1. Why was the Notice issued?
2. What is this lawsuit about?
3. What is a class action?
4. Why is there a settlement?
5. Who is included in the Settlement?
6. Are there exceptions to being included?
7. What does the Settlement provide?
8. What claims am I releasing if I stay in the Settlement Class?
9. How do I submit a claim for a Settlement benefit?
10. Are there any important Settlement payment deadlines?
11. When will the Settlement benefits be issued?
12. Do I have a lawyer in the case?
13. Should I get my own lawyer?
14. How will Class Counsel be paid?
15. How do I opt out of the Settlement?
16. How do I tell the Court if I like or do not like the Settlement?
17. What is the difference between objecting and excluding?
18. When is the Court's Final Approval Hearing?
19. Do I have to come to the Final Approval Hearing?
20. What happens if I do nothing at all?
21. How do I get more information?
The 17th Judicial Circuit for Broward County, Florida authorized the Notice. You have a right to know about the proposed Settlement of this class action lawsuit, and about all of your rights and options, before the Court decides whether to grant final approval of the Settlement. The Notice explains the lawsuit, the Settlement, your legal rights, what benefits are available, who can receive the benefits, and how to receive those benefits.
The lawsuit is called Robert Alejnikov et al. v. WaterStreet Company, Case No. CACE-26-005928. It is pending in the 17th Judicial Circuit for Broward County, Florida. The people that filed this lawsuit are called the "Plaintiffs" (or "Class Representatives") and the company they sued, WaterStreet Company, is called the "Defendant."
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On March 17, 2025, WaterStreet discovered suspicious activity related to its network environment. In response, WaterStreet promptly launched an investigation to confirm the nature and scope of the activity. The investigation revealed that an unauthorized actor accessed certain files on March 17, 2025 (the "Data Incident"). WaterStreet then conducted a thorough review of the files and identified potential access to personal information such as name, Social Security numbers, bank account information, and taxpayer identification number.
On April 9, 2026, Plaintiffs filed a class action Complaint against WaterStreet in the Circuit Court of the 17th Judicial Circuit in and for Broward County, Florida, alleging negligence, breach of implied contract, and unjust enrichment, in relation to the Data Incident.
WaterStreet does not in any way acknowledge, admit to, or concede any of the allegations made in the Complaint, and expressly disclaims and denies any fault or liability, or any charges of wrongdoing that have been or could have been asserted in the Complaint.
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In a class action, one or more individuals sue on behalf of other people with similar claims. These individuals are called the "Plaintiffs" or "Class Representatives." Together, the people included in the class action are called a "Settlement Class" or "Class Members." One court resolves the lawsuit for all Class Members, except for those who opt out from the Settlement. In this proposed Settlement, the Class Representatives are Robert Alejnikov and Daniel Baldwin. Everyone included in this Action is a member of the Settlement Class.
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The Court did not decide whether the Plaintiffs or the Defendant are right. Both sides have agreed to a settlement to avoid the costs and risks of a trial, and to allow the members of the Settlement Class to receive benefits from the Settlement. The Plaintiffs and their attorneys think the Settlement is best for all members of the Settlement Class.
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The Court has defined the Settlement Class this way: "All living individuals residing in the United States who were sent a notice of the Data Incident indicating their Private Information may have been impacted in the Data Incident."
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Yes. Excluded from the Class are: (1) all persons who are directors, officers, and agents of WaterStreet, or its respective subsidiaries and affiliated companies; (2) governmental entities; (3) the Judge assigned to the Action, that Judge's immediate family, and Court staff; (4) any Settlement Class Member who timely opts out of the Settlement Class as instructed in the Settlement Agreement; (5) the attorneys representing the Plaintiffs and WaterStreet in the lawsuit; and (6) any person found by a court of competent jurisdiction to be guilty under criminal law of initiating, causing, aiding, or abetting the Data Incident, or who pleads nolo contendere to any such charge.
If you are not sure whether you are a Settlement Class Member, you can ask for free help any time by contacting the Settlement Administrator at:
WaterStreet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@WaterstreetSettlement.com
Call toll free, 24/7: (833) 421-7237
You may also review the Settlement Agreement here.
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All members of the Settlement Class will be automatically granted Credit Monitoring and may claim one of the two Cash Payment options. There is a cap of $500,000.00 on Cash Payments. This means that if the total value of benefits claimed is over $500,000.00, everyone's payments will be reduced pro rata so that they add up to $500,000. The benefits are explained in more detail below.
Credit Monitoring. All members of the Settlement Class are eligible to enroll in three years of CyEx Financial Shield Complete. Enrollment codes will be sent either via email or by a Postcard mailed to you. Visit http://app.financialshield.com/enrollment/activate/waterstreet to enroll. Your CyEx Financial Shield Complete subscription will become active once the Court grants Final Approval to this Settlement (i.e. approves the Settlement). If you no longer have your enrollment code, please contact the Settlement Administrator.
