Excluding Your Financial Institution From the Settlement

To exclude your financial institution from the Settlement, or “opt out,” you must send a letter by U.S. mail that includes the information in the bullet points below. If you fail to include this information, the notice of exclusion will be ineffective and the Settlement Class Member will be bound by the Settlement, including all releases.

  • The name of this Litigation: Village Bank Caribou Coffee Co., Inc. et al, No. 0:19-cv-01640 (D. Minn.);
  • Your financial institution’s full name, address, and phone number;
  • The words “Request for Exclusion” at the top of the document, or a statement in the body of the document requesting exclusion from the Settlement Class;
  • The name, address, email address, telephone number, position, and signature of the individual who is acting on behalf of the Settlement Class Member; and
  • The total number of payment cards issued by your financial institution that were identified as having been at risk as a result of the Data Breach in any alerts (or similar documents) by Visa or MasterCard.

You must mail via first class postage prepaid U.S. mail the completed, above-described letter, postmarked no later than October 22, 2020, to each of the following addresses:

Settlement Administrator

Caribou Financial Institution Data Breach Settlement
c/o Analytics LLC
P.O. Box 2005
Chanhassen, MN 55317-2005

Settlement Class Counsel

Bryan L. Bleichner
Chestnut Cambronne PA
100 Washington Ave. S.
Suite 1700
Minneapolis, MN 55401

Defense Counsel

James Slater
Sam Camardo
Key Tower
127 Public Square
Suite 2000
Cleveland, OH 44114-1214

If you ask to be excluded, your financial institution will not get any payment as part of this Settlement, and you cannot object to this Settlement. Your financial institution will not be legally bound by anything that happens in the Settlement and related proceedings. Your financial institution may be able to sue (or continue to sue) Caribou in the future. If  you object to the Settlement and seek to exclude your financial institution, you will be deemed to have excluded your financial institution.