Themis VPPA Settlement

A Court authorized the 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. The Notice explains the lawsuit, the Settlement, and your legal rights.

The Honorable Steven C. Seeger, of the United States District Court for the Northern District of Illinois, is overseeing this case. The case is called Sahagún v. Themis Bar Review, LLC, Case No. 1:24-cv-02065. The person who has sued is called the Plaintiff. The Defendant is Themis Bar Review, LLC.

In a class action, one or more people called the Class Representative (in this case, Sophia Sahagún) 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 claims that Defendant violated the Video Privacy Protection Act, 18 U.S.C. § 2710, et seq. (“VPPA”) by disclosing its subscribers’ personally identifiable information (“PII”) to Facebook via the Facebook Tracking Pixel without consent. The VPPA defines PII to include information which identifies a person as having requested or obtained specific video materials or services from a video tape service provider. The Defendant denies that it violated any law. The Court has not determined who is right. Rather, the Parties have agreed to settle the lawsuit to avoid the uncertainties and expenses associated with ongoing litigation.

The Court has not decided whether the Plaintiff or the 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 Class Members will get compensation sooner rather than, if at all, after the completion of a trial.

The Settlement Class is defined as:

All persons in the United States who, from March 12, 2022, to and through August 22, 2024: (1) have or had a Facebook account; (2) also had a digital subscription to Themis Bar Review; and (3) who viewed videos on Themis’s website while their Facebook membership was active.

Monetary Relief: Defendant has created a Settlement Fund totaling $2,250,000.00. Class Member payments, and the cost to administer the Settlement, the cost to inform people about the Settlement, attorneys’ fees, and an award to the Class Representative will also come out of this fund (see Question 13).

A detailed description of the Settlement benefits can be found in the Settlement Agreement.

If you are member of the Settlement Class, you may submit a Claim Form to receive a portion of the Settlement Fund. The amount of this payment will depend on how many of the Class Members file valid Claims. Each Class Member who files a valid Claim will receive a proportionate share of the Settlement Fund, which Class Counsel anticipates will be approximately $263-$526. You can contact Class Counsel at 1-646- 837-7150 to inquire as to the number of Claims filed.

The Final Approval Hearing to consider the fairness of the Settlement is scheduled for March 16, 2026. If the Court approves the Settlement, eligible Class Members whose Claims were approved by the Settlement Administrator will receive their payment 90 days after the Settlement has been finally approved and/or any appeals process is complete. The payment will be made in the form of a check, unless you elect to receive payment by PayPal, Zelle, or Venmo, and all checks will expire and become void 180 days after they are issued.

If you are a Class Member and you want to get a payment, you must complete and submit a Claim Form by February 6, 2026. Claim Forms can be found and submitted here or by printing and mailing a paper Claim Form, copies of which are available for download on the Documents page.

If the Settlement becomes Final, you will give up your right to sue Defendant for the claims this Settlement resolve. The Settlement Agreement describes the specific claims you are giving up against the Defendants. You will be “releasing” the Defendant and certain of its affiliates described in Section 1.24 of the Settlement Agreement. Unless you exclude yourself (see Question 14), you are “releasing” the claims, regardless of whether you submit a claim or not. The Settlement Agreement is available through the “court documents” link on the website.

The Settlement Agreement describes the released claims with specific descriptions, so read it carefully. If you have any questions you can talk to the lawyers listed in Question 12 for free or you can, of course, talk to your own lawyer if you have questions about what this means.

The Court has appointed Philip L. Fraietta and Alec M. Leslie of Bursor & Fisher, P.A. to be the attorneys representing the Settlement Class. They are called “Class Counsel.” They believe, after conducting an extensive investigation, that the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your expense.

The Court has appointed Philip L. Fraietta and Alec M. Leslie of Bursor & Fisher, P.A. to be the attorneys representing the Settlement Class. They are called “Class Counsel.” They believe, after conducting an extensive investigation, that the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one at your 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 no more than 35% of the $2.25 million Settlement Fund, less settlement administration expenses and any incentive award, but the Court may award less than this amount.

As approved by the Court, the Class Representative will be paid an Incentive Award from the Settlement Fund for helping to bring and settle the case. The Class Representative will seek no more than $5,000 as an incentive award, but the Court may award less than this amount.

To exclude yourself from the Settlement, you must mail or otherwise deliver a letter (or request for exclusion) stating that you want to be excluded from the Sahagún v. Themis Bar Review, LLC, Case No. 1:24-cv-02065 settlement. Your letter or request for exclusion must also include your name, your address, your signature, the name and number of this case, and a statement that you wish to be excluded. You must mail or deliver your exclusion request no later than February 6, 2026 to:

Themis VPPA Settlement
Settlement Administrator
PO Box 5715
Portland, OR 97228-5715

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

No. If you exclude yourself, do not submit a Claim Form to ask for benefits.

If you’re a Class Member, you can object to the Settlement if you don’t like any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views. To object, you must file with the Court a letter or brief stating that you object to the Settlement in Sahagún v. Themis Bar Review, LLC, Case No. 1:24- cv-02065 and identify all your reasons for your objections (including citations and supporting evidence) and attach any materials you rely on for your objections. Your letter or brief must also include your name, an explanation of the basis upon which you claim to be a Settlement Class Member, including information sufficient to identify your current Facebook page or a screenshot showing that you were a Facebook member during the class period, the name and contact information of any and all attorneys representing, advising, or in any way assisting you in connection with your objection, and your signature. If you, or an attorney assisting you with your objection, have ever objected to any class action settlement where you or the objecting attorney has asked for or received payment in exchange for dismissal of the objection (or any related appeal) without modification to the settlement, you must include a statement in your objection identifying each such case by full case caption. You must also mail or deliver a copy of your letter or brief to Class Counsel and Defendant’s Counsel listed below.

Class Counsel will file with the Court and post on this website its request for attorneys’ fees by January 23, 2026.

If you want to appear and speak at the Final Approval Hearing to object to the Settlement, with or without a lawyer (explained below in answer to Question 12), you must say so in your letter or brief. File the objection with the Court and mail a copy to these two different places postmarked no later than February 6, 2026.

Objecting simply means telling the Court that you don’t like something about the Settlement. You can object only if you stay in the Class. Excluding yourself from the Class is telling the Court that you don’t want to be part of the Class. If you exclude yourself, you have no basis to object because the case no longer affects you.

The Final Approval Hearing was held on March 16, 2026. The Court granted final approval of the Settlement on March 18, 2026. A copy of the Order is on the Documents page.

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 come to Court to talk about it. As long as you filed and mailed your written objection on time, the Court will consider it. You may also pay another lawyer to attend, but it’s not required.

Yes. You may ask the Court for permission to speak at the Fairness Hearing. To do so, you must include in your letter or brief objecting to the settlement a statement saying that it is your “Notice of Intent to Appear in Sahagún v. Themis Bar Review, LLC, Case No. 1:24-cv-02065.” It must include your name, address, telephone number and signature as well as the name and address of your lawyer, if one is appearing for you. Your objection and notice of intent to appear must be filed with the Court and postmarked no later than February 6, 2026 and be sent to the addresses listed in Question 17.

The Notice summarizes the Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement here. You may also write with questions to:

Themis VPPA Settlement
Settlement Administrator
PO Box 5715
Portland, OR 97228-5715

You can call the Settlement Administrator at 1-877-570-6187 or Class Counsel at 1-646-837-7150, if you have any questions. Before doing so, however, please read this full Notice carefully. You may also find additional information here.