Frequently Asked Questions

Basic Information

1. Why was the Notice issued?

The Ross County Court of Common Pleas, Ohio, authorized the Notice. You have a right to know about the proposed Settlement of this class action lawsuit, and about all of your options, before the Court decides whether to grant final approval of the Settlement. The Notice explains the Litigation, your legal rights, what benefits are available, and who can receive them.

The Litigation is called Jarrell v. Adena Health System, Case No. 25CI000419. It is pending in the Ross County Court of Common Pleas, Ohio. The person that filed this lawsuit is called the “Plaintiff” (or “Class Representative”) and the company they sued, Adena Health System, is called the “Defendant.”

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2. What is this lawsuit about?

The Litigation alleges that Adena used third-party tracking technologies, called “tracking pixels,” on its website in a way that violates certain privacy laws.

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3. What is a class action?

In a class action, one or more individuals sue on behalf of other people with similar claims. This individual is called the “Plaintiff” or “Class Representative.” Together, the people included in the class action are called a “Class” or “Class Members.” One court resolves the lawsuit for all Class Members, except for those who opt out from the settlement. In this Settlement, the Class Representative is Robin Jarrell. Everyone included in the Litigation are the Class Members.

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4. Why is there a Settlement?

The Court did not decide whether the Plaintiff or the Defendant are right. Both sides have agreed to a Settlement to avoid the costs and risks of a trial, and to allow the Class Members to receive benefits from the Settlement. The Plaintiff and their attorneys think the Settlement is best for all Class Members.

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Who is in the Settlement?

5. Who is included in the Settlement?

The court has defined the Class this way: “All patients of Defendant who logged into its patient portal between November 1, 2022 and June 3, 2024.”

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6. Are there exceptions to being included?

Yes. Excluded from the Class are: (1) the Judge in this case, and the Judge’s family and staff; (2) Adena and its employees, officers, and directors; (3) Adena's Counsel and in-house counsel; and (4) anyone who validly excludes themselves from the Settlement.

If you are not sure whether you are a Class Member, you can ask for free help any time by contacting the Settlement Administrator at:

Adena Tracking Tools Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 417-4976
info@AdenaPixelSettlement.com

You may also view the Settlement Agreement here.

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The Settlement Benefits

7. What does the Settlement provide?

Adena has agreed to pay for two benefits that are available to all Class Members. You may file a claim for one or both of these benefits.

Privacy Monitoring. All Class Members are eligible to enroll in one year of CyEx Privacy Shield Global. This comprehensive service is designed to restore users' privacy and anonymity, and includes:

  • Dark Web scanning

  • compromised password scanning

  • VPN, password manager, and other online privacy tools

If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.

Cash Payment. All Class Members may claim a one-time $21.00 cash payment. You do not have to provide any proof or explanation to claim this payment.

If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at:

Adena Tracking Tools Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 417-4976
info@AdenaPixelSettlement.com

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8. What claims am I releasing if I stay in the Class?

If you stay in the class, you won’t be able to be part of any other lawsuit against Adena about the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section 3) describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available here.

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Submitting a Claim Form for a Settlement Payment

9. How do I submit a claim for a Settlement benefit?

The fastest way to submit your Claim Form is online. If you prefer, you can download a printable Claim Form and mail it to the Settlement Administrator.

You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (833) 417-4976, or by email info@AdenaPixelSettlement.com.

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10. Are there any important Settlement payment deadlines?

If you are submitting a Claim Form online, you must do so by March 6, 2026. If you are submitting a claim by U.S. mail, the completed and signed Claim Form, must be postmarked no later than March 6, 2026.

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11. When will the Settlement benefits be issued?

The Court will hold a final approval hearing on May 29, 2026 (see Question 18). If the Court approves the Settlement, there may be appeals. We do not know if appeals will be filed, or how long it will take to resolve them if they are filed.

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The Lawyers Representing You

12. Do I have a lawyer in the case?

Yes, the Court has appointed attorneys Joseph M. Lyon of The Lyon Firm; Gary M. Klinger of Milberg Coleman Bryson Phillips Grossman PLLC; Philip J. Krzeski of Chestnut Cambronne PA; and Terence R. Coates and Dylan J. Gould of Markovits Stock & DeMarco, LLC, to represent you and other Class Members (“Class Counsel”).

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13. Should I get my own lawyer?

You will not be charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense.

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14. How will Class Counsel be paid?

Class Counsel will ask the court to approve $555,000.00 as reasonable attorneys' fees and costs of litigation. This amount will be paid by Adena. Class Counsel will also ask for a Service Award payment of $2,500.00 for the Class Representative (the “Service Award”). The Service Award payment will also be paid by Adena.

