Basic Information

1. Why is Notice being provided?

A Court authorized the notice because you have the right to know about the proposed Settlement of this class action lawsuit and all of your rights and options before the Court decides to grant Final Approval of the Settlement. The notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who is eligible for the benefits, and how to get them.

The Honorable Jesse M. Furman of the United States District Court for the Southern District of New York is overseeing this class action. The lawsuit is known as In re Christie’s Data Breach Litigation., Case No. 24-cv-4221 (JMF) (“Action”). The persons who filed this Action are called the “Plaintiffs” and/or “Class Representatives” and the company sued, Christie’s, Inc., is called the “Defendant.”

2. What is this Action about?

Plaintiffs filed this lawsuit against Defendant. Plaintiffs allege that in May 2024, an unauthorized third party accessed Defendant’s computer network copied certain files from Defendant’s network containing Private Information (“PI”) including full names, dates of birth, addresses, birthplaces, sex, nationality, document numbers, passport numbers, full Machine Readable Zone (“MRZ”) numbers (the machine-readable code at the bottom of the identity page at the beginning of a passport, IDs, and visas), issuing authority, issue dates, expiration dates, and Driver’s License Numbers.

Plaintiffs brought this lawsuit against Defendant alleging legal claims for negligence, breach of implied contract, unjust enrichment, declaratory judgment, negligence per se, violation of the Florida Deceptive and Unfair Trade Practices Act, and Wantonness.

Defendant denies these allegations and denies any wrongdoing or liability. The Court has not decided who is right. Instead, Plaintiffs and Defendant have agreed to a settlement to avoid the risk, cost, and time of continuing the Action.

3. Why is the Action a class action?

In a class action, one or more people (called plaintiff(s) or class representative(s)) sue on behalf of all people who have similar legal claims. Together, all these people are called a “class” or “class members.” If the plaintiffs and defendant reach a settlement, the court resolves the issues for all class members via the settlement, except for those class members who timely opt out (exclude themselves) from the settlement.

The proposed Class Representatives in this lawsuit are Plaintiffs Efstathios Maroulis, William Colley, Russell DeJulio, Alice Bruce, and Ildar Gaifullin.

4. Why is there a Settlement?

Plaintiffs and Defendant do not agree about the legal claims made in the Action. The Action has not gone to trial, and the Court has not decided in favor of Plaintiffs or Defendant. Instead, Plaintiffs and Defendant have agreed to settle the Action. The Class Representatives believe the Settlement is best for all individuals in the Settlement Class because of the benefits available to the Settlement Class and the risks and uncertainty associated with continuing the Action.

Who Is Included In The Settlement

5. How do I know if I am a part of the settlement?

You are part of the Settlement Class if you are an individual residing in the United States whose Private Information was compromised as a result of the Christie’s Data Breach and who were sent notice of the Data Breach that occurred in May 2024. There are approximately 45,798 Settlement Class members.

6. Are there exceptions to being included in the Settlement?

Yes. Excluded from the Settlement Class are (a) all persons who are governing board members of the Defendant; (b) governmental entities; and (c) the Court, the Court’s immediate family, and Court staff.

7. What if I am still not sure whether I am part of the Settlement?

If you are still not sure whether you are a Settlement Class member, you may go to the Settlement Website at www.ChristiesDataSettlement.com or call the Settlement Administrator’s toll-free telephone number at 1-844-935-0003.

The Settlement Benefits – What you Get if You Qualify

8. What does the Settlement provide?

If you are a Settlement Class Member and you timely submit a Valid Claim, you may be eligible for the following Settlement benefits:

(1) Pro Rata Cash Payments:
You may elect to receive a Pro Rata Cash Payment. The payments shall be calculated by dividing remaining funds in the Settlement Fund, after payment of Settlement Administration Fees, Attorneys’ Fees Costs and Expenses, Credit Monitoring and Identity Restoration Services, and Documented Monetary Losses, by the number of eligible claims. The pro rata cash payment is estimated to be $100, but will be adjusted upwards or downwards based upon the number of valid claims filed.

