Frequently Asked Questions

The Court authorized the Notice because you have a right to know about the Settlement, and all of your options, before the Court decides whether to give “final approval” to the Settlement. The Notice explains the nature of the Lawsuit that is the subject of the Settlement, the general terms of the Settlement, and your legal rights and options.

United States District Judge Micheal L. Liburdi of the District of Arizona is overseeing this case captioned as Anderson, et al. v. U-Haul International Inc., Case No. CV-22-01565. The people who brought the Lawsuit are called the Plaintiffs. The Plaintiffs are Michelle Anderson, Saray Hendricks, Peter Telford, Hulises Rolon, Denise Bowen, Bryan Bowen, Mark Johnson, Gerardo Rivera, and Ariana Allen. The entity being sued, U-Haul International Inc. is called the Defendant.

The Lawsuit claims that Defendant was responsible for two Data Incidents and asserted claims such as negligence, breach of implied contract, violation of the Driver’s Privacy Protection Act, violations of the Arizona Consumer Fraud Act, violation of the California Consumer Privacy Act, violation of California’s Unfair Competition Law, violation of Oregon’s Unlawful Trade Practices Act, violation of New York’s General Business Law, violation of the Indiana Deceptive Consumer Sales Act, violation of Pennsylvania’s Unfair Trade Practices and Consumer Protection Law, violation of Virginia Consumer Protection Act, declaratory judgment, unjust enrichment, breach of fiduciary duty, breach of the implied covenant of good faith and fair dealing, invasion of privacy, violation of the Washington Consumer Protection Act, and violation of the Arizona Consumer Fraud Act. The Court issued two motion to dismiss rulings and ultimately permitted only Plaintiffs’ California Consumer Privacy Act, Cal. Civ. Code § 1798.100, et seq. (“CCPA”) claim to proceed. Plaintiffs filed a Second Amended Consolidated Complaint (“Complaint”) on May 8, 2024, naming additional Class Representatives who are residents of the State of California. 

Defendant denies these claims and says it did not do anything wrong. No court or other judicial entity has made any judgment or other determination that Defendant has any liability for these claims or did anything wrong.

In a class action, one or more people called Settlement Class Representatives or Plaintiffs sue on behalf of all people who have similar claims. Together, all of these people are called a class, and the individuals are called Settlement Class Members. One court resolves the issues for all Settlement Class Members, except for those who exclude themselves from the Settlement Class.

The Court has not decided in favor of the Plaintiffs or Defendant. Instead, both sides agreed to the Settlement. The Settlement avoids the cost and risk of a trial and related appeals, while providing benefits to members of the Settlement Class (“Settlement Class Members”). The Settlement Class Representatives appointed to represent the Settlement Class and the attorneys for the Settlement Class (“Class Counsel,” see Question 17) think the Settlement is best for all Settlement Class Members.

You are affected by the Settlement and potentially a Settlement Class Member if you reside in California and your Private Information was accessed or potentially accessed in connection with the 2022 and/or 2023 Data Incident, including if you were mailed a notification by or on behalf of U-Haul regarding either Data Incident.

Only Settlement Class Members are eligible to receive benefits under the Settlement. Specifically excluded from the Settlement Class are (1) the judge presiding over the class action Lawsuit and the judge’s direct family members; (2) the Defendant, its subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendant or its parents have a controlling interest, and their current or former officers, directors, and employees; and (3) Settlement Class Members who submit a valid request to be excluded from the Settlement.

If you are not sure whether you are included in the Settlement, you may call (833) 462-3470 with questions.  You may also write with questions to:

Anderson, et al. v. U-Haul International Inc.

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324

The Settlement permits each Settlement Class Member who submits a valid Claim Form to a Pro Rata Monetary Payment of approximately $100 from the $5,085,000 Settlement Fund.  

The estimated $100 Pro Rata Monetary Payment will be dispersed after the distribution of attorneys’ fees, Class Counsel’s litigation expenses, Settlement Class Representative Service Awards, and Notice and Settlement Administration Expenses. Also, as part of the Settlement, Defendant either has undertaken or will undertake certain reasonable steps to further secure its systems and environments. Notably, the Pro Rata Monetary Payment is based on 10% of the roughly 259,300 Settlement Class Members submitting valid claims under the Settlement. If only 5% of the roughly 259,300 Settlement Class Members submit valid claims under the Settlement, the Pro Rata Monetary Payment is then expected to exceed $200 per valid claim. There are approximately 2,458 Settlement Class Members involved in both the 2022 Data Incident and the 2023 Data Incident. These 2,458 Settlement Class Members will be eligible to submit claims for two Pro Rata Monetary Payments under the Settlement.

