Basic Information
The Court authorized the Notice to inform potential Class Members about the proposed Settlement of a class action Lawsuit. The Notice explains: In a class action lawsuit, one or more people, called “Plaintiffs” or “Class Representatives,” sue on behalf of people who have similar claims. The people together are called the “Class” or “Class Members.” In this case, the Plaintiffs and the company being sued, the Defendant, have reached a proposed Settlement. One court resolves the issues of all Settlement Class Members, except for those people who exclude themselves from the Settlement Class. A class action was filed in the Superior Court of California, County of Los Angeles entitled Victor Guzman, Perry Bruno, Lauren Fleming, David Plowden, Karen Betzag, and Jaime Napolitano individually, and on behalf of all others similarly situated, v. Dr. Squatch, LLC, Case No.: 25STCV03523. This lawsuit is referred to as the “Action.” In the class action, the Plaintiffs allege that Dr. Squatch LLC (“Defendant”) represented that certain of its products (“Products”) were natural even though the Products contained certain ingredients Plaintiffs allege were synthetic. Dr. Squatch has at all times denied, and continues to deny, the allegations and that it has engaged in any wrongdoing. Specifically, Dr. Squatch maintains that the Products were properly labeled as natural. The Parties have agreed to settle the Lawsuit, without any finding of wrongdoing or admission of liability by Dr. Squatch, as a compromise to avoid the burden, expense and uncertainty of further litigation. The Court did not decide in favor of the Plaintiffs or Defendant. The Class Representatives and Class Counsel (listed below) believe that the claims asserted in the class action have merit but believe that the Settlement is in the best interests of the Settlement Class. Class Counsel has evaluated information made available in the course of the Lawsuit and Settlement negotiations and have taken into account the risks and uncertainties of proceeding with the Action. Those risks include the uncertainty of obtaining and maintaining Class certification, prevailing on the merits, proving damages at trial, and prevailing on post-trial motions and likely appeals. Based upon the consideration of these and other factors, including the substantial time and expense of further litigation, Class Counsel believe that it is in the best interests of the Settlement Class to settle the class action on the terms described below. Defendant strongly denies any wrongdoing and does not believe it has any liability to the Class Representatives or the Settlement Class. More specifically, Defendant denies making any material misrepresentations about the Products and the naturalness of their ingredients. However, Defendant believes that it is in its best interest to settle the class action under the terms of the Settlement Agreement and obtain closure on these matters to avoid the uncertainty, expense, and burden of further litigation. The Parties engaged in Settlement negotiations, participated in a mediation before a professional mediator, and shared information pertaining to the claims asserted in the class action before reaching the Settlement. The Notice does not imply that any court has found or would have found that Defendant violated the law, that a Class would have been certified, or that any member of the Class would have recovered any amount of damages if the class action were not settled.
Who Is in the Settlement?
The Settlement Class includes all Persons who purchased Covered Products in the United States between November 1, 2018 through August 29, 2026. Excluded from the Settlement Class are current or former employees, officers, directors, agents, or legal representatives of Dr. Squatch LLC, or its affiliated entities (and their immediate family members). What are the Covered Products: Covered Products include all products manufactured, sold, or distributed by Dr. Squatch currently or in the past that contain the statement “natural” on the Product’s labeling. A complete list of Covered Products is attached as Exhibit C to the Settlement Agreement.
The Terms of the Proposed Settlement
These FAQs provide a summary of some, but not all, of the terms of the Settlement Agreement. Click here to see a copy of the entire Settlement Agreement. The Settlement Agreement must be approved by the Court and become “Final” before any benefits are paid.
The Defendant has agreed to establish a Settlement Fund of $9,000,000 to pay Settlement Class Members who make valid, timely claims; pay Class Counsel’s attorneys’ fees of up to one-third (33.333%) of the Settlement Fund; separately pay Class Counsel’s expenses and costs (up to a maximum of $50,000); pay service awards to the Class Representatives up to $40,000 total; and pay costs and expenses of notice and settlement administration (which are estimated to be $475,000). After the Court grants final approval of the Settlement, each Settlement Class Member who submitted a Valid Claim form as described above will receive payment for an amount that shall be calculated based on the Settlement Benefits claimed by you and others. Settlement benefits will be issued via check or a variety of digital payment methods. For more details on how payments are determined and will be made, please visit here to see a copy of the entire Settlement Agreement. No. No money or benefits are available now because the Court has not yet decided whether to approve the Settlement and because it is not yet final. There is no guarantee that money or benefits will ever be distributed.