AND

(2) Reimbursement for Documented Monetary Losses:
All Settlement Class Members who timely submit a Valid Claim are eligible for up to a total of $10,000.00 per person for actual documented monetary losses fairly traceable to the Data Breach incurred by a Settlement Class Member between May 8, 2024, and the Claims Deadline.

You must submit documentation supporting your Claim Form for Documented Monetary Losses, which may include but are not limited to (i) out-of-pocket credit monitoring costs that were incurred on or after May 8, 2024 through the date of claim submission; (ii) unreimbursed losses associated with actual fraud or identity theft; and (iii) unreimbursed bank fees, long distance phone charges, postage, or gasoline for local travel. Settlement Class Members may make claims for any documented unreimbursed out-of-pocket losses reasonably related to the Data Breach or to mitigating the effects of the Data Breach.

Documentation supporting your losses can include receipts or other documentation that show the costs incurred. “Self-prepared” documents such as handwritten receipts are, by themselves, insufficient to receive reimbursement, but can be considered to add clarity to or support other submitted documentation.

AND

(3) Credit Monitoring and Identity Theft Restoration Services:
In addition to selecting a Pro Rata Cash Payment, compensation for Documented Monetary Losses, and/or a California Statutory Payment (if eligible), you may elect to receive two (2) years of free three-bureau credit monitoring and Identity Restoration Services with at least $1 million of fraud/identity theft insurance.

(4) California Statutory Payments:
Settlement Class Members who were residents of California from May 8, 2024, to the end of the claims period (“California Settlement Class Members”) can submit a claim for payment of up to $100.00 for their potential statutory claims under the California Consumer Privacy Act (“California Statutory Payment”). The California Statutory Payment is an additional settlement benefit made available to California Settlement Class Members that is in addition to reimbursement of claims for Documented Monetary Losses and a Settlement Class Member’s selection of a Pro Rata Cash Payment.

(5) Business Practice Commitments:
Although Defendant denies any wrongdoing or liability, Plaintiffs have received confidential assurances that the Defendant has already and is continuously implementing additional security enhancements including defensive tools and increased monitoring. Defendant has committed to maintain its additional security measures for a period of 3 years following the effective date of this Settlement.

9. What am I giving up to receive Settlement benefits or stay in the Settlement Class?

Unless you opt out of the Settlement, you are choosing to remain in the Settlement Class. If the Settlement is approved and becomes final, all Court orders will apply to you and legally bind you. You will not be able to sue, continue to sue, or be part of any other lawsuit against the Released Parties, including Defendant, about the legal issues in this lawsuit that are released by this Settlement. The specific rights you are giving up are called “Released Claims.”

10. What are the Released Claims?

The Settlement Agreement in Section XIII describes the Released Claims and the Release, in necessary legal terminology, so please read this section carefully. The Settlement Agreement is available HERE or in the public Court records on file in this lawsuit. For questions regarding the Release or Released Claims and what the language in the Settlement Agreement means, you can also contact Class Counsel listed in Question 15 for free, or you can talk to your own lawyer at your own expense.

How To Get Benefits From The Settlement

11. How do I make a claim for Settlement benefits?

To receive any of the benefits described in Question 8, you must submit a Valid Claim, postmarked or submitted online by June 19, 2025. Claim Forms may be submitted online at www.ChristiesDataSettlement.com or printed from the Settlement Website and mailed to the Settlement Administrator at the address on the Claim Form. The quickest way to submit a Claim is online. Claim Forms are also available by calling 1-844-935-0003 or by writing to:

Christie’s Settlement Administrator
P.O. Box 3678
Baton Rouge, LA 70821

Claim Forms must be submitted online or by mail postmarked by JUNE 19, 2025.

12. What happens if my contact information changes after I submit a Claim?

If you change your mailing address or email address after you submit a Claim Form, it is your responsibility to inform the Settlement Administrator of your updated information. You may notify the Settlement Administrator of any changes by calling 1-844-935-0003 or by writing to:

Christie’s Settlement Administrator
P.O. Box 3678
Baton Rouge, LA 70821

13. When will I receive my Settlement benefits?

If you submit a timely and Valid Claim, payment will be made to you by the Settlement Administrator after the Settlement is approved by the Court and becomes final.

