessSettlement.com, or call the Settlement Administrator toll-free at 1-833-580-0090. Please do not call the Court or the Clerk of Court.

The Settlement provides both monetary damages and injunctive relief to all Class Members. Class Members who make valid claims will be entitled to monetary compensation.

As part of the Settlement, Seamless has agreed to establish a $1,125,000.00 “Settlement Fund” to pay all Settlement expenses, including Administration Expenses, attorneys’ fees and costs (the “Fee Award”), Service Awards for the Class Representatives, and payments for Class Members who submit valid approved claims. Further details about the Settlement Fund can be found in the Settlement Agreement.

The Settlement Fund will be allocated into five State-Specific Settlement Funds:

California Settlement Fund means the non-reversionary cash settlement fund that shall be established by Seamless in the total amount of Seven Hundred Seventy Thousand Seven Hundred Nine Dollars and Zero Cents ($770,709.00).

Illinois Settlement Fund means the non-reversionary cash settlement fund that shall be established by Seamless in the total amount of Two Hundred Eighteen Thousand Five Hundred Twelve Dollars and Zero Cents ($218,512.00).

Indiana Settlement Fund means the non-reversionary cash settlement fund that shall be established by Seamless in the total amount of Ninety-One Thousand Six Hundred Seventy-Two Dollars and Zero Cents ($91,672.00).

Nevada Settlement Fund means the non-reversionary cash settlement fund that shall be established by Seamless in the total amount of Two Thousand Four Hundred Fifty-Seven Dollars and Zero Cents ($2,457.00).

Ohio Settlement Fund means the non-reversionary cash settlement fund that shall be established by Seamless in the total amount of Forty-One Thousand Six Hundred Fifty Dollars and Zero Cents ($41,650.00).

Class Members who timely submit a valid approved claim are entitled to compensation. Each timely, valid claimant will receive payment of a pro rata share of their respective State-Specific Settlement Fund, after payment of Settlement Administration Expenses, the Fee Award, and any Service Award to that Settlement Class’s respective Class Representative. The amount of the settlement payment will depend on the number of valid claims submitted to the Settlement Administrator.

If you are a Class Member, unless you exclude yourself from the Settlement, you cannot sue Seamless, continue to sue, or be part of any other lawsuit against Seamless for claims released in this Settlement. It also means that all decisions by the Court will bind you. The Released Claims and Released Parties are defined in the Settlement Agreement and describe the legal claims that you give up (or “release”) if you stay in the Settlement. The Settlement Agreement is available HERE.

Class Members wishing to make a claim must either (a) visit the Settlement Website, [Settlement Website], and submit a claim form online, or (b) print, fill out, and mail the claim form to the Settlement Administrator at the following address: Seamless Settlement Administrator, P.O. Box 671, Baton Rouge, LA 70821. The deadline for submitting a claim is March 9, 2026. If you choose to mail the claim form, it must be postmarked before or on this date.

Payments will be made to Class Members who submit valid and timely Claim Forms after the Court grants “final approval” to the Settlement, and after any appeals are resolved. If the Court approves the Settlement, there may be appeals. It is always uncertain when these appeals will be resolved, and resolving them can take time. Please be patient.

Seamless will ensure the opt-out process is easy to use by making the opt-out more visible on the Seamless website, making the process more user-friendly (e.g., no requirement to create an account to opt out), and ensuring opt-out requests are honored indefinitely.

If you do not want to be bound by this Settlement, you must request to be excluded from the Class. If you request to be excluded, you will retain any individual rights you have against Seamless and will not have “released” it from any of the Released Claims. However, you will not be eligible to receive compensation under the Settlement, as described above. You also may not object to the Settlement if you request to be excluded.

To exclude yourself (or “opt-out”) from the Settlement, you must submit a written exclusion.

The exclusion must contain a statement to the effect that “I hereby request to be excluded from the settlement in Plowman et al. v. Seamless Contacts, Inc., Case No. 2025CH000163.

