1. Why was the Notice issued?
2. What is this lawsuit about?
3. What is a class action?
4. Why is there a settlement?
5. Who is included in the Settlement?
6. Are there exceptions to being included?
7. What does the Settlement provide?
8. What claims am I releasing if I stay in the Class?
9. How do I submit a claim for a Settlement benefit?
10. Are there any important Settlement payment deadlines?
11. When will the Settlement benefits be issued?
12. Do I have a lawyer in the case?
13. Should I get my own lawyer?
14. How will Class Counsel be paid?
15. How do I opt out of the Settlement?
16. How do I tell the Court if I like or do not like the Settlement?
17. What is the difference between objecting and excluding?
18. When is the Court’s Final Approval Hearing?
19. Do I have to come to the Final Approval Hearing?
20. What happens if I do nothing at all?
21. How do I get more information?
The Superior Court of California for Mono County 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 lawsuit, your legal rights, what benefits are available, and who can receive them.
The lawsuit is captioned Doe v. Southern Mono Healthcare District, Case No. 23UCM78, pending in the Superior Court of California for Mono County. The person that filed this lawsuit is called the “Plaintiffs” (or “Class Representatives”) and the entity they sued, Southern Mono Healthcare District d/b/a Mammoth Hospital, is called the “Defendant.”
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This lawsuit alleges that Mammoth used third-party tracking technologies, called “tracking pixels,” on its website in a way that violates certain California privacy laws.
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In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are called the “Plaintiffs” or “Class Representatives.” 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 Representatives is an individual (Jane Doe) whose name is under court seal, and everyone included in this Action are the Class Members
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The Court did not decide whether the Plaintiff or the Defendant is 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. Plaintiff and her attorneys think the Settlement is best for all Class Members.
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The court has defined the Class this way: “Mammoth patients who have used the Mammoth Web Properties to access Mammoth’s ‘Your Medical Record’ located at https://mammothhospital.org between August 9, 2020, through August 9, 2023.”
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Yes. Excluded from the Class are:
the Judge in this case, and the Judge’s family and staff,
Mammoth and its officers and directors, and
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:
Mammoth Hospital Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
1-833-360-6895
info@MammothHospitalPixelSettlement.com
You may also view the Settlement Agreement here.
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Mammoth 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.
CyEx Privacy Shield Pro. CyEx Privacy Shield Pro is a service that keeps your personal information safe by checking for it on the dark web. If it finds your private details there, it will alert you immediately. If fraud does occur, a dedicated case manager will help you fix the problem. All Class Members may claim one year of this service.
Cash Payment. All Class Members may claim a one-time $20.00 cash payment.
If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at:
Mammoth Hospital Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
1-833-360-6895
info@MammothHospitalPixelSettlement.com
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Unless you opt out of the Settlement, you won’t be able to sue, continue to sue, or be part of any other lawsuit against the Defendants about any of the legal claims this Settlement resolves. Paragraphs 25 and 26 of the Settlement Agreement describe the legal claims that you give up if you remain in the Class.
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The fastest way to submit your Claim Form is via the online claim module. If you prefer, you can download the printable Claim Form here and mail it to the Settlement Administrator at:
Mammoth Hospital Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
You may also contact the Settlement Administrator to request a Claim Form by email info@MammothHospitalPixelSettlement.com, or by U.S. mail at the address above.
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If you are submitting a Claim Form online, you must do so by October 14, 2025. If you are submitting a claim by U.S. mail, the completed and signed Claim Form must be postmarked no later than October 14, 2025.
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The Court will hold a final approval hearing on November 6, 2025 (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.
Settlement payments and the link to sign up for CyEx will be distributed if the Court grants final approval, and after any appeals are resolved.
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Yes, the Court appointed attorneys Raina C. Borrelli of Strauss Borrelli PLLC and Foster Johnson of Ahmad, Zavitsanos & Mensing, to represent you and other Class Members (“Class Counsel”).
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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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Class Counsel will ask the court to approve attorneys’ fees, costs, and expenses of $380,000.00, which will be paid directly by Mammoth.
Class Counsel will also ask for Service Award of $2,500.00 for the Class Representatives. Service Awards will also be paid directly by Mammoth
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If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement. This is called a Request for Exclusion and is sometimes also called “opting out.” If you opt out, you will not receive a Settlement payment, but you will keep any rights you may have to sue Mammoth on your own about the legal issues in this case.
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 September 15, 2025.
To be valid, your Request for Exclusion must have the following information:
The name of the Action: Doe v. Southern Mono Healthcare District, Case No. 23UCM78, pending in the Superior Court of California for Mono County;
Your full name, mailing address, and telephone number;
Personal signature; and
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:
Mammoth Hospital Pixel Settlement
ATTN: Exclusion Request
P.O. Box 25226
Santa Ana, CA 92799
Your Request for Exclusion must be postmarked or emailed by September 15, 2025.
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If 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 reasons for 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:
The name of the Action: Doe v. Southern Mono Healthcare District, Case No. 23UCM78, pending in the Superior Court of California for Mono County;
Your full name, mailing address, telephone number, and email address;
Information that proves that you as a Class Member (such as a settlement notice, or your attestation that you are a Class Member);
A statement that you object to some or all of the Settlement;
A clear description of all the reasons you object; include any legal support you may have for your objection;
Copies of any documents that you want to submit to support your objection;
If you have hired your own lawyer to represent you at the Final Approval Hearing, provide their contact information and state that you have authorized that attorney to represent you in this case;
Whether or not you or your lawyer would like to speak at the Final Approval Hearing;
If either your or your attorney have objected to a class action in the past 3 years, please provide a list of those cases, including case names, court information, and docket number;
Your signature (or, if you have hired your own lawyer, your lawyer’s 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 September 15, 2025. You must also send copies of the objection to Class Counsel and both counsel for Defendants.
Clerk of the Court | Class Counsel | Counsel for Defendants |
Clerk of the Court | Raina C. Borrelli | Rachel A. Straus |
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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 will hold a final approval hearing on November 6, 2025, at 9:30 a.m. Pacific Time at the Superior Court of California for Mono County, at 100 Thompson Way, Mammoth Lakes, CA 93546.
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 to the Class Representative who brought this Action on behalf of the Class. 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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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 you do nothing, you will not receive a benefit from this Settlement. You will also give up the rights described in Question 8.
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This website is 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:
Mammoth Hospital Pixel Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
1-833-360-6895
info@MammothHospitalPixelSettlement.com
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 100 Thompson Way, Mammoth Lakes, CA 93546.
Do Not Contact the Court or Clerk of Court Regarding This Settlement
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