A state court authorized this Notice because 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. This Notice explains the lawsuit, your legal rights, what benefits are available, and who can receive them.
The lawsuits are captioned Aaron Umberger and Tracy Bruner et al. v. Kerber, Eck & Braeckel LLP, Case No. 2024LA000198. (Circuit Court of Sangamon County Illinois, Seventh Judicial Circuit) and Jessica Kurtz v. Kerber, Eck & Braeckel LLP, Case No. 2024LA000264 (Circuit Court of Sangamon County, Illinois, Seventh Judicial Circuit). The people that filed these lawsuits are called the “Plaintiffs” and the company they sued, KEB, is called the “Defendant.”
This lawsuit alleges that personal information was potentially impacted by the cybersecurity incident that affected KEB in or around February 2023 (“Data Incident”).
In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are known as “Class Representatives” or “Plaintiffs.” Together, the people included in the class action are called a “class” or “class members.” One court resolves the lawsuit for all settlement class members, except for those who opt out from a settlement. In this Settlement, the Class Representatives are Aaron Umberger; Tracy Bruner and Jessica Kurtz.
The Court did not decide in favor of the Plaintiffs or the Defendant. The Defendant denies all claims and contends that it has not violated any laws. Plaintiffs and the Defendant agreed to a Settlement to avoid the costs and risks of a trial, and through the Settlement, Settlement Class Members are eligible to receive payments. The Plaintiffs and their attorneys think the Settlement is best for all Settlement Class Members.
The Settlement Class consists of all individuals residing in the United States whose Private Information was identified as being actually or potentially accessed, compromised or impacted in connection with the Data Incident discovered by KEB in February 2023.
Yes. Excluded from the Settlement Class are (i) the judges presiding over this Litigation, and members of their direct families; (ii) the Defendant, their subsidiaries, parent companies, successors, predecessors, and any entity in which the Defendant or their parents have a controlling interest, and their current or former officers and directors; and (iii) Settlement Class Members who submit a valid Request for Exclusion prior to the Opt-Out Deadline.
Under the Settlement, KEB will fund a non-reversionary $1,400,000 Settlement Fund to pay all valid and timely claims for Credit Monitoring, Unreimbursed Economic Losses, and Pro Rata Cash Payments, as well as notice and administration costs, attorneys’ fees and expenses, and service awards, subject to Court approval.
Payments will vary - Settlement Class Members may submit a claim form for any or all of the following benefits: (1) 2 years of credit monitoring; (2) Unreimbursed Economic Losses – up to a total of $10,000 per claimant; and (3) a Pro Rata Cash Payment estimated to be $50.
Credit Monitoring Services. All Settlement Class Members shall have the ability to make a claim for 2 years of Three-Bureau Credit Monitoring Services by choosing this benefit on this Claim Form.
Unreimbursed Economic Losses up to a total of $10,000 per claimant, upon submission of a valid claim with supporting documentation for unreimbursed economic losses incurred as a result of or fairly traceable to the Data Incident, including, without limitation, unreimbursed losses relating to fraud or identity theft; professional fees including attorneys’ fees, accountants’ fees, and fees for credit repair services; costs associated with freezing or unfreezing credit with any credit reporting agency; credit monitoring costs that were incurred on or after the Data Incident through the date of claim submission; and miscellaneous expenses such as notary, fax, postage, copying, mileage, and long-distance telephone charges.
Pro Rata Cash Payment which is a pro rata share of the Net Settlement Fund, less all valid claims for Unreimbursed Economic Losses. This is estimated to be at least $50.
Unless you opt out of the Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against the Defendant about any of the legal claims this Settlement resolves. The “Releases” section in the Settlement Agreement describes the legal claims that you give up if you remain in the Settlement Class. The Settlement Agreement can be found on the Court Documents page of this website.
You may file a claim if you are an individual who resides in the United States whose Private Information was identified as being actually or potentially accessed, compromised or impacted in connection with the Data Incident discovered by KEB in February 2023.
Claim Forms may be submitted online through claims portal located on the Claims Filing Portal Page of this website, or printed from the PDF of the Claim Form located on the Notice and Claim Page of this website and mailed to the Settlement Administrator at:
KEB Data Incident Settlement,
c/o RG/2 Claims Administration,
P.O. Box 59479
Philadelphia, PA 19102-9479
If you submit a claim by U.S. mail, the completed and signed Claim Form must be postmarked by November 25, 2025. If submitting a Claim Form online, you must do so by November 25, 2025.
The Court is scheduled to hold a final approval hearing on January 7, 2026 at 2:30 via Zoom, to decide whether to approve the Settlement, how much attorneys’ fees and costs to award to Settlement Class Counsel for representing the Settlement Class, and whether to award Service Awards to the Class Representatives who brought this Action on behalf of the Settlement Class.