Specifically, the exclusions must:

1. 1. be in writing;
   2. identify the case name Plowman et al. v. Seamless Contacts, Inc., Case 2025CH000163;
   3. identify if the person seeking exclusion is a member of the California Settlement Class, the Illinois Settlement Class, the Indiana Settlement Class, the Ohio Settlement Class, or the Nevada Settlement Class;
   4. state the full name, current address, and telephone number of the person seeking exclusion;
   5. provide all grounds for the request to be excluded, with factual and legal support for the stated request, including any supporting materials;
   6. identify any other exclusion request she/he has filed, or has had filed on her/his behalf, in any other class action in the last five years;
   7. be signed by the person(s) seeking exclusion; and
   8. be postmarked or emailed to the Settlement Administrator on or before February 9, 2026.

If you have retained your own attorney, you must also provide the name, email, and telephone number of your attorney.

To be timely, an Exclusion (Opt-Out) request must postmarked, or emailed, on or before February 9, 2026.

Seamless Settlement Administrator P.O. Box 671 Baton Rouge, LA 70821 info@SeamlessSettlement.com

No. Unless you exclude yourself, you give up any right to sue Seamless for the claims that this Settlement resolves (i.e., those claims defined in the Settlement Agreement as the “Released Claims”). If you have a pending lawsuit against Seamless regarding similar claims, speak to your lawyer in that lawsuit immediately. You may need to exclude yourself from this Settlement to continue your own lawsuit. If you properly exclude yourself from the Settlement, you will not be bound by any orders or judgments entered in the Action relating to the Settlement.

No. You will not get any money from the Settlement if you exclude yourself. If you exclude yourself from the Settlement, do not submit a Claim Form asking for benefits.

If you are a Class Member and you do not exclude yourself from the Settlement Class, you can object to the Settlement. You must give the Court reasons why it should deny approval of the settlement by filing an objection.  You can’t ask the Court to order a different settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no Settlement payments will be sent out, and the lawsuit will continue.

Any objection to the proposed settlement must be in writing and personally signed by the objector. If you file a timely written objection, you may, but are not required to, appear at the Final Approval Hearing, either in person or through your own attorney. If you appear through your own attorney, you are solely responsible for hiring and paying that attorney. Additionally, if you or your attorney has objected to any class action settlement where you or your 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 your objection must include a statement identifying each such case by full case caption and amount of payment received.

All written objections must include:

1. 1. your full name and current address;
   2. a statement that you believe you are a member of the California Settlement Class, the Illinois Settlement Class, the Indiana Settlement Class, the Ohio Settlement Class, or the Nevada Settlement Class;
   3. whether your objection applies only to you, to a specific subset of your respective class, or to the entirety of your class;
   4. the specific grounds for the objection;
   5. all documents or writings that you desires the Court to consider;
   6. the name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection; and
   7. a statement indicating whether you intend to appear at the Final Approval Hearing (either personally or through counsel, who must file an appearance or seek pro hac vice admission).

All written objections must be (1) filed with the Court, or (2) mailed and postmarked or emailed to the Settlement Administrator, no later than the February 9, 2026.

Seamless Settlement Administrator P.O. Box 671 Baton Rouge, LA 70821 info@SeamlessSettlement.com

In addition to filing your objection with the Court, you must send via mail, email, or delivery service, by no later than February 9, 2026, copies of your objection and any supporting documents to both Class Counsel and Seamless’s lawyers at the addresses listed below:

Class Counsel	Seamless’s Counsel
Sam Strauss sam@straussborrelli.com Raina Borrelli raina@straussborrelli.com Brittany Resch bresch@straussborrelli.com Strauss Borrelli PLLC 980 N. Michigan Ave, Suite 1610 Chicago, Illinois 60611Michael Ram mram@forthepeople.com Morgan & Morgan 711 Van Ness Ave, Ste 500, San Francisco, CA 94102	Aneca E. Lasley Aneca.Lasley@icemiller.com Ice Miller LLP 250 West Street, Suite 700 Columbus, Ohio 43215Melissa Siebert msiebert@cozen.com Cozen O’Connor 123 N. Wacker Dr., Suite 1800 Chicago, Illinois 60606

