1. Why was the Notice issued?
2. What is a class action?
3. What is this lawsuit about?
4. Why is there a settlement?
5. How do I know if I am in the Settlement Class?
6. What does the Settlement provide?
7. How much will my payment be?
8. When will I get my payment?
9. How do I get a payment?
10. What am I giving up if I stay in the Class?
11. What happens if I do nothing at all?
12. Do I have a lawyer in the case?
13. How will the lawyers be paid?
14. How do I get out of the Settlement?
15. If I don’t exclude myself, can I sue the Defendant for the same thing later?
16. If I exclude myself, can I get anything from this Settlement?
17. How do I object to the Settlement?
18. What’s the difference between objecting and excluding myself from the Settlement?
19. When and where will the Court decide whether to approve the Settlement?
20. Do I have to come to the hearing?
21. May I speak at the hearing?
22. Where do I get more information?
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 case is called Geoffrey Cavalier v. University Health Systems, Inc. d/b/a The University of Tennessee Medical Center, Case No. 207369-2, pending in the Chancery Court for Knox County, Tennessee. The person who sued is called the Plaintiff. The Defendant is University Health Systems, Inc. d/b/a The University of Tennessee Medical Center (“UTMC”).
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In a class action, one or more people called the Class Representatives (in this case, Geoffrey Cavalier) sued 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.
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This lawsuit claims that Defendant violated the law by disclosing patients’ confidential personally identifiable information (“PII”) and/or protected health information (“PHI”) (collectively referred to as “Private Information”) to third-party technologies without consent. UTMC contends that the third-party technologies were not enabled on UTMC’s patient portal and that no PHI for any visitor to www.utmedicalcenter.org was transmitted to any third party. Defendant firmly denies all of Plaintiff’s claims in the lawsuit and maintains that it did nothing wrong.
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By agreeing to settle, both sides avoid the cost and risk of a trial, and people who submit valid, timely Claims will get compensation. The Class Representative and his counsel believe the settlement is fair, reasonable, and adequate and, thus, best for the Settlement Class and its members. The Settlement does NOT mean that Defendant did anything wrong.
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The Settlement Class is defined as:
“All patients of UTMC residing in the United States who had a patient portal account with UTMC between January 1, 2015, to and through September 30, 2023.”
Excluded from the Settlement Class are: (1) any Judge(s) presiding over this Action, any members of the Judges’ respective staffs, and immediate members of the Judge’s family; (2) officers and directors of the Defendant, its agents, affiliates, subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendant or its parents have a controlling interest; (3) persons who timely and validly request exclusion from and/or opt-out of the Settlement Class; (4) the legal representatives, successors or assigns of any such excluded persons; (5) Class Counsel; and (6) any person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the criminal activity occurrence of the Security Incident, or who pleads nolo contendere to any such charge.
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Monetary Relief and Privacy Shield Pro Product: Each Settlement Class Member will automatically receive a code and a link to instructions to enroll in the Privacy Shield Pro product. The code is listed at the top of the Notice. Each Settlement Class Member who files a timely, valid Claim will also have the option to select a cash payment of $25.00. To submit a Claim, you can do so online here, or you may download a paper claim form here.
In addition, Defendant has agreed to pay the costs of Notice and Settlement Administration Expenses, approved attorneys’ fees and costs to Class Counsel, and an Incentive Award to the Class Representative if approved by the Court.
A detailed description of the Settlement benefits can be found in the Settlement Agreement.
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You must submit a timely and valid Claim Form to receive a payment. If you submit a valid Claim Form and elect to receive a cash payment, you will receive a $25.00 cash payment.
You must verify you are a Settlement Class Member when filing a Claim by providing the Class Member Login ID and Class Member Password on the Notice you received by email. If for some reason you did not receive this information, but believe you are a Settlement Class Member, please email info@UTMCSettlement.com to verify your identity and receive your Class Member Login ID and Class Member Password.
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The hearing to consider the fairness of the settlement is scheduled for December 8, 2025, at 1:30 p.m. If the Court approves the Settlement, eligible Class Members whose Claims were approved by the Settlement Administrator will receive their payment thirty (30) days after the Settlement has been finally approved and any appeals process is complete. The payment will be made in the form of a check, unless you elect to receive payment by PayPal, Venmo, or Zelle, and all checks will expire and become void one-hundred eighty (180) days after they are issued.
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You must complete and submit a Claim Form to receive a payment. You may submit a Claim Form either electronically here or by printing and mailing in a paper Claim Form, copies of which are available for download here. Claim Forms must be submitted online by 11:59 p.m. EST on December 9, 2025, or postmarked and mailed by December 9, 2025.
