Wang et al. v. Grubhub, Inc.

BASIC INFORMATION

1. Why should I read this Notice?

   If you ordered and paid for food through the Grubhub or Seamless app or website between January 24, 2019 and January 12, 2026 for delivery to an address in the State of California, you are a Settlement Class Member and may be entitled to receive a Settlement Award in the form of a $10.00 Grubhub site credit for use on the Grubhub App or website if you file a Claim.

   A Court authorized this Notice because you have a right to know about the proposed Settlement of a class action lawsuit known as Wang et al. v. Grubhub, Superior Court of the State of California for the County of Los Angeles, Case No. 23STCV24118 and about all of your options before the Court decides whether to give final approval to the Settlement. This Notice explains the lawsuit, the Settlement, and your legal rights.

   Judge Timothy Patrick Dillon of the Superior Court of the State of California for the County of Los Angeles is overseeing this lawsuit. The people who sued are called the “Plaintiffs.” Grubhub Inc. (“Grubhub”) is the Defendant.

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2. What is this lawsuit about?

   This lawsuit alleges that Grubhub made false or misleading representations regarding delivery fees, service fees, and menu prices on its delivery orders between January 24, 2019 and January 12, 2026. You can get complete details regarding these allegations in the Class Action Complaint available at the settlement website www.GHdeliveryfeesettlement.com. Grubhub denies these allegations and denies any wrongdoing. The Court has not decided who is right. The Parties have agreed to a Settlement.

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3. Why is this lawsuit a class action?

   In a class action, one or more people called “Class Representatives” (in this case, Plaintiffs Charles Wang, Marilee Bogaert, Robert Allan Perkins, Jr., Carissa Recco, Christine Bak, Denise Sznitko and Jesse Stout) sued on behalf of themselves and other people with similar legal claims. Together, all the people with similar legal claims (except those who exclude themselves) are members of a “Settlement Class.”

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4. Why is there a Settlement?

   The Court has not decided in favor of the Plaintiffs or Grubhub. Instead, both sides have agreed to the Settlement to avoid the costs and uncertainty of a trial; if the Settlement is approved by the Court, Settlement Class Members will receive the benefits described in this Notice. The proposed Settlement does not mean that any law was broken or that Grubhub did anything wrong. Grubhub denies all legal claims in this case and denies any wrongdoing. Plaintiffs and their lawyers think the proposed Settlement is best for everyone affected.

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WHO IS IN THE SETTLEMENT?

To see if you are eligible for benefits, you must first determine if you are a Settlement Class Member.

5. Am I part of the Settlement?

   You are a Settlement Class Member if you ordered and paid for food through the Grubhub or Seamless app or website between January 24, 2019 and January 12, 2026, for delivery to an address in the state of California.

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THE SETTLEMENT BENEFITS - WHAT YOU GET

6. What does the Settlement provide?

   As a Settlement Class Member, you can file a Claim to receive a Settlement Award. Settlement Class Members who submit a valid Claim Form will receive a Settlement Award in the form of a $10.00 Grubhub site credit for use on the Grubhub app or website. No sales taxes will be assessed on the value on the credit.

   The value of the Settlement Award(s) issued to Settlement Class Members will not exceed $5,000,000. If it is not possible to issue Settlement Awards of $10.00 to all Settlement Class Members who file a Valid Claim, the Settlement Awards will be adjusted downward proportionally.

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HOW TO GET BENEFITS FROM THE SETTLEMENT

7. How can I get my Settlement Award?

   If you are a Settlement Class Member, you must fill out and submit a Claim Form to qualify for a Settlement Award. You can easily file your Claim at www.GHdeliveryfeesettlement.com. The completed Claim Form must be submitted online by August 7, 2026.

   Upon receiving a completed Claim Form, the Class Action Settlement Administrator will review and confirm or deny your eligibility for a Settlement Award. If the Settlement is approved, Settlement Class Members who file a valid Claim Form will be sent an email providing instruction on how to accept and redeem a Settlement Award in the form of a $10.00 Grubhub site credit.

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8. When will I receive my Settlement Award?

   The Court will hold a hearing on August 10, 2026, at 10:00 a.m. (subject to change), to decide whether to approve the Settlement. Even if the Court approves the Settlement, there may be appeals. The appeal process can take time, perhaps more than a year. You will receive your Settlement Award 60 days after the Final Approval Order is entered or 60 days after any and all appeals are resolved, whichever is later. Please be patient.

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9. What else does the Settlement Provide?

