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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANTONIO SOLIS, JOSE SOLIS, and 

JUAN RANGEL, individually and on behalf 

of all others similarly situated,

Plaintiffs, 

 v. 

HILCO REDEVELOPMENT LLC, et al., 

Defendants.

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Case No. 20-CV-2348 

Hon. Martha M. Pacold, 

District Judge

Hon. Sunil R. Harjani, 

Magistrate Judge 

DECLARATION OF JACOB KAMENIR

I, JACOB KAMENIR, pursuant to 28 U.S.C. § 1746, hereby declare as follows:

1. I am the Senior Director of Notice at Simpluris, Inc. (“Simpluris”). Simpluris is a 

national full-service class action notice and claims administrator located in Costa Mesa, 

California. 

2. I am an attorney licensed to practice in Minnesota, and hold a Master of Science 

in Industrial Administration (a variant of an MBA) from Purdue University. 

3. I have an extensive background in data analytics and legal marketing, and lead 

Simpluris’ legal noticing team. I have developed and overseen, in whole or in part, over 200 

notice programs and administrations, and have given both written and oral testimony on notice 

and administration procedures in federal and state court. 

SUMMARY OF RELEVANT EXPERIENCE

4. Simpluris has been executing notice plans and administering class action 

settlements since 2007. In that time, we have been appointed in over 9,000 cases and distributed 

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over $8 billion in funds. Our leadership team has over 100 years of combined industry 

experience that includes some of the largest class action administrations in the United States, 

including In re: Equifax, Inc., Customer Data Security Breach, Case No. 1:17-md-2800 (N.D. 

Ga.) and In re: Premera Blue Cross Customer Data Security Breach, Case No. 3:15-md-2633 

(D. Or.). Additional representative cases include In re: Ambry Genetics Data Breach Litigation, 

Case No. 8:20-cv-00791 (C.D. Cal.); Orellana v. Planned Parenthood of Los Angeles, Case No. 

21STCV44106, Cal. Sup. Ct. (Los Angeles); Cordova et al v. United Education Institute et al, 

Case No. 37-2012-00083573, Cal. Sup. Ct. (San Diego); Shuts v. Covenant Holdco, LLC, Case 

No. RG10551807, Cal. Sup. Ct. (Alameda); Hamilton et al v. Suburban Propane Gas Corp., 

Case No. BC433779, Cal. Sup. Ct. (Los Angeles); Upadhyay et al v. Prometheus Real Estate 

Group, Case No. 1-08-CV-118002, Cal. Sup. Ct. (Santa Clara); Starke v. Stanley Black & 

Decker Inc., Case No. C-03-CV-21-001091, Md. Cir. Ct. (Baltimore); and Hale v. Manna Pro 

Products LLC, Case No. 2:18-cv-00209 (E.D. Cal.). 

PRIVACY AND SECURITY

5. Simpluris maintains robust data and cybersecurity practices, controls, and 

procedures. These include the use of layered, industry-leading software and hardware systems to 

prevent both external and internal unauthorized access to sensitive client and company data. 

Unique among other administrators, Simpluris has developed a comprehensive, integrated 

administration system, Cadence, which was designed specifically to provide the highest level of 

data privacy and anti-intrusion security. Our systems are monitored, tested, and constantly 

upgraded by a highly experienced team of IT professionals, and systemwide security is overseen 

directly by our CTO. 

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6. Simpluris is SOC 2 certified. SOC 2 is a standard developed by the American 

Institute of CPAs (AICPA) to ensure that customer data is handled in a way that meets strict 

security, availability, integrity, confidentiality, and privacy standards. Certification requires an 

extensive audit of all aspects of company data practices by a qualified independent CPA or 

accounting firm. A true and correct copy of our SOC 2 certification is attached hereto. 

7. All Simpluris employees are required to undergo HIPAA training. 

8. Simpluris will access and handle class member data solely for the purpose of 

administering this notice program. 

9. Simpluris has been selected by the parties to be the Claims Administrator for the 

Settlement Agreement Solis, et al. v. Hilco Redevelopment LLC, et al., Case No. 20-CV-2348 

(N.D. Ill.). This declaration details the proposed notice plan (“Notice Plan”) that we will execute 

to provide notice to the Class in accordance with the requirements of due process, Fed. R. Civ. P. 