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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 Defendant. You will be “releasing” the Defendant and their affiliates described in Section 1.26 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 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.
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If you do nothing, you won’t get any benefits from this Settlement. But, unless you exclude yourself, you won’t be able to start a lawsuit or be part of any other lawsuit against the Defendant for the claims being resolved by this Settlement.
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The Court has appointed law firms CohenMalad, LLP, Stranch, Jennings & Garvey, PLLC, and Strauss Borelli PLLC to be the attorneys representing the Settlement Class. They are called “Class Counsel.” They believe, after conducting a thorough 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.
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Class Counsel’s attorneys’ fees, costs, and expenses will be paid separately by Defendant and awarded by the Court. Class Counsel is entitled to seek no more than $1,000,000.00, but the Court may award less than this amount.
As approved by the Court, the Class Representative will be paid an Incentive Award by Defendant for helping to bring and settle the case. The Class Representative may seek up to $3,500.00 as an Incentive Award, but the Court may award less than this amount.
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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 Settlement. Your letter or request must be in writing and must: (1) identify the case name and number (Geoffrey Cavalier v. University Health Systems, Inc. d/b/a The University of Tennessee Medical Center,Case No. 207369-2); (2) state the name. current address, telephone number, and unique ID of the Class Member seeking exclusion; (3) be physically signed by the person(s) seeking exclusion; and (4) must also contain a statement to the effect that “I hereby request to be excluded from the Settlement Class for purposes of this Settlement.” You must mail or deliver your exclusion request no later than November 10, 2025, to:
The University of Tennessee Medical Center Settlement
c/o Simpluris
P.O. Box 25226
Santa Ana, CA 92799
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No. Unless you exclude yourself, you give up any right to sue the Defendant for the claims being resolved by this Settlement.
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No. If you exclude yourself, you will not be entitled to any benefits of the Settlement, and you should not submit a Claim Form to ask for benefits.
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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 a letter or brief stating that you object to the Settlement in Geoffrey Cavalier v. University Health Systems, Inc. d/b/a The University of Tennessee Medical Center, Case No. 207369-2, which must be personally signed, and identify all reasons for your objections. Your letter or brief must include: (1) the objector’s name, address, and telephone number; (2) an explanation of the basis upon which the objector claims to be a Settlement Class Member; (3) all grounds for the objection, including all citations to legal authority and evidence supporting the objection; (4) the name and contact information of any and all attorneys representing, advising, or in any way assisting the objector in connection with the preparation or submission of the objection or who may profit from the pursuit of the objection (the “Objecting Attorneys”); (5) a statement indicating whether the objector intends to appear at the Final Approval Hearing (either personally or through counsel who files an appearance with the Court in accordance with the Local Rules); and (6) a list, by case name, court, and docket number, of all other cases in which the objector and/or the Objecting Attorneys have filed an objection to any proposed class action settlement within the last three (3) years.
All objections must be submitted to the Settlement Administrator, Class Counsel identified below, and to the Court. Class Counsel’s Motion for Fee Award will be filed with the Court and posted on the Settlement Website.
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 21), 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 November 10, 2025.
Court | Class Counsel | Defendant’s Counsel |
Clerk’s Office | J. Gerard Stranch, IV | Samuel L. Felker |
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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 Settlement Class. If you exclude yourself, you have no basis to object because the case no longer affects you.
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The Court will hold the Final Approval Hearing at 1:30 p.m. EST on December 8, 2025, before Chancellor Armstrong, Division II, Courtroom 138 at the Chancery Court for Knox County, Tennessee, 400 Main St SW, Knoxville, Tennessee 37902. The hearing may be held remotely, and if so, instructions will be posted on this website. The purpose of the hearing will be for the Court to determine: 1) whether to approve the Settlement as fair, reasonable, adequate, and in the best interests of the Settlement Class; 2) to consider the Class Counsel’s request for attorneys’ fees and expenses; and 3) to consider the request for an Incentive Award to the Class Representative. 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 it is a good idea to check the Important Dates page or call (833) 417-4897.
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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 for your own lawyer to attend, but it’s not required.
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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 it is your “Notice of Intent to Appear in Geoffrey Cavalier v. University Health Systems, Inc. d/b/a The University of Tennessee Medical Center, Case No. 207369-2.” 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 November 10, 2025, and be sent to the addresses listed in Question 17.
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This website summarizes the Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement and other documents on the Important Documents page. You may also write with questions to The University of Tennessee Medical Center Settlement, c/o Simpluris, P.O. Box 25226, Santa Ana, CA 92799. You can call the Settlement Administrator at (833) 417-4897 or Class Counsel at (615) 254-8801, if you have any questions. Before doing so, however, please read the full Notice carefully.
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