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 Settlement 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 Circuit Court for Cass County, Missouri, authorized the Notice. You have a right to know about the proposed Settlement of this class action lawsuit, and about all of your rights and options, before the Court decides whether to grant final approval of the Settlement. The Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who can receive them, and how to receive those benefits.
The lawsuit is called Ferry et al., v. Safe Fleet, LLC Clarience Technologies, LLC, Case No. 26CA-CC0013. It is pending in the Circuit Court for Cass County, Missouri. The people that filed this lawsuit are called the “Plaintiffs” (or “Class Representatives”) and the companies they sued, Clarience Technologies, LLC, and Safe Fleet Holdings, LLC, are called the “Defendants”.
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On or about April 13, 2024, Safe Fleet became aware of suspicious activity in its computer systems. In response, Safe Fleet promptly launched an investigation to confirm the nature and scope of the activity. The investigation revealed that an unauthorized actor accessed or took certain information on or before April 13, 2024. Safe Fleet then conducted a thorough review of the information and identified the potential access to personal information such as names; addresses; dates of birth; Social Security numbers; driver’s license numbers; state identification numbers; other government identification numbers; passport numbers; taxpayer identification numbers; financial account information; payment card information; username/email addresses and passwords for non-financial accounts; health insurance information; and medical information.
On May 8, 2026, Plaintiffs filed a class action Complaint against the Entities in the Circuit Court for Cass County, Missouri, alleging negligence, negligence per se, breach of implied contract, invasion of privacy, unjust enrichment, breach of fiduciary duty, and declaratory judgment, in relation to the Data Incident.
The Entities do not in any way acknowledge, admit to, or concede any of the allegations made in the Complaint, and expressly disclaim and deny any fault or liability, or any charges of wrongdoing that have been or could have been asserted in the Complaint.
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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 “Settlement Class” or “Class Members”. One court resolves the lawsuit for all Class Members, except for those who opt out from the settlement. In this proposed Settlement, the Class Representatives are Brian Ferry and David Clement. Everyone included in this Action are members of the Settlement Class.
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The Court did not decide whether the Plaintiffs or the Defendants are right. Both sides have agreed to a settlement to avoid the costs and risks of a trial, and to allow the members of the Settlement Class to receive benefits from the Settlement. The Plaintiffs and their attorneys think the Settlement is best for all members of the Settlement Class.
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The Court has defined the Class this way: “All individuals residing in the United States whose Private Information may have been impacted in the Data Incident affecting Defendants on or around April 13, 2024, including all those who received notice of the Data Incident.”
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Yes. Excluded from the Class are: (i) Clarience Technologies, LLC, and Safe Fleet Holdings, LLC, including all persons who are directors, officers, and agents of Clarience Technologies, LLC, and Safe Fleet Holdings, LLC, or its respective subsidiaries and affiliated companies; (ii) any Settlement Class Member that timely and validly requests exclusion from the Settlement in accordance with Section VI (“Opt Out”); (iii) any judges assigned to this case and their staff and family; (iv) governmental entities; (v) the attorneys representing the Parties in the Action; and (vi) any other person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding or abetting the Data Incident or who pleads nolo contendere to any such charge.
If you are not sure whether you are a Settlement Class Member, you can ask for free help any time by contacting the Settlement Administrator at:
Safe Fleet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@SafeFleetDataSettlement.com
Call toll free, 24/7: (855) 256-5304
You may also view the Settlement Agreement here.
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All members of the Settlement Class may claim Credit Monitoring and one of the two Cash Payment options.
Credit Monitoring Services. All Class Members are eligible to enroll in two years of CyEx Financial Shield Complete. This comprehensive service comes with $1 million of financial fraud insurance, and includes monitoring for:
fraud or identity theft
unauthorized financial transactions
personal information associated with high-risk transactions
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
Your CyEx Financial Shield Complete subscription will become active once the Court grants Final Approval to this Settlement (i.e. approves the Settlement).
If you no longer have your enrollment code, please contact the Settlement Administrator.
Cash Payments. You may claim only one payment from the two options.
Compensation for Out-of-Pocket Losses. If you incurred actual, documented out-of-pocket losses due to the Data Incident, you can get back up to $2,500.00. The losses must have occurred between April 13, 2024, and December 2, 2026. You must have also made reasonable efforts to avoid, or seek reimbursement for, the loss.
This benefit covers out-of-pocket expenses like:
losses because of identity theft or fraud
fees for credit reports, credit monitoring, or freezing and unfreezing your credit
cost to replace your IDs
postage to contact banks by mail
You need to send third-party proof, like bank statements or receipts, to show how much you spent or lost. You can also send notes or papers you made yourself to explain or support other proof, but those notes or papers alone are not enough to make a valid claim. Your proof must show that your expenses were because of the Data Incident or more likely than not caused by the Data Incident.
Personal certifications, declarations, or affidavits do not constitute reasonable documentation to make a valid claim, but may be used to provide clarification, context, or support for other reasonable documentation.
You cannot claim a payment for expenses that have already been reimbursed by a third party. This includes reimbursement in connection with the credit monitoring and identity theft protection product offered as part of the notification letter provided by Safe Fleet or otherwise. There will also be no payments for emotional distress, personal/bodily injury, or to punish the Entities.
