The CEG team boasts decades of collective experience, having managed over 1,800 class action administrations covering a wide spectrum of areas including the Telephone Consumer Protection Act (TCPA), Employee Retirement Income Security Act (ERISA), human rights, data breach, Real Estate Settlement Procedures Act (RESPA), insurance, Fair Labor Standards Act (FLSA), antitrust, securities fraud, and other class action matters. Throughout these cases, CEG's leadership successfully identified and notified millions of class members, distributing hundreds of millions of dollars in recoveries to individuals who met the criteria for each respective class.
CEG offers an array of class action notice and settlement administration services including, but not limited to, the following:
Pre-settlement Consultation
Damages Data Analysis
Mediation Preparation
Settlement Agreement Review
Notice Plan Development
Drafting Notice Documents
Compilation of Class Member Lists
Mail and Email Class Notice
Digital and Social Media Notice
Call Center and Interactive Voice Response (IVR)
Automated Voicemail Transcription
Multilingual Support
Advanced Class Member Location
Website Hosting and Management
Notice Plan Effectuation Affidavits
Notice Adequacy Analysis
Paper and Electronic Claims Processing
Pro Rata Calculations
Escrow Agency Services
Qualified Settlement Fund (QSF) Administration
Class Settlement Payment Options
Settlement and QSF Tax Reporting
Class Notice
CEG is a nationally recognized expert in the design, preparation and dissemination of legal notice. Ensuring that class members are aware of, understand, and can act on their legal rights is the essence of Federal Rules of Civil Procedure Rule 23. By using industry-approved measurement processes and accredited consumer data, CEG develops notice programs that fully comply with the requirements of Rule 23 and its state equivalents. Our notice programs have never faced a successful objection.
CEG’s case-specific notice programs utilize available class data, demographic, geographic, behavioral, and interest-based criteria to effectively connect with specific audiences via direct mail, email, third-party notice, publication, and digital media. Advancements in technology and communication outlets offer an expanding range of methods to efficiently and effectively notify class members. CEG’s notice campaigns fulfill the following legal notice requirements:
Timeliness: Notice is timely and provided at the appropriate stage in the litigation process.
Content: Notice adequately describes the nature of the action, the definition of the class, the claims, issues, or defenses involved, and the binding effect of a class judgment.
Opt-Out Information: Notice informs class members of their right to opt out of the action (if applicable) if they wish to pursue individual claims separately.
Method of Notice: Notice is given through various means such as direct mail, email, publication, or other appropriate forms of communication. The method chosen is the most effective means of reaching class members.
Scope: Notice is provided to all members of the class or a reasonable subset of the class that adequately represents the interests of absent members.
For example, CEG utilizes the telephone numbers and emails of individuals who should receive notice to match to similarly situated social media users so that the publication notice, in the form of digital banners, is disseminated across different platforms such as mobile and desktop web, Facebook, Instagram, TikTok, Google Ads, X (formerly Twitter), Adobe, Amazon marketing services, etc.
The court has always approved the form and manner of CEG notice that ensured it met the requirements of Rule 23 and provided adequate information to class members.
Courts have also endorsed the effectiveness of CEG’s notice programs. CEG was appointed as the Settlement Administrator in the matter of Leslie Ann Wilkie Peltier, et al. v. Deb Haaland, et al., No. 20-cv-03775 (D. D.C.), a class action lawsuit to redress alleged breaches of trust by the United States Department of the Interior, the United States Department of the Treasury, and the United States of America with respect to the accounting and management of two Judgment Awards of the Indian Claims Commission (ICC). The $59 million settlement provided relief to several generations of tribal families. As part of this litigation, CEG’s team worked over the course of several years to develop a novel class notice plan and claims adjudication process that would effectively and efficiently distribute settlement funds to surviving tribal members and their heirs, many of whom are ageing. At the preliminary approval hearing, presiding Federal Judge Thomas F. Hogan overseeing the settlement noted that CEG was “instrumental in helping to shape the deal…”
At the final settlement approval fairness hearing in Leslie Ann Wilkie Peltier, et al. v. Deb Haaland, et al., No. 20-cv-03775 (D. D.C.), class counsel noted that CEG “made extensive efforts to identify and reach” the class and that CEG’s class notification efforts “have met or gone beyond the Rule 23 and due process…requirements…The notice program here has been thorough…” In his order granting final class action settlement agreement approval, Federal Judge Thomas F. Hogan noted that CEG’s class notification process provided “the best notice practicable under the circumstances…and it was reasonably calculated to reach the class members.”