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Excluding Yourself from the Settlement

15. How do I opt out of the Settlement?

If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement (a “Request for Exclusion”), also referred to as “opting out.” If you opt out, you are telling the Court that you do not want to be part of the Settlement, and you will not receive Settlement benefits or payment. However, you will keep any rights you may have to sue Adena on your own about the legal issues in the Litigation. If you exclude yourself, you are telling the Court that you do not want to be part of the Settlement. You will not be eligible to receive any Settlement benefits if you exclude yourself. The deadline to exclude yourself from the Settlement is February 4, 2026.

To be valid, your Request for Exclusion must have the following information:

  1. the name of the Litigation: Jarrell v. Adena Health System, Case No. 25CI000419, pending in the Court of Common Pleas for Ross County, Ohio;

  2. your full name, mailing address, telephone number, and email address;

  3. personal signature; and

  4. the words “Request for Exclusion” or a clear and similar statement that you do not want to participate in the Settlement.

You may only exclude yourself—not any other person.

Mail your Request for Exclusion to the Settlement Administrator at:

Adena Tracking Tools Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

Your Request for Exclusion must be submitted, postmarked, or emailed by February 4, 2026.

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Commenting on or Objecting to the Settlement

16. How do I tell the Court if I like or do not like the Settlement?

you are a Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reason(s) why you think the Court should not approve the Settlement. The Court will consider your views.

You cannot object if you have excluded yourself from the Settlement (see Question 15)

You must provide the following information for the Court to consider your objection:

  1. the name of the Litigation: Jarrell v. Adena Health System, Case No. 25CI000419, pending in the Court of Common Pleas for Ross County, Ohio;

  2. your full name, mailing address, telephone number, and email address;

  3. information that proves that you are a Class Member (such as a notice you have received, or proof that you used the patient portal between November 1, 2022 and June 3, 2024);

  4. a clear description of all the reasons you object; include any legal support, such as documents or citations to legal authority, you may have for your objection;

  5. if you have hired your own lawyer in connection with this objection, provide their name, bar number, and contact information (address, telephone number, and email address);

  6. if you have hired your own lawyer, their signed statement or certificate of representation;

  7. if you or your lawyer have objected in any other cases in the past three years, list the names, courts, and civil action numbers for each of those cases;

  8. whether or not you or your lawyer would like to speak at the Final Approval Hearing;

  9. if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a full list of both;

  10. your signature.

For your objection to be valid, it must meet each of these requirements.

To be considered by the Court, you must file your complete objection with the Clerk of Court by February 4, 2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and counsel for Defendant.

Clerk of the Court

Settlement Administrator

Clerk of the Court
2 North Paint Street
Chillicothe, OH 45601

Adena Tracking Tools Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799

Class Counsel

Counsel for Defendant

Dylan J Gould
Markovits, Stock & DeMarco, LLC
119 E. Court Street, Suite 530
Cincinnati, OH 45202

Christopher G. Dean
McDonald Hopkins LLC
600 Superior Avenue East, Suite 2100
Cleveland, OH 44114

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17. What is the difference between objecting and excluding?

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 opting out and stating to the Court that you do not want to be part of the Settlement. If you opt out of the Settlement, you cannot object to it because the Settlement no longer affects you.

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The Court's Final Approval Hearing

18. When is the Court’s Final Approval Hearing?

The Court will hold a final approval on May 29, 2026, at 2:00 p.m. Eastern Time, at The Ross County Court of Common Pleas, 2 North Paint Street, Courtroom #1, Chillicothe, OH 45601. At the final approval hearing, the Court will decide whether to approve the Settlement. The court will also decide how Class Counsel should be paid, and whether to award a Service Award payment to the Class Representative. The Court will also consider any objections to the Settlement.

If you are a Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see Question 16).

The date and time of this hearing may change without further notice. Please check this website for updates.

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19. Do I have to come to the Final Approval Hearing?

No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish, but you do not have to.

If you file an objection, you do not have to come to the Final Approval Hearing to talk about it; the Court will consider it as long as it was filed on time. You may also pay your own lawyer to attend, but you do not have to.

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If I Do Nothing

20. What happens if I do nothing at all?

If you do nothing, you will not receive a benefit from this Settlement. You will also give up the rights described in Question 18.

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Getting More Information

21. How do I get more information?

This website and the Notice are a summary of the proposed Settlement. The full Settlement Agreement and other related documents are available on the Important Documents page.

If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at:

Adena Tracking Tools Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 417-4976
info@AdenaPixelSettlement.com

You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 2 North Paint Street, Chillicothe, OH 45601.

Do not contact the Court or Clerk of Court regarding this Settlement

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