It may take time for the Settlement to be approved and become final. Please be patient and check www.ChristiesDataSettlement.com for updates.

14. How will I receive my payment?

If you submit a timely and Valid Claim for payment, and if your Claim and the Settlement are finally approved, you will be sent an electronic payment to the electronic payment option that you select when you file your claim, or will be sent a paper check if you select that option. Several electronic payment options will be available, or you can elect a check. Please ensure you have provided a current and complete email address. If you select a paper check, the Settlement Administrator will attempt to send you a check relying on your physical address submitted on your Claim Form.

The Lawyers Representing You

15. Do I have a lawyer in this lawsuit?

Yes, the Court has appointed David Lietz of Milberg Coleman Bryson Phillips Grossman PLLC and Jonathan Mann of Pittman, Dutton, Hellums, Bradley & Mann, P.C. as Class Counsel lawyers to represent you and the Settlement Class for the purposes of this Settlement. You may hire your own lawyer at your own cost and expense if you want someone other than Class Counsel to represent you in this lawsuit.

Class Counsel may be contacted at the following addresses and phone numbers:


David K. Lietz, Esq.
MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN
5335 Wisconsin Avenue NW, Suite 440
Washington, DC 20015
(866) 252-0878


Jonathan S. Mann, Esq.
PITTMAN, DUTTON, HELLUMS, BRADLEY & MANN, P.C.
2001 Park Place North, Suite 1100
Birmingham, AL 35203
(205) 322-8880

16. How will Class Counsel be paid?

Class Counsel will file a motion asking the Court to award attorneys’ fees of up to 1/3 ($330,000) of the $990,000 Settlement Fund, plus reimbursement of out-of-pocket litigation expenses. The Court may award less than the amount requested. Class Counsel will also request approval of Service Awards of five thousand dollars ($5,000) for each Class Representatives. If awarded by the Court, the Settlement Administrator will pay attorneys’ fees, litigation expenses, and service awards out of the Settlement Fund.

Class Counsel’s motion for Attorneys’ Fees, Litigation Expenses, and Service Awards will be made available on the Settlement Website at www.ChristiesDataSettlement.com before the deadline for you to object to or opt out of the Settlement.

Opting Out Of The Settlement

If you are a Settlement Class Member and want to keep any right you may have to sue or continue to sue the Released Parties on your own based on the legal claims raised in this lawsuit or released by the Released Claims, then you must take steps to get out of the Settlement. This is called opting out of the Settlement.

17. How do I opt out of the Settlement?

To opt out of the Settlement, you must timely mail written notice of a request to opt out. The written notice must include:

     (1) Your full name, current address, telephone number, and email address (if any);
     (2) A statement indicating your request to be excluded from the Settlement Class; and
     (3) Your physical signature as a Settlement Class member;

The opt out request must be mailed to the Settlement Administrator at the following address, and be postmarked by May 20, 2025:

Christie’s Settlement Administrator
Exclusions
P.O. Box 3678
Baton Rouge, LA 70821

You cannot opt out by telephone or by email.

“Mass” or “class” requests for exclusion filed by third parties on behalf of a “mass” or “class” of Settlement Class Members or multiple Settlement Class Members where an opt out has not been signed by each and every individual Settlement Class Member will not be allowed.

18. If I opt out can I still get anything from the Settlement?

No. If you opt out, you will not be entitled to receive any Settlement benefits, but you will not be bound by any judgment in this lawsuit. You can only get Settlement benefits if you stay in the Settlement and submit a Valid Claim.

19. If I do not opt out, can I sue Defendant for the same thing later?

No. Unless you opt out, you give up any right to sue Defendant and other Released Parties for the legal claims this Settlement resolves and Releases relating to the Data Breach. You must opt out of the lawsuit to start or continue with your own lawsuit or be part of any other lawsuit against Defendant or other Released Parties. If you have a pending lawsuit, speak to your lawyer in that case immediately.

Objecting To The Settlement

20. How do I tell the Court that I do not like the Settlement?

If you are a Settlement Class Member, you can tell the Court you do not agree with all or any part of the Settlement and/or Class Counsel’s motion for Attorneys’ Fees and Expenses.