   Grubhub has agreed to the following: (1) Grubhub will display fees and taxes as separate line items or otherwise ensure they are prominently disclosed; and (2) Grubhub will not advertise “free delivery” for Grubhub+ members (but may advertise “$0 delivery” and similar alternatives for Grubhub+) on Grubhub+ orders where other fees apply and in these instances will, space permitting, note other fees may apply.

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10. What am I giving up to receive these Settlement benefits?

    Unless you exclude yourself from the Settlement, you cannot sue or be part of any other lawsuit against Grubhub about the legal issues in this lawsuit, including any existing lawsuit, arbitration, or proceeding. Unless you exclude yourself, all of the decisions and judgments made by the Court will bind you. If you file a Claim Form for a Settlement Award or do nothing at all, you will be releasing Grubhub from all of the legal claims described and identified in Section IV.C of the Settlement Agreement.

    The Settlement Agreement is available at www.GHdeliveryfeesettlement.com. The Settlement Agreement provides more details regarding the Released Claims with specific descriptions in necessary, accurate legal terminology, so read it carefully. You can talk to Class Counsel, the lawyers representing the Settlement Class listed in Question 11 for free, or you can, at your own expense, talk to your own lawyer if you have any questions about the Released Claims or what they mean.

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THE LAWYERS REPRESENTING YOU

11. Do I have a lawyer in this case?

    The Court has appointed lawyers from the law firm KalielGold PLLC, of Washington, D.C. to represent you and the other Settlement Class Members. The lawyers are called Class Counsel. They are experienced in handling similar class action cases. You will not be charged for these lawyers. If you want to be represented by your own lawyer, you may hire one at your own expense.

    You may contact Class Counsel if you have any questions about this Notice or the Settlement. Please do not contact the Court.

    Class Counsel:
    KALIELGOLD PLLC
    1100 15th Street NW, 4th Floor
    Washington, D.C. 20005

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12. How will the Class Counsel lawyers be paid?

    The Class Counsel lawyers will ask the Court for an award of attorneys’ fees and costs not to exceed $1,000,000. If approved by the Court, these attorneys’ fees and costs will be paid separately by Grubhub.

    Class Counsel will also ask the Court for an incentive award for each Class Representative of $1,000 each, for their participation as Class Representatives, for taking on the risks of the lawsuit, and for Settlement of their individual legal claims as Settlement Class Members in this lawsuit. If approved by the Court, the incentive award will be paid separately by Grubhub.

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YOUR RIGHTS - EXCLUDING YOURSELF FROM THE SETTLEMENT

If you do not want a Settlement Award, and you want to keep your right to sue or continue to sue Grubhub on your own about the legal issues in this lawsuit, then you must take steps to exclude yourself from the Settlement (get out of the Settlement). This is called “excluding yourself”—or “opting out” of the settlement class.

13. How do I get out of the Settlement?

    To exclude yourself from the Settlement, you must send a written “Request for Exclusion” that includes:

    • Your name, address, email address, and telephone number;

    • Your personal signature and not a signature of your lawyer or anyone acting on your behalf; and

    • The statement “I/we request to be excluded from the class Settlement in Wang et al. v. Grubhub.”

    You must mail your Request for Exclusion postmarked 45 days after Notice Date, please see your individual Notice for the Exclusion Deadline that applied to you to:

    Grubhub Delivery Fee Settlement Exclusions
    P.O. Box 2349
    Portland, OR 97208-2349

    If you do not follow these procedures and meet the deadline, you will remain a Settlement Class Member and lose any opportunity to exclude yourself from the Settlement. This means that your rights in this lawsuit will be determined by the Settlement Agreement if it receives final approval from the Court.

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14. If I exclude myself, can I get anything from the Settlement?

    No. If you exclude yourself, you cannot receive a Settlement Award. However, you may sue, continue to sue, or be part of a different lawsuit against Grubhub about the legal issues in this lawsuit.

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YOUR RIGHTS - OBJECTING TO THE SETTLEMENT

You can tell the Court that you do not agree with the Settlement or any part of it.

15. How do I tell the Court that I do not agree with the Settlement?

    If you are a Settlement Class Member, you can object to the Settlement if you do not agree with any part of it. You can give reasons why you think the Court should not approve it. The Court will consider your views. Note: You cannot ask the Court to order a different Settlement; the Court can only approve or reject the Settlement. If the Court denies approval of the Settlement, no Settlement Award will be sent out and the lawsuit will continue.