CEG provides reach and frequency analysis in its class action notice campaigns. That involves measuring the number of unique individuals exposed to the notice (reach) and the number of times they are exposed (frequency). These metrics, detailed further in the Federal Judicial Center’s Judge’s Class Action Notice and Claims Process Checklist and Plain Language Guide 2010, ensure that the notice is effectively communicated to the affected class members, maximizing awareness and understanding while avoiding oversaturation. Proper analysis helps achieve compliance with legal requirements, enhances the campaign’s effectiveness, and ensures cost-efficiency by balancing the extent and repetition of the communication.
In addition, CEG provides notice adequacy analysis that assesses whether the communication efforts to inform potential class members about the class action lawsuit meet legal standards and are effective in reaching and informing them. This analysis ensures that the notice is clear, concise, and comprehensive, providing all necessary information about the class action, including the nature of the lawsuit, the rights of class members, and any required actions they need to take. The goal is to confirm that the notice method is appropriate and sufficient to alert a significant portion of the class, ensuring that affected individuals are adequately informed and can participate or opt out as needed. This involves evaluating the content, distribution channels, timing, and overall reach and frequency of the notice to ensure compliance with legal requirements and the best possible communication to the class members.
CEG completes the notice with the Declaration on Mailing confirming the details of how class action notices were distributed to class members with a description of the mailing process, compliance with court orders, dates of mailing, the total number of notices sent, and any additional steps taken to ensure delivery to provide the court with evidence that all identified class members were adequately notified according to legal and procedural requirements.
Class Action Fairness Act Notice (CAFA) CAFA Notice, under the Class Action Fairness Act of 2005, requires notifying federal and state officials about the filing of a class action lawsuit or proposed settlement. Sent to the U.S. Attorney General and relevant state officials within 10 days of filing, the notice must include key details and documents including but not limited to the complaint, dates of scheduled hearings, copies of draft class member notifications, settlement agreement(s), etc. The purpose is to ensure transparency and allow officials to review and potentially intervene in the settlement process, ensuring it is fair, reasonable, and adequate for class members.
Call Center Integral to a comprehensive notice plan is providing an accessible means of communication by telephone. CEG’s call center specialists are trained and equipped to handle a wide range of class member inquiries, significantly reducing the need for escalations to Counsel by providing thorough and accurate responses. With a scalable team and the latest technology, CEG’s call center is equipped to adapt to a variety of case sizes.
CEG’s call center services include, but are not limited to, the following: •Dedicated toll-free number for each case •Case-specific call script •Interactive Voice Response (IVR) system •Answering frequently asked questions •24 hours a day, 7 days a week access •Assisting with claim form completion •Live operators per case requirements •Inbound and outbound call tracking •Multi-lingual translation and transcription •Detailed reporting •Voicemail transcription •Forwarding calls to class counsel, if needed
Website Dedicated, case-specific websites are another means of communication with class members in a class action proceeding. Overall, a class action administration website aims to streamline the administration of the lawsuit, ensure that class members are well-informed, and facilitate the efficient handling of claims and distribution of settlement funds.
CEG designs, builds, and hosts case websites which are customized per the case specifications, meet legal requirements, and include, but are not limited to, the following features: •Search Engine Optimization (SEO) •User-friendly navigation •High-speed loading •Access to case documents •Mobile device compatible •Important dates and deadlines •Online claim filing capability •Interactive contact form •Change of name and/or address •Website traffic reporting •Frequently asked questions and answers •Case-specific updates
Claims Administration Claims administration plays a vital role in the successful resolution of class action settlements, fulfilling several essential functions. It manages the often complex task of processing thousands or even millions of claims in an organized, accurate manner. This reduces the risk of errors and fraud, ensuring a higher degree of precision throughout the process. Additionally, claims administration provides critical support to class members by guiding them through the claims submission process and addressing their questions or concerns. This ensures that class members fully understand their rights and the steps involved in seeking compensation. Another key function is the timely distribution of settlement funds, which helps prevent unnecessary delays in compensating class members. Finally, the administration process handles any appeals from class members who dispute their claim outcome or compensation amount, ensuring fairness and consistency in the overall distribution of funds.
•Claims Management At CEG, we pride ourselves on maintaining the highest standards of quality and security to ensure meticulous attention to detail and swift resolution. Our claims management system is designed to ensure the secure, transparent, and efficient administration of class action lawsuits. We incorporate several essential components to comply with legal requirements while maintaining ethical and data protection standards.
CEG ensures strict adherence to the provisions outlined in the court-approved settlement agreement. This includes meeting the eligibility criteria for claimants and executing the distribution plan. CEG’s system includes comprehensive anti-fraud measures. We maintain detailed audit trails, creating clear records of all transactions and decisions throughout the claims process.
CEG emphasizes reporting and transparency as critical components of our claims management system. We provide regular, detailed reports to the court and attorneys, outlining the status of claims, including the number of claims received, approved, or denied, as well as the amounts distributed. In today’s privacy-conscious environment, CEG’s system complies with relevant data protection and privacy laws.