23, and guidance from the Federal Judicial Center (“FJC”), as well as the administration 

procedures we will undertake in keeping with applicable laws and industry best practices. 

10. Unless otherwise stated, capitalized terms in this declaration have the same 

meaning and are used in the same manner as in the Settlement Agreement.

OVERVIEW

11. Simpluris has been selected by Class Counsel to serve as the class action Claims 

Administrator in this case, if approved by the Court. Simpluris will be charged with, among other 

responsibilities: (a) disseminating direct notice by U.S. mail to individually ascertainable class 

members; (b) hanging “door hanger” notice on the doors of accessible addresses within the Class 

Boundaries; (c) executing a publication notice program, consisting of a press release, publication 

of notice in newspapers, and digital media programmatically targeted to adults in the Chicago, 

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Illinois area; (d) establishing and maintaining a settlement toll-free telephone number; (e) 

developing and maintaining a settlement interactive website that will host class documents, as 

well as allow class members to submit claims online; (f) processing incoming claims, requests 

for exclusion, objections, and related class correspondence; (g) establishing and maintaining a 26 

C.F.R. § 1.468B-1 compliant Qualified Settlement Fund (“QSF”); (h) calculating the amounts 

due to each class member pursuant to the settlement; (i) processing payments to class members 

who have made timely and valid claims; (j) preparing, processing, and filing all applicable tax 

forms and tax returns with state and federal agencies; and (k) providing appropriate notice to 

state and federal officials in compliance with the Class Action Fairness Act of 2005, 28 U.S.C. § 

1715(b) (“CAFA”). Additionally, Simpluris will coordinate with counsel to organize one or more 

community outreach events to provide Class Members opportunities to learn more about the 

Settlement and submit claims in a face-to-face setting.

NOTICE PROGRAM

12. The Notice Program design uses overlapping media channels to reach the 

maximum number of Class Members. 

13. To create a mailing list, Simpluris will acquire the names and addresses of all 

Class Members who owned or leased residential or commercial property within the Class 

Boundaries on April 11, 2020. Prior to mailing the Notice, Simpluris will update the mailing 

address information for Class Members via the USPS National Change of Address (“NCOA”) 

database, which provides updated address information for individuals or entities who have 

moved during the previous four years and filed a change of address with the USPS. Additionally, 

all addresses will be processed through the USPS Coding Accuracy Support System (“CASS”) 

and Locatable Address Conversion System (“LACS”) to ensure deliverability. 

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14. Notice of the Settlement will be mailed to all identified Class Members as a 

double-sided postcard via the United States Postal Service (“USPS”). The postcard will have a 

detachable Claim Form, and the Claim Form will have pre-paid Business Reply Mail (“BRM”) 

postage. The Notice will use both English and Spanish to direct Class Members to the Settlement 

Website, described in Paragraph 21. 

15. Notices returned to Simpluris by the USPS with a forwarding address will be remailed to the new address provided by the USPS and the Class Member database will be updated 

accordingly. 

16. Notices returned to Simpluris by the USPS without forwarding addresses will be 

processed through a public records address verification search (commonly referred to as “skip 

tracing”) utilizing a wide variety of data sources, including public records, real estate records, 

electronic directory assistance listings, and other sources, to locate updated addresses. 

17. When a new address is identified through the skip trace process, the Class 

Member database will be updated with the new address information and Notice will be re-mailed 

to that address. 

18. Simpluris will also cause an abbreviated form of notice to be placed on the doors 

of all accessible addresses within the Class Boundaries in the form of door hangers. These door 

hangers will use both English and Spanish to direct Class Members to the Settlement Website, 

described in Paragraph 21. 

19. Contemporaneous with the direct notice efforts, Simpluris will also execute a 

publication notice program. This will include a press release to Illinois media; publication of 

notice in the Chicago Tribue (106,156 print circulation) and La Raza (153,500 print circulation) 

newspapers; digital notice on the Facebook and Instagram social media platforms; and digital 

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notice in the form of programmatic banner ads (commonly called “website banner ads”). The 

social media and banner ad notices will demographically target adults 18 and older and 

geographically target to the area in and around ZIP Code 60623. Planned reach for digital notice 

is 98,167 impressions on Facebook and Instagram, and 24,542 impressions through banner ads. 