To receive a benefit under the Settlement, you must complete and submit a claim for that benefit (a “Claim”). Every Claim must be made on a form (“Claim Form”) available for online filing here, or also available to download for mailing here. Claim Forms will also be sent to Settlement Class Members as part of the postcard Notice and tear-off Claim Form that will be mailed to Settlement Class Members. Read the instructions carefully, fill out the Claim Form, provide the required documentation, and submit it according to the instructions on the Claim Form.

The Settlement Administrator, Kroll Settlement Administration LLC, will decide whether and to what extent any Claim made on each Claim Form is valid. The Settlement Administrator may require additional information. If you do not provide the additional information in a timely manner, then the Claim will be considered invalid and will not be paid.

The Court will hold a Final Approval Hearing on October 23, 2024, at 10:00 a.m. MST to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals from that decision and resolving those can take time, perhaps more than a year. It also takes time for all the Claim Forms to be processed.  Please be patient.

The Defendant gets a release from all claims covered by this Settlement. Thus, if the Settlement becomes Final and you do not exclude yourself from the Settlement, you will be a Settlement Class Member and you will give up your right to sue Defendant and other persons (“Released Parties”) as to all claims (“Released Claims”) arising out of or relating to either Data Incident. This release is described in the Settlement Agreement, which is available here. If you have any questions you can talk to the law firms listed in Question 17 for free or you can talk to your own lawyer.

No. If you exclude yourself, you will not be entitled to receive any benefits from the Settlement, but you will not be bound by any judgment in this case.

No. Unless you exclude yourself, you give up any right to sue Defendant (and any other Released Parties) for the claims that this Settlement resolves. You must exclude yourself from the Settlement Class to start your own lawsuit or to be part of any different lawsuit relating to the claims in this case. If you want to exclude yourself, do not submit a Claim Form to ask for any benefit under the Settlement.

To exclude yourself, send a letter that says you want to be excluded or opt-out (“Opt-Out Request”) from the Settlement in Anderson, et al. v. U-Haul International Inc., Case No. CV-22-01565 to the Settlement Administrator so that it is postmarked by September 16, 2024. For a Settlement Class Member’s Opt-Out Request to be valid, it must (a) state his or her full name, address, and telephone number; (b) contain the Settlement Class Member’s personal signature (or the signature of a Person previously authorized by law, such as a trustee, guardian, or Person acting under a power of attorney to act on behalf of the Settlement Class Member with respect to a claim or right, such as those in the Lawsuit); and (c) clearly manifest the Settlement Class Member’s intent to be excluded from the Settlement Class, to be excluded from the Settlement, not to participate in the Settlement, and/or to waive all rights to the benefits of the Settlement. The Settlement Administrator shall promptly inform Class Counsel and U-Haul Counsel of any Opt-Out Requests. You must mail your Opt-Out Request postmarked by September 16, 2024, to:

Anderson, et al. v. U-Haul International Inc.

c/o Kroll Settlement Administration LLC

Attn: Exclusion Request

PO Box 5324

New York, NY 10150-5324

You can tell the Court that you do not agree with the Settlement or some part of it by objecting to the Settlement. The Court will consider your views in its decision on whether to approve the Settlement. The Court can only approve or deny the Settlement and cannot change its terms. To object, timely written notice of an objection in the appropriate form must be filed with the Clerk of the Court on or before September 16, 2024, and must be mailed to Class Counsel and U-Haul’s Counsel with a postmarked date no later than September 16, 2024. The address for the Clerk of Court is Untied States District Court of Arizona – Phoenix Division, Sandra Day O’Connor U.S. Courthouse, Suite 130, 401 West Washington Street, SPC 1, Phoenix, Arizona 85003. 

Your objection must be written and must include all of the following: (i) state the objecting Settlement Class Member’s full name, current address, telephone number, and email address (if any); (ii) contain the objecting Settlement Class Member’s signature; and (iii) set forth a statement of all grounds for the objection, including any legal support for the objection that the objector believes applicable.

To be timely, an Objection in the appropriate form must be filed with the Clerk of the Court no later than September 16, 2024, and must be mailed to Class Counsel and U-Haul’s Counsel with a postmarked date no later than September 16, 2024.

Objecting is telling the Court that you do not like the Settlement and why you do not think it should be approved. You can object only if you are a Settlement Class Member. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class and do not want to receive any payment or benefit from the Settlement. If you exclude yourself, then you have no basis to object because you are no longer a member of the Settlement Class, and the case no longer affects you. If you submit both a valid Objection and a valid request to be excluded, you will be deemed to have only submitted the request to be excluded.

Yes. The Court appointed Terence R. Coates of Markovits, Stock & DeMarco, LLC as Class Counsel to represent the Class. Mr. Coates may be contacted at 119 E. Court Street Suite 530, Cincinnati, OH 45202; Email: [email protected]; Phone (513) 651-3700.

