Objecting to the Settlement

If your financial institution is a Settlement Class Member, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. You can give reasons why you think the Court should not approve it. The Court will consider your views. If you both object to the Settlement and seek to exclude your financial institution, your financial institution will be deemed to have excluded itself and your objection will be deemed null and void.

Your objection must be in writing, and must include:

  • The name of this Litigation: In re: Equifax, Inc. Customer Data Security Breach Litigation, No. 1:17-md-2800-TWT (N.D. Ga.) (“Financial Institution Track”);
  • Your financial institution’s full name, and the full name, address, email address, and telephone number of the person acting on its behalf;
  • An explanation of the basis for why your financial institution is a Settlement Class Member;
  • Whether the objection applies only to your financial institution, to a specific subset of the Settlement Class, or to the entire Settlement Class;
  • All grounds for the objection stated with specificity, accompanied by any legal support for the objection;
  • The identity of all counsel who represent the objector, including any former or current counsel who may be entitled to compensation for any reason related to the objection to the Settlement Agreement, Class Counsel’s request for attorney’s fees, costs, and expenses, or the application for Service Awards;
  • The identity of all representatives (including counsel representing the objector) who will appear at the Final Approval Hearing;
  • A description of all evidence to be presented at the Final Approval Hearing in support of the objection, including a list of any witnesses, a summary of the expected testimony from each witness, and a copy of any documents or other non-oral material to be presented;
  • All other information specified in the Preliminary Approval Order (available here), including but not limited to information relating to any objections you or your counsel have filed in other class action litigation and any agreements that relate to your objection; and
  • Your signature on the written objection.

Any objection must be either filed electronically with the Court or mailed to the Clerk of the Court, Class Counsel, and Equifax’s counsel at the addresses set forth below. The objection must be electronically filed, or if mailed postmarked, no later than September 2, 2020.


Clerk of the Court
USDC, Northern District of Georgia
Richard B. Russell Federal Bldg.
2211 United States Courthouse
75 Ted Turner Drive, SW
Atlanta, GA 30303-3309

Settlement Class Counsel

Joseph P. Guglielmo
230 Park Avenue, 17th Floor
New York, NY 10169

Gary F. Lynch
1133 Penn Avenue, 5th Floor
Pittsburgh, PA 15222


Defense Counsel

S. Stewart Haskins II
1180 Peachtree Street, N.E.
Atlanta, GA 30309

In addition, any Settlement Class Member that objects to the proposed Settlement Agreement may be required to appear for deposition regarding the grounds for its objection, and must provide along with its objection the dates when the objector will be available to be deposed during the period from when the objection is filed through the date five days before the Final Approval Hearing.