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 telling the Court that you do not want to be part of the Settlement. If you exclude yourself from the Settlement, you have no basis to object to the Settlement because it no longer affects you. Therefore, if you submit both a Request for Exclusion Form and Objection, you will be deemed to have opted out of the Settlement, and thus to be ineligible to object. However, any objecting Class Member who has not timely submitted a completed Request for Exclusion Form will be bound by the terms of the Agreement in the event the Court enters a final approval of the Settlement.

Yes. The Court has appointed Sam J. Strauss, Raina C. Borrelli, and Brittany Resch of Strauss Borrelli PLLC and Michael F. Ram of Morgan & Morgan, P.A. as Class Counsel. The lawyers will be compensated from the Settlement Fund, in an amount to be determined by the Court. If you want to be represented by your own lawyer, you may hire one at your own expense.

Class Counsel spent considerable time and effort prosecuting this matter on a purely contingent fee basis, and advanced the expenses of the litigation, in the expectation that they would receive a fee, and have expenses reimbursed, only if there was a benefit created for the Class. The Court will determine the amount of fees, expenses, and service awards that will be paid from the Settlement Funds.

Class Counsel will file a motion seeking an award of thirty-five percent (35%) of each State-Specific Settlement Fund, after proportional Settlement Administration Expenses and Service Awards are deducted.

Class Counsel will also seek, on behalf of the Class Representatives, Service Awards of $5,000 to the California Settlement Class Representative and $2,500 to the Illinois, Indiana, Ohio, and Nevada State Class Representatives

The Court will hold a Final Approval Hearing on April 6, 2026 at 9:30 a.m. via Zoom.

At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. The Court will also consider how much to award to Class Counsel and the Class Representatives. If there are objections, the Court will consider them at this time. After the hearing, the Court will decide whether to approve the Settlement. The Court will also listen to people who have asked to speak at the hearing. The Court will then issue decisions on these issues; we do not know how long those decisions will take.

Please note that the date of the Final Approval Hearing date may change by the Court’s order without further notice to the Class. It is strongly advised to check the Settlement Website to confirm that the date has not been changed.

No. Class Counsel will answer any questions that the Court may have, but you may come at your own expense. If you send an objection, you do not have to come to Court to talk about it. As long as you submit your written objection by February 9, 2026, in accordance with the instructions in this Notice (see Question 17 above) the Court will consider it. You may also pay your lawyer to attend, but you do not have to.

Yes. If you do not exclude yourself, you may appear and speak at the Final Approval Hearing. Although it is not required, if you intend to appear and speak, you are requested to file with the Court and/or serve on the Parties a “Notice of Intent to Appear,” no later than (7) days before the Final Approval Hearing. Persons who opt out, however, may not appear and be heard.

If you do nothing, you will not get a payment from the Settlement. Unless you exclude yourself, you will not be able to start a lawsuit, or be part of any other lawsuit against Seamless about the claims in this case, ever again.

This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement, available HERE. If you have additional questions, you can visit the Settlement Website or contact the Settlement Administrator:

By Mail:	Seamless Settlement Administrator PO Box 671 Baton Rouge, LA 70821
By Email:	info@SeamlessSettlement.com
By Phone (Toll Free):	1-833-580-0090

Updates will be posted at the Settlement Website, as information about the Settlement process becomes available.

For a more detailed statement of the matters involved in the litigation or the Settlement, you may review the various documents on the Settlement Website HERE, call 1-833-580-0090, or write to the Seamless Settlement Administrator, PO Box 671, Baton Rouge, LA 70821.