Plaintiffs’ counsel who worked with Class Counsel to represent Plaintiffs in this matter, including M. Anderson Berry, Arnold Law Firm; Gary M. Klinger, Milberg Coleman Bryson Phillips Grossman PLLC; Kiley L. Grombacher, Bradley Grombacher LLP; Cristina Perez Hesano, Perez Law Group LLP; A. Brooke Murphy, Murphy Law Firm; Ryan D. Maxey, Maxey Law Firm PA; William B. Federman, Federman & Sherwood; John Y. Yanchunis, Morgan & Morgan; Marc E. Dann, Dann Law; Courtney Maccarone, Levi & Korsinsky LLP; and, Thomas A. Zimmerman, Jr., Zimmerman Law Offices PC. 

If you seek to be represented by your own lawyer, then you may hire one at your own expense.

Class Counsel will ask the Court for an award for attorneys’ fees up to 30% of the Settlement Fund ($1,525,500), plus reasonable litigation expenses not to exceed $70,000, as well as Service Awards of $2,000 for each Settlement Class Representative (“Service Award”). Defendant has not agreed to any award of attorneys’ fees, costs, and expenses up to those amounts, to the extent they are approved by the Court. This payment for any attorneys’ fees and expenses to Class Counsel and Plaintiffs’ Counsel and Service Awards will be made out of the Settlement Fund. Any such award would compensate Class Counsel and Plaintiffs’ Counsel for investigating the facts, litigating the case, and negotiating the Settlement and will be the only payment to them for their efforts in achieving this Settlement and for their risk in undertaking this representation on a wholly contingent basis.

Any award for attorneys’ fees and expenses for Class Counsel and Plaintiffs’ Counsel and any Service Awards must be approved by the Court. The Court may award less than the amount requested. Class Counsel’s papers in support of final approval of the Settlement will be filed no later than October 9, 2024, and their application for attorneys’ fees, costs, and expenses will be filed no later than September 2, 2024, and will be posted on this Settlement Website.

The Court will hold a Final Approval Hearing at 10:00 a.m. MT on October 23, 2024, at the Sandra Day O’Connor U.S. Courthouse, 401 W. Washington St., Suite 130, SPC 1, Phoenix, AZ 85003 or by remote or virtual means as ordered by the Court. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are timely and valid Objections, then the Court will consider them and will listen to people who have asked to speak at the hearing if such a request has been properly made. The Court will also rule on the request for an award of attorneys’ fees, reasonable costs and expenses, and any Service Awards. After the hearing the Court will decide whether to approve the Settlement. We do not know how long these decisions will take. The hearing may be moved to a different date or time without additional notice. Class Counsel recommends checking this Settlement Website, or calling (833) 462-3470 before the date of the Final Approval Hearing for any updates.

No. Class Counsel will present the Settlement Agreement to the Court. You or your own lawyer are welcome to attend at your expense, but you are not required to do so. If you send an Objection, you do not have to visit the Court to talk about it. As long as you filed your written objection on time with the Court and mailed it according to the instructions provided in Question 15, the Court will consider it.

You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must file an objection according to the instructions in Question 15, including all the information required. Your objection must be filed with the Clerk of the Court no later than September 16, 2024. See No. 15 for further details on the requirements for submitting an objection to the Settlement.

If the objecting Settlement Class Member intends to appear at the Final Approval Hearing through counsel, the notice of appearance filed with the Court must also identify the attorney(s) representing the objector who will appear at the Final Approval Hearing and include each such attorney’s name, address, phone number, email address, state bar(s) to which counsel is admitted. 

If you do nothing you will not get any money from this Settlement. If the Settlement is granted final approval and the judgment becomes Final, then you will not be able to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against Defendant and the other Released Parties based on any of the Released Claims related to the Data Incidents, ever again.

It is your responsibility to inform the Settlement Administrator of your updated information. You may do so at the address below, by calling (833) 462-3470, or by contacting the Settlement Administrator using the Contact section of this Settlement Website:

Anderson, et al. v. U-Haul International Inc.

c/o Kroll Settlement Administration LLC

PO Box 5324

New York, NY 10150-5324

The Notice summarizes the proposed Settlement. More details are in the Settlement Agreement itself. A copy of the Settlement Agreement is available here. You may also call the Settlement Administrator with questions or to receive a Claim Form at (833) 462-3470.

The Notice is approved by the United States District Court for the District of Arizona. DO NOT CONTACT THE COURT DIRECTLY IF YOU HAVE QUESTIONS ABOUT THE SETTLEMENT. Please contact the Settlement Administrator or Class Counsel if you have any questions about the Settlement.