-OR-
Alternative Cash Payment. Instead of Compensation for Out-of-Pocket Losses, you may claim a one-time $50.00 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:
Safe Fleet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@SafeFleetDataSettlement.com
Call toll free, 24/7: (855) 256-5304
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If you stay in the Settlement Class and do not opt out, you won’t be able to be part of any other lawsuit against the Entities (and the Released Parties) or separately file a lawsuit about the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section X) describes the legal claims that you give up and against whom, if you remain in the Settlement Class.
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The fastest way to submit your Claim Form is online here. If you prefer, you can download a printable Claim Form here and mail it to the Settlement Administrator at:
Safe Fleet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (855) 256-5304, by email info@SafeFleetDataSettlement.com, or by U.S. mail at the address above.
For more information about the Claim Process, please review Section IV of the Settlement Agreement.
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If you are submitting a Claim Form online here, you must do so by December 2, 2026. If you are downloading a Claim Form here and submitting a claim by U.S. mail, the completed and signed Claim Form, including supporting documentation, must be postmarked no later than December 2, 2026.
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The Court will hold a Final Approval Hearing on November 2, 2026, at 10:30 a.m. (see Question 18 for more information about the Final Approval Hearing). If the Court approves the Settlement, then Settlement payments will be distributed for all Valid Claims filed by December 2, 2026. More information about this process can be found in the Settlement Agreement (Section IV).
Settlement payments cannot be distributed if there are any 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 will be distributed if the Court grants final approval, and after any appeals are resolved. Please be patient and check this website for updates.
It is your responsibility to inform the Settlement Administrator of any updates to your information after the submission of your Claim Form.
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Yes, the Court has appointed attorneys Raina C. Borrelli of Strauss Borrelli PLLC; Grayson Wells of Stranch, Jennings & Garvey, PLLC; and Leigh S. Montgomery of Ellzey, Kherkher, Sanford & Montgomery LLP, to represent you and other member of the Settlement Class (“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 $250,000.00 as reasonable attorneys' fees and reimbursement of litigation costs. This amount will be paid by the Entities and is separate from the Entities’ payment of the Settlement Administration Costs and the Settlement Class Member Benefits.
Class Counsel will also ask for Service Award payments of $2,000.00 for each of the Class Representatives. Service Award payments will also be paid by the Entities and separately from the Entities’ payment of the Settlement Administration Costs and the Settlement Class Member Benefits.
The Court may award less than these amounts.
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If you do not want to be part of the Settlement or bound by the Agreement, 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 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 or payment, if you opt out. However, you will keep any rights you may have to sue the Entities (and the Released Parties) on your own about the legal issues in this case.
The deadline to exclude yourself from the Settlement is November 2, 2026.
To be valid, your Request for Exclusion must have the following information:
the name of the Litigation: Ferry et al., v. Safe Fleet Holdings LLC and Clarience Technologies, LLC, Case No. 26CA-CC0013, pending in the Circuit Court for Cass County, Missouri;
your full name, mailing address, telephone number, and email address (if any);
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 or a group of persons.
Mail your Request for Exclusion to the Settlement Administrator at:
Safe Fleet Data Incident Settlement
ATTN: Exclusion Request
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be postmarked or emailed by November 2, 2026.
More information about this process can be found in the Settlement Agreement (Section VI).
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If you are a Settlement Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons 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 Litigation: Ferry et al., v. Safe Fleet Holdings LLC and Clarience Technologies, LLC, Case No. 26CA-CC0013, pending in the Circuit Court for Cass County, Missouri;
your full name, mailing address, telephone number, and email address (if any);
information that proves that you are a Settlement Class Member (such as a notice you have received);
whether the objection applies only to you, or to other Class Members, as well;
a clear description of all the reasons you object; include any legal support, such as documents, you may have for your objection;
if you have hired your own lawyer to represent you for this objection, provide their name, bar number, and contact information (including any former counsel who may be entitled to compensation for any reason related to the objection);
whether or not you or your lawyer would like to attend or speak at the Final Approval Hearing;
if you plan on calling witnesses or submitting documents at the Final Approval Hearing, provide a full list of both;
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 November 2, 2026. You must also send a copy of the objection to the Settlement Administrator, Class Counsel, and counsel for the Entities postmarked or emailed no later than November 2, 2026.
All addresses are provided below.
Clerk of the Court | Settlement Administrator | Counsel for Defendants |
Clerk of the Court | Safe Fleet Data Incident Settlement | Carolyn Purwin Ryan |
Class Counsel | ||
Raina C. Borrelli | Grayson Wells | Leigh S. Montgomery |
More information about this process can be found in the Settlement Agreement (Section VI).
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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 or bound by the Settlement Agreement. 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 on November 2, 2026, at 10:30 a.m. Central Time, in Division I Courtroom of the Circuit Court for Cass County, Missouri, at 2501 W. Mechanic St. Harrisonville, MO 64701.
At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The Court will also decide Class Counsel’s request for an attorneys’ fees and costs award and the request for a Service Award to the Class Representatives. The Court will also consider any timely objections to the Settlement.
If you are a Settlement 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 and be bound by any Judgement issued by the Court along with the terms of the Settlement Agreement.
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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:
Safe Fleet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@SafeFleetDataSettlement.com
Call toll free, 24/7: (855) 256-5304
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 2501 W. Mechanic St. Harrisonville, MO 64701.
Do not contact the Court or Clerk of Court regarding this Settlement.
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