Welcome from Classaction.org!

Thank you for your interest. Milberg is pursuing arbitration claims against ClassPass USA LLC (“ClassPass”) for using the Meta Pixel to track the activities of account holders and share them with third parties (including Meta) without the consent of users. We believe this is a violation of the Video Privacy Protection Act (VPPA).
If this happened to you, we believe you may be eligible to receive compensation for your damages. Milberg can pursue these claims on your behalf.

Please answer the following questions to help us determine if you are eligible to make a claim for compensation:





Congratulations!

Looks like you qualify and we’d like to immediately move your claim forward. This will cost you nothing out of pocket. We get paid only if we recover an award or settlement on your behalf. Our fee is 40% of the award we recover for you. If we don’t win, you don’t pay.

To move forward, please provide the following information:

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By continuing through this form, you represent that you do not own, work for, represent, or contemplate representing the company that is the subject of this arbitration. Milberg considers the following retainer agreement attorney work product and privileged. Any employee of a law firm viewing this document and not seeking representation is in violation of the Model Rules of Professional Conduct, including, but not limited to Rule 4.1.

Help us verify your claim

ClassPass USA may require you to produce documentation or proof that you used their services. Please keep an eye out for future correspondence from Milberg. Your data privacy is important to us. This information will not be shared for any reason outside of pursuing this claim on your behalf.

If you don't have it available, leave this blank and continue.

The next step is essential in order to give us the permission we need to pursue this claim on your behalf.

You will be asked to electronically sign our Contingency Fee Agreement.

  • You pay nothing out of pocket
  • You will not be asked for any credit card information to hire our firm
  • If we win, our fee is paid from a percentage of the money we recover for you
  • If we do not win, you pay nothing


By continuing through this form, you represent that you do not own, work for, represent, or contemplate representing the company that is the subject of this arbitration. Milberg considers the following retainer agreement attorney work product and privileged. Any employee of a law firm viewing this document and not seeking representation is in violation of the Model Rules of Professional Conduct, including, but not limited to Rule 4.1.

Client Name: 
Client Email: 

Re: [CLIENT NAME] v. ClassPass USA, LLC
Dear [CLIENT NAME]

This is an agreement (the “Agreement”) between you and Milberg Coleman Bryson Phillips Grossman LLC (“MCBPG”) for legal representation for your claims against ClassPass USA, LLC (“ClassPass”) for its violations of the Video Privacy Protection Act, 18 U.S.C. § 2710. If applicable, you are representing that you have authority and legal capacity to pursue this claim on behalf of your minor child. 

You understand and authorize MCBPG to proceed with filing your claims as an individual arbitration. Arbitration is a simplified means of pursuing legal claims, where the claim is decided by an arbitrator rather than a judge or jury. However, this agreement also authorizes MCBPG to settle your claim as a part of a class action if ClassPass chooses to do so. MCBPG intends to secure the maximum recovery for your claims. However, you authorize MCBPG to resolve your claims with ClassPass, at a minimum, the choice of either money or in-app credit with a fifty-dollar ($50.00) value.  Of course, we will try to obtain a larger settlement amount. 

Our firm will handle this matter with a contingent fee of the greater of either forty percent (40%), as allowed by state law, of any recovery obtained in this matter or a total attorneys’ fees awarded by the arbitrator or court. We reserve the right to associate with any co-counsel, but our fee will be split among our firm and any firm(s) we associate. 

We will advance all costs incurred by our firm during this litigation (e.g., filing fees, travel, etc.). We will be reimbursed for these costs if, and only if, we ultimately obtain a recovery. Advanced costs are deducted after the calculation of the contingent fee.

You authorize MCBPG to withdraw from our representation if we determine for sufficient reasons that the case should not continue. Regardless, we will maintain the file on this matter for at least six years. If requested, these will be returned to you after the conclusion of the representation.

Finally, we do not make any promises or guarantees regarding the outcome of your claims. If you have any questions about the foregoing, please advise. We would appreciate your returning a signed copy of this engagement letter to us for our files.

          Sincerely,    

                  Natalie M. Rico   


CERTIFICATION 

I, the undersigned client, understand that I will not be able to pursue a VPPA claim against ClassPass unless I have purchased a subscription on ClassPass’ website and/or mobile application during the past two years.  By signing this agreement, I hereby represent that I have visited the above-described website and/or mobile application and purchased at least one subscription during the past two years.  If necessary, I could testify or produce documents confirming that I have or had an account with ClassPass, visited the website and/or mobile application at issue, and purchased an individual subscription. 



AGREED TO: 

By: _________________                  Date: _______________

[1] Please note that the company against which you are retaining Milberg to pursue individual arbitration claims on your behalf requires a notice letter personally signed by you to begin the dispute resolution process.  So that Milberg can start this process, by signing the retainer agreement, it is your intent to provide Milberg with your electronic signature and your consent to include your electronic signature in the notice letter to be sent on your behalf to the company identified in the retainer agreement as the party against whom Milberg has agreed to represent you in connection with an individual arbitration.  This is the sole limited purpose for which you are giving Milberg legal authority to utilize your electronic signature.

Thank you for letting us review your potential claim.

After review of the information provided, our firm has decided to respectfully decline representation.

Although we are not representing you in this matter, we appreciate the opportunity to review your case, and we wish you the best possible outcome. Please feel free to contact us again should the need arise.

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