    To object to the Settlement, you must do so in writing and your objection must be postmarked 45 days after the Notice Date, please see your individual Notice for the Objection Deadline that applied to you. Your objection and any supporting papers must (a) clearly identify the case name and number (Wang et al. v. Grubhub, Superior Court of the State of California for the County of Los Angeles, Case No. 23STCV24118); and (b) be submitted to the Class Action Settlement Administrator at the following address:

    Grubhub Delivery Fee Settlement Objections
    P.O. Box 2349
    Portland, OR 97208-2349

    Written objections must include:

    • Your full name, address and telephone number;

    • A written statement of all grounds for the objection accompanied by any legal support for the objection (if any);

    • Copies of any papers, briefs or other documents upon which the objection is based;

    • A list of all persons who will be called to testify in support of the objection (if any);

    • A statement of whether you intend to appear at the Fairness Hearing;

    • Proof of membership in the Settlement Class;

    • A list of all objections filed by you, the objector and your lawyer to any and all class action settlements in the last ten years; and

    • Your signature and the signature of your lawyer, if any.

    If you file a timely objection, it will be considered by the Court at the Fairness Hearing. You do not need to attend the Fairness Hearing for the Court to consider your objection.

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16. What is the difference between objecting and asking to be excluded?

    Objecting is simply telling the Court that you do not agree with something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you do not want to be part of the Settlement Class. If you exclude yourself, you cannot object because you are no longer part of the lawsuit.

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YOUR RIGHTS - APPEARING AT THE FAIRNESS HEARING

The Court will hold a “Fairness Hearing” to decide whether to approve the Settlement. You may attend and you may ask to speak, but you do not have to.

17. When and where will the Court decide whether to approve the settlement?

    The Court will hold a Fairness Hearing at 10:00 a.m. on August 10, 2026, at the Superior Court of the State of California for the County of Los Angeles, located at 312 North Spring Street, Los Angeles, California 90012 in Courtroom 15.

    At the hearing, the Court will hear any comments, objections, and arguments concerning the fairness of the proposed Settlement, including the amount requested by Class Counsel for attorneys’ fees and costs. If there are objections, the Court will consider them. You do not need to attend this hearing. You also do not need to attend to have a comment or objection considered by the Court. After the hearing, the Court will decide whether to approve the Settlement. It is unknown how long these decisions will take.

    Note: The date and time of the Fairness Hearing are subject to change by Court Order. Any change will be posted at www.GHdeliveryfeesettlement.com. You should check this website to confirm that the date and/or time have not changed.

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18. Do I have to attend the Fairness Hearing?

    No. Class Counsel will answer all questions the Court may have. But you are welcome to attend the hearing at your own expense. If you submit an objection, you do not have to attend the hearing to talk about your objection. As long as you filed your written objection by the deadline, the Judge will consider it. You may also pay your own lawyer to attend, but it is not necessary.

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19. May I speak at the Fairness Hearing?

    As long as you do not exclude yourself, you can (but do not have to) participate and speak for yourself in this lawsuit about the Settlement. This is called making an appearance. You also can have your own lawyer speak for you, but you will have to pay for the lawyer yourself.

    If you have filed an objection and you want to appear, or if you want your own lawyer instead of Class Counsel to speak for you in this lawsuit, you should include in your objection a statement of whether you intend to appear at the Fairness Hearing.

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YOUR RIGHTS - DO NOTHING

20. What happens if I do nothing at all?

    If you do nothing, you will be part of the Settlement Class, and you will not get a Settlement Award from the Settlement. Unless you exclude yourself, you will not be permitted to continue to assert Released Claims in any other lawsuit against Grubhub about the legal issues in this case, ever again.

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GETTING MORE INFORMATION

21. Are there more details available about the Settlement?

    This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement at www.GHdeliveryfeesettlement.com, or by contacting Class Counsel at the address listed in response to Question 11 above.

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22. How do I get more information?

    You can call toll-free 1-877-522-2081; write to Grubhub Delivery Fee Settlement, P.O. Box 2349, Portland, OR 97208-2349; or go to www.GHdeliveryfeesettlement.com, where you will find answers to common questions about the Settlement, the Settlement Agreement, the Motion for Preliminary Approval and Class Counsel’s request for attorneys’ fees and costs (once it is filed), and other important documents in the case.

    PLEASE DO NOT CONTACT THE COURT OR THE COURT CLERK’S OFFICE REGARDING THIS NOTICE.

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