To object, you must mail a timely, written objection stating that you object. Your objection must be postmarked by May 20, 2025.

The objection must also include all of the following information:

(1) Your full name, current address, current telephone number;
(2) The case name and case number, In re Christie’s Data Breach Litigation., Case No. 24-cv-4221 (JMF);
(3) Documentation sufficient to establish membership in the Settlement Class, such as a copy of the Postcard Notice you received;
(4) A statement of the position(s) you wish to assert, including the factual and legal grounds for the position(s);
(5) Copies of any other documents that you wish to submit in support of your position;
(6) Whether you intend to appear at the Final Approval Hearing;
(7) Whether you are represented by a lawyer and, if so, the name, address, and telephone number of your lawyer, and
(8) Your signature (a lawyer’s signature is not sufficient).

To be timely, written notice of an objection in the appropriate form must be mailed postmarked by May 20, 2025, to the Settlement Administrator at:

Christie’s Settlement Administrator
Objections
P.O. Box 3678
Baton Rouge, LA 70821

You may also file any Objection with the Court.

Any Settlement Class Member who fails to comply with the requirements for objecting detailed above will waive and forfeit any and all rights they may have to appear separately and/or to object to the Settlement Agreement and will be bound by all the terms of the Settlement Agreement and by all proceedings, orders, and judgments in the lawsuit.

21. What is the difference between objecting and asking to opt out?

Objecting is simply telling the Court you do not like something about the Settlement or requested attorneys’ fees and expenses. You can object only if you stay in the Settlement Class (meaning you do not opt out of the Settlement). Opting out of the Settlement is telling the Court you do not want to be part of the Settlement Class or the Settlement. If you opt out, you cannot object to the Settlement.

The Final Approval Hearing

22. When and where will the Court decide whether to approve the Settlement?

The Court will hold a Final Approval Hearing on July 22, 2025, at 3:00 p.m. before the Honorable Jesse M. Furman at the Thurgood Marshall United States Courthouse, 40 Foley Square, New York, NY 10007 or via video conference or by phone. At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate and decide whether to approve the Settlement, Class Counsel’s Application for Attorneys’ Fees and Expenses, and Service Awards.

If there are objections, the Court will consider them. The Court will also listen to Settlement Class Members who have asked to speak at the hearing.

Note: The date and time of the Final Approval Hearing are subject to change. The Court may also decide to hold the hearing via video conference or by phone. Any change will be posted at www.ChristiesDataSettlement.com.

23. Do I have to attend the Final Approval Hearing?

No. Class Counsel will answer any questions the Court may have. However, you are welcome to attend at your own expense. If you mail an objection, you do not have to attend the Final Approval Hearing to speak about it. As long as you mail your written objection on time, the Court will consider it.

24. May I speak at the Final Approval Hearing?

Yes, as long as you do not opt out, you can (but do not have to) participate and speak for yourself at the Final Approval Hearing. This is called making an appearance. You also can have your own lawyer speak for you, but you will have to pay for the lawyer yourself.

If you want to appear, or if you want your own lawyer instead of Class Counsel to speak for you at the Final Approval Hearing, you must follow all of the procedures for objecting to the Settlement listed in Question 20 above—and specifically include a statement whether you and your lawyer will appear at the Final Approval Hearing.

If You Do Nothing

25. What happens if I do nothing at all?

If you are a Settlement Class Member and you do nothing, you will not receive any Settlement benefits, and you will give up rights explained in the “Opting Out of the Settlement” section of this notice, including your right to start a lawsuit, continue with a lawsuit, or be part of any other lawsuit against any of the Released Parties, including Defendant, about the legal issues in this lawsuit that are released by the Settlement Agreement relating to the Data Breach.

Getting More Information

26. How do I get more information?

The Notice summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available at www.ChristiesDataSettlement.com, by calling 1-844-935-0003 or by writing to:

Christie’s Settlement Administrator
P.O. Box 3678
Baton Rouge, LA 70821

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT’S CLERK OFFICE REGARDING THE NOTICE.