20. All forms of publication notice will use both English and Spanish to direct Class 

Members to the Settlement Website, described in Paragraph 21, and all forms of digital notice 

will further be hyperlinked (“clickable”) to the Class Website.

21. Simpluris will establish and maintain a Settlement Website, at which Class 

Members will be able to easily view information about the Settlement, including a map clearly 

showing the Class Boundaries; review relevant Court documents, such as the Settlement 

Agreement and long-form notice; view important dates and deadlines pertinent to the Settlement, 

such as the Final Fairness Hearing; learn about the dates, times, and locations of community 

outreach events, as described in Paragraph 23; file claims; and select payment options. The 

website will be designed to be accessible and user-friendly from any device, and will include 

both English and Spanish versions. Documents identified by the parties will be translated into 

Spanish and made available on the Settlement Website.

22. A toll-free telephone number devoted to this case will be implemented to further 

apprise Settlement Class Members of the rights and options in the Settlement. The toll-free 

telephone number will be listed on the Notice and the Settlement Website. The toll-free 

telephone number will utilize an interactive voice response (“IVR”) system to provide Class 

Members with responses to frequently asked questions about the Settlement in both English and 

Spanish. This toll-free telephone number will be accessible 24 hours a day, 7 days a week. 

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23. Simpluris will coordinate with counsel to organize one or more community 

outreach events. These events will provide Class Members with opportunities to learn about the 

settlement in person, ask questions, and receive instruction and assistance to file valid claims. 

These events will be referenced in all forms of notice, and the dates, times, and locations will be 

prominently displayed on the Settlement Website. 

24. The Notice Program described abo is designed for maximum outreach. It utilizes 

multiple overlapping methodologies and channels in effort to reach the largest possible number 

of Class Members.

CLAIMS ADMINISTRATION

25. As described in Paragraph 14, Simpluris will send paper Claim Forms as 

detachable, postage-paid postcards with the Notice. The Settlement Website will also have an 

online Claim Form that will substantively match the paper Claim Form. The online Claim Form 

will be designed to be easily accessible and viewed from all types of electronic devices, and will 

be available in English and Spanish. Claim filing assistance will be available at the community 

outreach events described in Paragraph 23. 

26. Simpluris will coordinate with counsel to implement processes and procedures for 

validating Class Member claims, both for online and paper submissions. Simpluris will provide 

counsel timely reports on the quantity and type of claims submitted.

27. Dispute resolution for claims will be conducted in accordance with the Settlement 

Agreement and in consultation with counsel. Simpluris will timely notify counsel of any disputed 

claims.

28. Simpluris will immediately notify counsel if any requests for exclusion or 

objections are received.

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AWARD DISBURSEMENT

29. Simpluris will establish and maintain a 26 CFR § 1.468B-1 compliant Qualified 

Settlement Fund for this Settlement. Simpluris will ensure that all federal and state statutory and 

regulatory tax filing and reporting requirements are fully complied with and completed. 

30. Once the Claims Deadline has passed, Simpluris will calculate individual award 

amounts based on the Settlement Agreement and disburse award payments accordingly. 

31. Individuals who chose to receive their award payment digitally will receive tax 

documents, if required, via email. Individuals who chose to receive their award as a paper check 

with receive tax documents, if required, as an enclosure with the check. 

32. Any mailed award payment checks that are returned as undeliverable will be skip

traced, as described in Paragraph 16, and remailed.

33. Once Attorneys’ Fees and Costs, Incentive Award, costs of notice and 

administration, and individual award payments have been paid and the final check negotiation 

deadline has passed, any residual funds remaining in the QSF will be disposed of in accordance 

with the Settlement Agreement.

CONCLUSION

34. The Notice Program that Simpluris will execute is “the best notice that is 

practicable under the circumstances” of this case in accordance with Fed. R. Civ. P. 23; due 

process; and the notice guidelines published by the FJC. 

35. Simpluris will administer the Settlement Agreement, including claims processing 

and award disbursement, as agreed to by the parties and approved by the Court, and in 

accordance with industry best practices and in full compliance with all applicable federal and 

state statutes and regulations. 

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 I declare under penalty of perjury that the foregoing is true and correct. 

Date: December 1, 2023 

 

 Jacob J. Kamenir

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