Notice of Class Action Settlement
Vega v. Ampac Holdings, LLC

1.     Introduction

An Illinois circuit court in McHenry County preliminarily approved a class action settlement in the lawsuit, Vega v. Ampac Holdings, LLC, Case No. 2026LA000060 (the “Lawsuit”).

You received this notice because you may be a member of the Settlement Class. The Court has approved this Notice to inform you of your rights. As further explained in this Notice, you have the following four options:

Summary of Your Options
1.	Receive a Settlement Payment. To get a Settlement Payment, you must complete, sign, and return a Claim Form, in exchange for giving up certain legal claims you have. The Claim Form is attached to this Notice and is also accessible via the QR code printed on this Notice below. To receive a Settlement Payment, the Claim Form must be submitted on the website or be completed and returned via U.S. Mail, and postmarked on or before June 15, 2026.
2.	Exclude Yourself from the Settlement. If you do not want to receive a Settlement Payment and do not want to give up any legal claims, you can exclude yourself from the Settlement by following the instructions below.
3.	Object to the Settlement. You can object to the Settlement by following the instructions below.
4.	Do Nothing. If you do nothing, you will not receive a settlement payment, but you will still give up certain legal claims you have.

Before any money is paid, the Court will decide whether to grant final approval of the settlement.

2.     What Is this Lawsuit About?

The Illinois Biometric Information Privacy Act (“BIPA”) prohibits private companies from capturing, collecting, or otherwise obtaining an individual’s biometric identifier or biometric information, including a fingerprint or handprint, or identifying information based on a fingerprint or handprint, without first providing an individual with certain written disclosures and obtaining written consent. The Lawsuit alleges that Defendant Ampac Holdings, LLC (“Defendant”) violated BIPA by using one or more biometric devices to collect biometric data from employees in Illinois without first providing written notice and obtaining written consent. Defendant contests these allegations, and denies that it violated BIPA. The parties agreed to a settlement to resolve the Lawsuit. The Court did not decide whether Defendant violated the law.

You can learn more about the Lawsuit by contacting the settlement administrator, ILYM Group, at (888) 250-6810. You may also review the Settlement Agreement and related case documents at the settlement website: www.AmpacBIPASettlement.com.

3.     Who Is Included in the Settlement?

The settlement includes all individuals who scanned a portion of a finger or handprint on a timekeeping device within the State of Illinois between February 12, 2020, and March 3, 2026 (“Settlement Class”). Excluded from the Settlement Class are persons who timely elect to exclude themselves (as described below), as well as those who previously released the claims raised in the complaint or who executed a consent for the collection of biometric information prior to the first time they completed such scan.

4.     What does the Settlement Provide?

Defendant has agreed to create a cash Settlement Fund to settle the claims of Settlement Class Members. Subject to Court approval, the following expenses will be deducted from the Settlement Fund: (1) an award of up to 35% of the total settlement for Settlement Class Counsel’s attorneys’ fees and litigation costs; (2) a Service Award of $8,500 to Settlement Class Representative, Michael Vega; and (3) the Settlement Administrator’s costs estimated to be less than $12,000.00. Following these deductions, the remaining amount shall be distributed equally to Settlement Class Members who timely return valid claim forms.

Settlement Class Counsel estimate that Settlement Class Members who submit valid claim forms will receive approximately $572.36 each.

Unless Settlement Class Members exclude themselves from the settlement as explained below, they will give up all claims against the Released Parties arising out of or relating to the collection, storage, possession, disclosure, or use of data derived from alleged biometric identifiers or biometric information in Illinois, between February 12, 2020, and March 3, 2026, including, but not limited to, claims under BIPA, statutory and common law claims, as well as related claims for liquidated damages, penalties, attorneys’ fees and costs, expenses, and interest.