This comprehensive service comes with $1 million of financial fraud insurance, and includes monitoring for:
fraud or identity theft
unauthorized financial transactions
personal information associated with high-risk transactions
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
Cash Payments. You may claim only one payment from the two options.
Cash Payment A – Documented Losses. If you incurred actual, documented out-of-pocket losses due to the Data Incident, you can get back up to $3,000.00. The losses must have occurred between March 17, 2025, and August 19, 2026. You must have also made reasonable efforts to avoid, or seek reimbursement for, the loss.
This benefit covers out-of-pocket expenses like:
losses because of identity theft or fraud
fees for credit reports, credit monitoring, or freezing and unfreezing your credit
cost to replace your IDs
postage to contact banks by mail
You need to send third-party proof, like bank statements or receipts, to show how much you spent or lost. You can also send notes or papers you made yourself to explain or support other proof, but those notes or papers alone are not enough to make a valid claim. Your proof should show that your expenses were because of the Data Incident or more likely than not caused by the Data Incident.
Again, personal certifications, declarations, or affidavits do not constitute reasonable documentation to make a valid claim, but may be used to provide clarification, context, or support for other reasonable documentation.
You cannot claim payment for expenses that have already been reimbursed by a third party. This includes reimbursement in connection with the credit monitoring and identity theft protection product offered as part of the notification letter provided by WaterStreet or otherwise. There will also be no payments for emotional distress, personal/bodily injury, or to punish WaterStreet.
This payment may be smaller depending on the total claims filed.
-OR-
Cash Payment B – Alternate Cash. Instead of Cash Payment A, you may claim a one-time cash payment. This payment is expected to be $55.00 but may be smaller depending on the total claims filed. You do not have to provide any proof or explanation to claim this payment.
If you have questions about these benefits, you can ask for free help any time by contacting the Settlement Administrator at:
WaterStreet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@WaterstreetSettlement.com
Call toll free, 24/7: (833) 421-7237
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If you stay in the Settlement Class and do not opt out, you will not be able to be part of any other lawsuit against WaterStreet (and the Released Parties) or separately file a lawsuit about the issues that this Settlement covers. The "Releases" section of the Settlement Agreement (Section XI) describes the legal claims that you are giving up and against whom, if you remain in the Settlement Class.
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The fastest way to submit your Claim Form is online here. All submissions for Cash Payment A – Documented Losses must be submitted online. If you prefer, you can download a printable Claim Form here and mail it to the Settlement Administrator at:
WaterStreet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
You may also contact the Settlement Administrator to request a Claim Form by telephone, toll free, (833) 421-7237, by email info@WaterstreetSettlement.com, or by U.S. mail at the address above.
For more information about the Claim Process, please review Section VIII of the Settlement Agreement.
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If you are submitting a Claim Form online here, you must do so by August 19, 2026. If you are downloading a Claim Form here and submitting a claim by U.S. mail, the completed and signed Claim Form, including supporting documentation, must be postmarked no later than August 19, 2026.
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The Court will hold a Final Approval Hearing on September 3, 2026, at 8:45 a.m. ET (see Question 18 for more information about the Final Approval Hearing). If the Court approves the Settlement, then Settlement payments will be distributed for all Valid Claims filed by August 19, 2026. More information about this process can be found in the Settlement Agreement (Section VIII).
Settlement payments cannot be distributed if there are any appeals. We do not know if appeals will be filed, or how long it will take to resolve them if they are filed.
Settlement payments will be distributed if the Court grants final approval, and after any appeals are resolved. Please be patient and check this website for updates.
It is your responsibility to inform the Settlement Administrator of any updates to your information after the submission of your Claim Form.
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Yes, the Court has appointed attorneys Jeff Ostrow of Kopelowitz Ostrow P.A.; Mariya Weekes of Milberg LLC; Rachel Dapeer of Dapeer Law, P.A.; and Manuel Hiraldo of Hiraldo Law P.A. ("Class Counsel"), to represent you and other members of the Settlement Class.
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You will not be charged for Class Counsel's services. If you want your own lawyer, you may hire one at your expense.
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Class Counsel will ask the Court to approve up to $282,500.00 as reasonable attorneys' fees and costs of litigation. This amount will be paid by WaterStreet and is separate from WaterStreet's payment of the Settlement Administration Costs and the Settlement Class Member Benefits.
Class Counsel will also ask for Service Award payments of $2,500.00 for each of the Class Representatives. Service Award payments will also be paid by WaterStreet and separately from WaterStreet's payment of the Settlement Administration Costs and the Settlement Class Member Benefits.
The Court may award less than these amounts.
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If you do not want to be part of the Settlement or bound by the Agreement, you must formally exclude yourself from the Settlement. This is called an Opt-Out Request.
