SUBMIT A CLAIM
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 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 this 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 that 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 Superior Court of Orange County, California, authorized the Notice. 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. The Notice explains the lawsuit, your legal rights, what benefits are available, and who can receive them.
The lawsuit is called Kenneth Keller v. System Pavers, LLC, Case No. 30-2025-01477814-CU-BT-CXC. It is pending in the Superior Court of Orange County, California. The person that filed this lawsuit is called the “Plaintiff” (or “Class Representative”) and the company they sued, System Pavers, LLC, is called the “Defendant.”
Back To Top
This lawsuit alleges that during the September 2024 cyberattack on System Pavers' computer systems, certain files that contained private information were or potentially were accessed. These files may have contained personal information such as first name or first initial and last name, and Social Security number.
Back To Top
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 “Class” or “Class Members.” One court resolves the lawsuit for all Class Members, except for those who opt out from the settlement. In this Settlement, the Class Representative is Kenneth Keller. Everyone included in this Action are the Class Members.
Back To Top
The Court has not decided in favor of the Plaintiff or the Defendant. Both sides have agreed to a settlement to avoid the costs and risks of a trial, and to allow the Class Members to receive benefits from the Settlement. The Plaintiff and their attorneys think the Settlement is best for all Class Members.
Back To Top
The Court has defined the Class this way: “All individuals residing in the United States whose Personal Information was potentially compromised in the Data Security Incident experienced by System Pavers, including all those who were notified of the Data Security Incident.”
Back To Top
Yes. Excluded from the Class are: (1) System Pavers and its officers, directors, and related companies; (2) anyone who validly excludes themselves from the Settlement; (3) the Judge in this case, and the Judge’s family and staff; and (4) anyone who perpetrated the Data Security Incident.
If you are not sure whether you are a Class Member, you can ask for free help any time by contacting the Settlement Administrator at:
System Pavers Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@SystemPaversDataIncident.com
Call toll free, 24/7: (833) 421-7276
You may also view the Settlement Agreement here.
Back To Top
System Pavers will establish a Settlement Fund of $350,544.00. The Settlement Fund will first be used to pay court-approved attorneys’ fees and costs, Service Award payments for the Plaintiffs, and the costs of administering the Settlement. The net remaining money will be used to pay for the benefits described below.
Credit Monitoring Services. All Class Members are eligible to enroll in three (3) years of CyEx Financial Shield Complete. This comprehensive service comes with $1 million of financial fraud insurance, and includes monitoring for:
If anything suspicious happens, you will be able to talk to a fraud resolution agent to help fix any problems.
Cash Payments. In addition to Credit Monitoring, all Class Members may claim one or more of the following cash payment options:
Documented Losses. If you incurred actual, documented, unreimbursed out-of-pocket losses due to the Data Security Incident you can get back up to $3,000.00. The losses must have occurred between September 20, 2024, and September 28, 2026.
This benefit covers out-of-pocket expenses like:
You need to send 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 or notes should show that your expenses were because of the Data Incident.
You cannot claim a payment for expenses that have already been reimbursed by a third party.
Lost Time. Class Members who spent time responding to the Data Security Incident may claim up to four (4) hours, at $20.00 per hour, for a maximum of $80.00.
You must have spent the time on tasks related to the Data Security Incident. Some examples include things like:
You must briefly describe how you spent this time. This payment counts toward the $3,000.00 cap for loss claims.
Alternative Cash Payment. Instead of any other cash payment option, you may claim a one-time cash payment. This payment is expected to be $100.00 for California residents, and $80.00 for residents of all other states. The payment may be larger or 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:
System Pavers Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Email: info@SystemPaversDataIncident.com
Call toll free, 24/7: (833) 421-7276
Back To Top
If you stay in the class, you won’t be able to be part of any other lawsuit against System Pavers about the issues that this Settlement covers. The “Releases” section of the Settlement Agreement (Section IX) describes the legal claims that you give up if you remain in the Class. The Settlement Agreement is available here.
Back To Top
The fastest way to submit your Claim Form is online here. If you prefer, you can download a printable Claim Form here and mail it to the Settlement Administrator at:
System Pavers Data Security 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) 421-7276, by email info@SystemPaversDataIncident.com, or by U.S. mail at the address above.
Back To Top
If you are submitting a Claim Form online here, you must do so by September 28, 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 September 28, 2026.
Back To Top
The Court will hold a Final Approval Hearing on November 13, 2026 (see Question 18). If the Court approves the Settlement, there may be 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.
Back To Top
Yes, the Court has appointed attorneys Carly M. Roman and Brittany Resch of Strauss Borrelli PLLC., to represent you and other Class Members (“Class Counsel”).
Back To Top
You will not be charged for Class Counsel’s services. If you want your own lawyer, you may hire one at your expense.
Back To Top
Class Counsel will ask the Court to approve $116,848.00 as reasonable attorneys' fees and costs of litigation. This amount will be paid from the Settlement Fund.
Class Counsel will also ask for a Service Award Payment of $3,000.00 for the Class Representative. The Service Award Payment will also be paid from the Settlement Fund.
Back To Top
If you do not want to be part of the Settlement, you must formally exclude yourself from the Settlement. This is called a Request for Exclusion and is sometimes also called “opting out.” If you opt out, you will not receive Settlement benefits or payment. However, you will keep any rights you may have to sue System Pavers on your own about the legal issues in this case.
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 any Settlement benefits if you exclude yourself.
The deadline to exclude yourself from the Settlement is August 28, 2026.
To be valid, your Request for Exclusion must have the following information:
You may only exclude yourself, not any other person.
Mail your Request for Exclusion to the Settlement Administrator at:
System Pavers Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Your Request for Exclusion must be postmarked or emailed by August 28, 2026.
Back To Top
If you are a Class Member and do not like part or all of the Settlement, you can object to it. Objecting means telling the Court your reasons for why you think the Court should not approve the Settlement. The Court will consider your views.
You cannot object if you have excluded yourself from the Settlement (see Question 15).
You must provide the following information in writing to the Settlement Administrator by the Objection Deadline or appear and orally present at the Final Approval Hearing for the Court to consider your objection:
For your objection to be valid, it must meet each of these requirements.
To be considered by the Court, you must either submit your objection in writing to the Settlement Administrator by August 28, 2026 or personally appear at the Final Approval Hearing.
System Pavers Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Back To Top
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.
Back To Top
The Court will hold a final approval on November 13, 2026, at 9:00 a.m. Pacific Time, in Department CX101 of the Superior Court of Orange County, California, at 751 W Santa Ana Blvd, Santa Ana, CA 92701.
At the Final Approval Hearing, the Court will decide whether to approve the Settlement. The Court will also decide how Class Counsel should be paid, and whether to award a Service Award Payment to the Class Representative. The Court will also consider any objections to the Settlement.
If you are a 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 the hearing may change without further notice. Please visit this website for updates.
Back To Top
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 submit 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 submitted by the Objection Deadline. If you did not timely submit an objection, you may still appear at the Final Approval Hearing at your own expense to orally present your objection. You may also pay your own lawyer to attend, but you do not have to.
Back To Top
If you do nothing, you will not receive a benefit from this Settlement.
You will also give up the rights described in Question 8.
Back To Top
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:
System Pavers Data Security Incident Settlement
c/o Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799-9958
Emai: info@SystemPaversDataIncident.com
Call toll free, 24/7: (833) 421-7276
You can obtain copies of publicly filed documents by visiting the office of the Clerk of the Court, 751 W Santa Ana Blvd, Santa Ana, CA 92701.
Do not contact the Court or Clerk of Court regarding this Settlement
Back To Top