The “Released Parties” include Defendant, Class Members’ employing entities (specifically, Ampac Flexicon, LLC, Prairie State Group, Gateway Packaging Company, LLC, and Ampac Flexibles, LLC), and their current and former owners, affiliates, parents, subsidiaries, divisions, officers, directors, shareholders, agents, vendors, employees, attorneys, insurers, reinsurers, benefit plans, predecessors, and successors. The full release of claims is set forth in the Settlement Agreement.

5.     What Are My Options?

(1) Request a settlement payment. If you received this Notice and want to receive a settlement payment, you must complete and submit online, or return via U.S. Mail, a claim form by June 15, 2026. You may return your claim form in the accompanying pre-paid envelope (if you received this Notice by mail). Or you may complete and submit a claim form online through the settlement website: www.AmpacBIPASettlement.com, which is also accessible through the QR code printed on the first page of this Notice. If you are a part of the Settlement Class, you timely return a completed and valid claim form, and the Court grants final approval of the settlement, you will receive a check or an electronic payment, depending on which method of payment you select on the claim form. If required by law, you may also be sent a 1099 tax reporting form.

(2) Exclude yourself from the settlement and receive no money. If you received this Notice and do not want to be legally bound by the settlement, you must exclude yourself from the settlement by June 15, 2026. If you do this, you will NOT get a settlement payment. To exclude yourself, you must mail your written request for exclusion to the Settlement Administrator (contact information below). Your written request for exclusion must include your full name, address, telephone number, the last four digits of your Social Security Number, a statement that you wish to be excluded from the settlement, and it must be signed by you (an electronic signature qualifies). If you exclude yourself, you will not receive money from this settlement, but you will keep your legal rights regarding any claims that you may have against Defendant and the other Released Parties.

(3) Object to the Settlement. If you received this Notice, you may object to the settlement by June 15, 2026. If you want to object to the settlement, you must mail a written objection to the Settlement Administrator (contact information below), which includes your full name, address, telephone number, the last four digits of your Social Security Number, the grounds for the objection, whether the objection applies to you only, a subset of the class, or the entire class, and copies of any other documents that you wish to submit in support of your objection. Any objection must also be personally signed by you (an electronic signature qualifies). If you exclude yourself from the settlement, you cannot file an objection.

(4) Do Nothing. You may choose to do nothing. If you receive this Notice and you do nothing, you will receive no money from the settlement, but you will still be bound by all orders and judgments of the Court. You will not be able to file or continue a lawsuit against the Released Parties regarding any legal claims released in this settlement.

6.     How do I update my Contact Information?

You must notify the Settlement Administrator of any changes in your mailing address so that your settlement award, should you be eligible to receive one, will be sent to the correct address. To update your address, contact the Settlement Administrator, listed below.

7.     Who Are the Attorneys Representing the Class and How Will They Be Paid?

The Court has appointed Settlement Class Counsel, identified below, to represent Settlement Class Members in this settlement.

Settlement Class Counsel will request up to 35% of the total settlement amount as attorneys’ fees and for reimbursement of their costs. You may review Settlement Class Counsel’s request for attorneys’ fees and costs at the settlement website, www.AmpacBIPASettlement.com, after August 25, 2026. You will not have to pay Settlement Class Counsel from your settlement award or otherwise.

You also have the right to hire your own attorney at your own expense.

8.     When is the Final Approval Hearing?

The Court will hold a hearing in this case on August 25, 2026, at 9:00 a.m. via Zoom, to consider, among other things: (1) whether to finally approve the settlement; (2) a request by the lawyers representing Settlement Class Members for an award of no more than 35% of the settlement as attorneys’ fees and for reimbursement of litigation costs; (3) a request for a Service Award for the Settlement Class Representative Michael Vega of no more than $8,500; and (4) a request for the Settlement Administrator’s costs.

You may appear at the final approval hearing, but you are not required to do so.

9.     What If You Have Questions or Want More Information?

If you have any questions or for more information, contact the Settlement Class Counsel (identified in Section 7 of this Notice) or the Settlement Administrator at:

PLEASE DO NOT CONTACT THE COURT OR THE CLERK OF COURT ABOUT THIS SETTLEMENT.