If you opt out, you are telling the Court that you do not want to be part of the Settlement. You will not be eligible to receive any Settlement benefits or payment, if you opt out. However, you will keep any rights you may have to sue WaterStreet (and the Released Parties) on your own about the legal issues in this case.
The deadline to opt out from the Settlement is August 4, 2026.
To be valid, your Opt-Out Request must have the following information:
the name of the Litigation: Robert Alejnikov et al. v. WaterStreet Company, Case No. CACE-26-005928, pending in the 17th Judicial Circuit for Broward County, Florida;
your full name, mailing address, telephone number, and email address;
personal signature; and
the words "Opt-Out Request" or a clear and similar statement that you do not want to participate in the Settlement.
You may only exclude yourself—not any other person or a group of persons.
Mail your Request for Exclusion to the Settlement Administrator at:
WaterStreet Data Incident Settlement
ATTN: Exclusion Request
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Opt-Out Request must be postmarked by August 4, 2026.
More information about this process can be found in the Settlement Agreement (Section VII).
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If you are a Settlement Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons why you think the Court should not approve the Settlement. The Court will consider your views.
You cannot object if you have opted out from the Settlement (see Question 15).
You must provide the following information for the Court to consider your objection:
the name of the Litigation: Robert Alejnikov et al. v. WaterStreet Company, Case No. CACE-26-005928, pending in the 17th Judicial Circuit for Broward County, Florida;
your full name, mailing address, telephone number, and email address (if any);
a statement as to whether the objection applies only to you, to a specific subset of the class, or to the entire class
all grounds for the objection, accompanied by any legal support for the objection known to you or your lawyer;
if you or your lawyer have objected in any other class action settlements in the past five years, provide the names, courts, and civil action number or case number for each of those cases, along with a copy of any orders related to or ruling upon your prior objections that were issued by the trial and/or appellate courts in each listed case;
if you have hired your own lawyer to represent you for this objection, provide their name, bar number, and contact information (including any former counsel who may be entitled to compensation for any reason related to the objection);
whether or not you or your lawyer will appear at the Final Approval Hearing and would like to speak at the Hearing;
a list of all persons who will be called to testify at the Final Approval Hearing in support of the objection (if any); and
your signature (if you have hired your own lawyer, their signature is not sufficient).
For your objection to be considered, it must meet each of these requirements.
To be considered by the Court, you must file your complete objection with the Clerk of Court by August 4, 2026. You must also send a copy of the objection by U.S. Mail to the Settlement Administrator, Class Counsel, and WaterStreet's Counsel. An objection shall be deemed to have been submitted on the date of the postmark on the envelope. If submitted by private courier (e.g., Federal Express), an objection shall be deemed to have been submitted on the shipping date reflected on the shipping label.
Clerk of the Court | Settlement Administrator | Counsel for Defendants |
Clerk of the Court | WaterStreet Data Incident Settlement | Carolyn Purwin Ryan |
Class Counsel | |||
Jeff Ostrow | Rachel Dapeer | Mariya Weekes | Manuel Hiraldo |
More information about this process and the deadlines can be found in the Settlement Agreement (Section VII).
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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 opt out from the Settlement. Opting out from the Settlement is stating to the Court that you do not want to be part of the Settlement or bound by the Settlement Agreement. If you opt out of the Settlement, you cannot object to it because the Settlement no longer affects you.
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The Court will hold a Final Approval Hearing on September 3, 2026, at 8:45 a.m. Eastern Time, in the 17th Judicial Circuit for Broward County, Florida, at 201 SE 6th Street, Ft. Lauderdale, FL 33301.
At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The Court will also decide Class Counsel's request for an attorneys' fees and costs award and the request for a Service Award to the Class Representatives. The Court will also consider any timely objections to the Settlement.
If you are a Settlement Class Member, you or your lawyer may ask permission to speak at the hearing at your own cost (see Question 16).
The date and time of this hearing may change without further notice. Please check this website for updates.
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No. Class Counsel will answer any questions the Court may have. You may attend at your own expense if you wish, but you do not have to.
If you file an objection, you do not have to come to the Final Approval Hearing to talk about it; the Court will consider it as long as it was filed on time. You may also pay your own lawyer to attend, but you do not have to.
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If you do nothing, you will not receive a benefit from this Settlement.
You will also give up the rights described in Question 8 and be bound by any Judgment issued by the Court along with the terms of the Settlement Agreement.
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This website and the Notice are a summary of the proposed Settlement. The full Settlement Agreement and other related documents are available on the Important Documents page.
If you have additional questions, you can ask for free help any time by contacting the Settlement Administrator at:
WaterStreet Data Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@WaterstreetSettlement.com
Call toll free, 24/7: (833) 421-7237
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 17th Judicial Circuit for Broward County, Florida, at 201 SE 6th Street, Ft. Lauderdale, FL 33301.
Do Not Contact the Court or Clerk of Court Regarding this Settlement.
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