•Claims Processing At CEG, class action claims processing and auditing is a meticulous and structured process designed to ensure fairness and accuracy in the distribution of settlement funds, safeguarding the interests of both claimants and defendants. Our process begins with the collection of claims, where all submitted forms, documents, and supporting evidence from class members are gathered. This is followed by a precise data entry process to ensure that all information is accurately recorded in our claims management system.
Once data is entered, CEG undertakes a thorough verification of claims, ensuring each claim meets the eligibility criteria outlined in the settlement agreement. This involves reviewing supporting documentation, such as financial records or medical reports, and validating data by cross-referencing internal and external databases to confirm the accuracy of claims.
CEG’s system allows class members to file claims online, offering a convenient and efficient way to participate in the settlement process. Online claim filing simplifies the submission process, enabling class members to easily provide the necessary information. This digital option reduces administrative costs, speeds up the processing of claims, and increases participation rates by eliminating barriers such as mailing delays or lost paperwork. Additionally, CEG’s online filing system offers features like automatic confirmation of submission, providing class members with greater transparency and assurance throughout the claims process.
The next phase is claims analysis and evaluation, where compensation amounts are calculated according to the settlement terms. During this stage, we also work to identify and eliminate any duplicate claims to prevent double payments. Additionally, we address dispute resolution through a formal process, allowing claimants to appeal decisions as outlined in the settlement agreement if they believe their claim was denied in error or other discrepancies arise Throughout the auditing process, CEG maintains detailed audit trails to ensure transparency and accountability. We generate compliance reports summarizing the findings, including statistics on approved, denied, and disputed claims, providing a comprehensive overview of the claims auditing process.
Settlement Fund Distribution Once the settlement allocation determinations have been calculated, audited, and finalized, the fund distribution commences. There are various forms of payment options available in a class action, including but not limited to: •Check payment •Rebate, refund, or credit •Retirement or pension plan distribution •Product repair or replacement •Coupon or voucher •Goods or services •Gift card •Injunctive relief
New forms of settlement payments, such as Zelle, PayPal, and Venmo, Amazon Pay, Google Pay, Apple Pay, e-checks, ACH, and more are becoming increasingly popular as efficient alternatives to traditional check distributions. These digital payment methods offer faster and more convenient ways for class members to receive their settlement funds, often providing near-instant access to their compensation. By leveraging these platforms, CEG reduces administrative costs and eliminates issues like lost or uncashed checks. These payment options provide tracking and receipt confirmation, giving all parties clear records of the transaction.
•Qualified Settlement Funds At CEG, we specialize in the comprehensive management of Qualified Settlement Funds (QSFs), a vital component of settlement administration. With decades of experience, we manage every phase of QSF administration—including fund creation, record-keeping, oversight, and tax reporting—ensuring settlement funds are handled efficiently and in full compliance with all legal and regulatory requirements.
The process begins with obtaining court approval, where we assist in preparing and submitting the necessary documentation to establish the QSF. Once the court order is secured, CEG facilitates the complete setup of the fund, including obtaining an Employer Identification Number (EIN) from the IRS for tax compliance purposes. We also establish a segregated, federally insured bank account to hold the settlement proceeds, ensuring the security, transparency, and traceability of all financial transactions.
As part of our QSF management services, CEG provides escrow agency support to safeguard and manage the settlement funds throughout the lifecycle of the administration. We deliver detailed reporting and reconciliation services to ensure full transparency and accountability. Our team generates comprehensive financial reports that monitor all key fund activities—deposits, distributions, investments, earnings, and administrative expenses—giving stakeholders a clear and real-time view of the fund's status and performance.
In collaboration with experienced tax professionals, CEG ensures that all required tax returns are prepared and filed accurately and on time, addressing any federal, state, or local withholding obligations. We maintain rigorous compliance with all applicable laws, including complex banking and securities regulations, ensuring the QSF operates within the full scope of legal mandates.
Our reconciliation process ensures the accuracy and integrity of all fund transactions. This includes reconciling bank statements, investment records, and internal accounting logs. By maintaining precise, up-to-date records, CEG ensures that the QSF adheres to all court orders and regulatory requirements, while also providing the necessary documentation for tax filings, audits, and other legal obligations.
If there are unclaimed or undistributed funds at the conclusion of the administration, CEG will assist in implementing the options defined by the settlement agreement and the parties involved. This may include reversion, where the remaining funds are returned to the defendant, or a cy pres distribution to a designated charitable organization, as specified in the agreement. In instances where escheatment is necessary, we ensure that unclaimed funds are transferred to the state in accordance with unclaimed property laws. CEG provides expert guidance in executing these options, ensuring full compliance with court orders and all regulatory requirements while respecting the terms agreed upon by the parties.
