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, Arkansas Federal Credit Union and Summit Federal Credit Union v. Hudson’s Bay Company, et al., No. 19-cv-4492 (PKC) (S.D.N.Y.);
  • 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;
  • 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 Alerted-On Payment Cards issued by your financial institution.

You must mail via first class postage prepaid United States mail the completed above-described letter, postmarked no later than November 15, 2021, to each of the following addresses:

Settlement Administrator

Hudson’s Bay Company Financial Institution Data Breach Settlement
c/o Analytics Consulting LLC, Settlement Administrator
P.O. Box 2005
Chanhassen, MN 55317-2005

Settlement Class Counsel

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

Defense Counsel

Gregory T. Parks
Morgan, Lewis, & Bockius LLP
1701 Market Street
Philadelphia, PA 19103

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) Hudson’s Bay 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.