Yes, the Court appointed Cassandra P. Miller of Strauss Borrelli PLLC; Tyler J. Bean of Siri Glimstad LLP; and Gary Klinger of Milberg Coleman Bryson Phillips Grossman to represent you and other members of the Settlement Class. You will not be charged directly for these lawyers; instead, they will receive compensation from the Settlement Fund (subject to Court approval). If you want to be represented by your own lawyer, you may hire one at your own expense.
It is not necessary for you to hire your own lawyer because Settlement Class Counsel works for you. If you want to be represented by your own lawyer, you may hire one at your own expense.
Settlement Class Counsel will file a motion for an award of attorneys’ fees and litigation costs and expenses to be paid from the Settlement Fund. KEB has agreed not to oppose Settlement Class Counsel’s request for an award of attorneys’ fees and litigation costs and expenses not to exceed $486,666.67.
Settlement Class Counsel will also seek a service award payment for the Class Representatives in recognition for their contributions to this Action. KEB has agreed not to oppose Settlement Class Counsel’s request for service awards not to exceed $5,000 for each of the three Class Representatives ($15,000 total).
If you do not want to receive any benefits from the Settlement, and you want to keep your right, if any, to separately sue the Defendant about the legal issues in this case, you must take steps to exclude yourself from the Settlement Class. This is called “opting out” of the Settlement Class. The deadline for requesting exclusion from the Settlement is October 27, 2025.
Your request for exclusion must be mailed to the Settlement Administrator at the address below, postmarked no later than October 27, 2025.
KEB Data Incident Settlement
ATTN: Exclusion Request
c/o RG/2 Claims Administration
P.O. Box 59479
Philadelphia, PA 19102-9479
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 a payment or any other benefits under the Settlement if you exclude yourself. You may only exclude yourself – not any other person.
If you are a Settlement Class Member, you can choose (but are not required) to object to the Settlement if you do not like it or a portion of it. You can give reasons why you think the Court should not approve the Settlement.
For an objection to be considered by the Court, the objection must: (i) state the objecting Settlement Class Member’s full name, current address, telephone number, and email address (if any); (ii) contain the objecting Settlement Class Member’s original signature; (iii) set forth information identifying the objector as a Settlement Class Member, including proof that the objector is within the Settlement Class (e.g., copy of the Notice or copy of original notice of the Data Incident); (iv) set forth a statement of all grounds for the objection, including any legal support for the objection that the objector believes applicable; (v) identify all counsel representing the objector; (vi) state whether the objector and/or his or her counsel will appear at the Final Approval Hearing, and; (vii) contain the signature of the objector’s duly authorized attorney or other duly authorized representative (if any), along with documentation setting forth such representation.
Any Settlement Class Member who does not file a timely and adequate objection in accordance with above paragraph waives the right to object or to be heard at the Final Approval Hearing and shall be forever barred from making any objection to the Settlement and shall be bound by the terms of the Agreement and by all proceedings, orders, and judgments in the Action.
Objections must be filed with the Court no later than October 27, 2025.
Clerk of Court
7th Judicial Circuit Court
200 South 9th Street
Springfield, IL 62701
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.
The Court is scheduled to hold a final approval hearing on January 7, 2026 at 2:30 pm CT via Zoom, to decide whether to approve the Settlement, how much attorneys’ fees and costs to award to Settlement Class Counsel for representing the Settlement Class, and whether to award a service award payment to each Class Representative who brought this Action on behalf of the Settlement Class. If you are a Settlement Class Member, you or your attorney may ask permission to speak at the hearing at your own cost. The date and time of this hearing may change without further notice. Please check www.kebdatasettlement.com for updates.
No. Settlement Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish. If you file an objection, you do not have to come to the Final Approval Hearing to talk about it. If you file your written objection on time and in accordance with the requirements above, the Court will consider it. You may also pay your own lawyer to attend, but such attendance is not necessary for the Court to consider an objection that was filed on time and meets the requirements above.
If you are a Settlement Class Member and you do nothing, you will give up the rights explained in Question 9 above, including your right to start a lawsuit, continue a lawsuit, or be part of any other lawsuit against the Defendant and the Released Parties, as defined in the Settlement Agreement, about the legal issues resolved by this Settlement. In addition, you will not receive a payment from this Settlement.
The Notice summarizes the proposed Settlement. Complete details are provided in the Settlement Agreement. The Settlement Agreement and other related documents are available on the Court Documents Page of this website.
If you have additional questions, you may contact the Settlement Administrator by email, phone, or mail:
Email: kebdatasettlement@rg2claims.com
Toll-Free: 1-866-742-4955
Mail: KEB Settlement Administrator, c/o RG/2 Claims Administration, P.O. Box 59479, Philadelphia, PA 19102-9479
Publicly filed documents can also be obtained by visiting the office of the Circuit Court of Sangamon County, Illinois or by reviewing the Court’s online docket.