Your Rights and Options
If you do nothing, you will become a Class Member bound by the terms of the Settlement Agreement and Final Judgment, thus forfeiting your right to sue on your own regarding any claims that are part of the Settlement. If you fail to submit a timely Valid Claim you will forfeit your right to receive your portion of the settlement fund. If you are a Class Member and the Settlement is approved by the Court, you will forfeit your right to all “Released Claims,” defined as “all claims, demands, rights, suits, obligations, debts, liens, contracts, agreements, judgments, expenses, costs, liabilities, causes of action of every nature and description, claims for attorneys’ fees, expenses and costs, losses and remedies and all other legal responsibilities in any form or nature, whether known or unknown, suspected or unsuspected, existing now or arising in the future that is or are based on any act, omission, inadequacy, misstatement, representation, harm, matter, cause, or event that in any way relate to or arise from Dr. Squatch’s use of the term “Natural” on the Products during the Class Period, as alleged, or could have been alleged, in the Action. For sake of clarity, Released Claims do not include claims the Releasing Parties may have, if any, against the Released Parties for personal injury damages or products liability relating to the Products.” Other defined terms are defined in Settlement Agreement available here. If you remain in the Settlement Class, you give up your right to sue in Court or arbitration or be part of any other lawsuit or arbitration against Defendant or its affiliates regarding any issues related to the Released Claims (please see the Settlement Agreement for the claims that will be released). Additionally, all of the Court’s orders will apply to you and legally bind you. You may want to exclude yourself from the Settlement Class if you already have filed (or intend to file) a lawsuit or arbitration against Defendant or its affiliates for the Released Claims and want to continue that lawsuit or arbitration individually, on your own behalf. If you do not exclude yourself, you will be legally bound by all orders of the Court regarding the Settlement Class, the Settlement Agreement, and the Released Claims. All Settlement Class Members who do not ask to be excluded will be forever barred from asserting against Defendant and its affiliates any and all actions, claims, causes of action, proceedings, or rights of any nature and description whatsoever regarding the Released Claims, as more fully described in the Settlement Agreement. Settlement Class Members who request exclusion shall not be entitled to recover any benefits from the Settlement. Settlement Class Members who request exclusion will not receive a check in the mail after the Settlement becomes Final. You may exclude yourself (“Opt-Out”) from the Settlement Class by providing written notice to the Settlement Administrator, Class Counsel and Defendant’s counsel. Opt-Out requests must (a) be signed by the Class Member who is requesting exclusion; and (b) include the full name, address, and phone number(s) of the Class Member requesting exclusion. No Opt-Out request will be valid unless all the information described above is included. The Opt-Out Form must be submitted electronically or postmarked no later than October 13, 2026. If you exclude yourself from the Settlement, you cannot object to the Settlement, and you will not receive any money or other benefits from the Settlement. Yes, but not if you exclude yourself from the Settlement Class. Objecting is simply telling the Court that you do not like something about the Settlement but that you elect to remain in the Settlement Class. To object you must mail an Objection to the Settlement Administrator no later than October 13, 2026. To be effective, any such Objection must include: All objections will be considered at the Final Approval Hearing on March 2, 2027, at 10:00 a.m. Pacific Time. In general, the Court will hear from any Class Member who attends the Final Approval Hearing and asks to speak regarding his or her Objection. If the Settlement is ultimately approved over your Objection, you will receive payment in the amount of your pro rata share of the Settlement Amount less any awarded attorney’s fees, costs of suit and administration costs, after the Settlement’s Effective Date and after the Court grants final approval of the Settlement. You will be bound by the Settlement and give up your right to sue on your own regarding any claims that are part of the Settlement. The deadline to submit your Objection is October 13, 2026. The address for the Settlement Administrator is: Dr. Squatch Settlement Administrator The Court will hold a Final Approval Hearing on March 2, 2027, at 10:00 a.m. Pacific Time in Department 11 of the Superior Court of California, County of Los Angeles, located at 312 N. Spring Street, Los Angeles, California 90012. The date of the Final Approval Hearing may change, so please refer to the Settlement Website to confirm the date and time of the Final Approval Hearing. At the Final Approval Hearing, the Court will consider if: No. Your attendance at the Final Approval Hearing is not required even if you submit a written Objection. However, you or your attorney may attend the hearing at your own expense. Yes, you may speak at the Final Approval Hearing to object to the proposed Settlement. In general, the Court will hear from any Class Member who attends the final approval hearing and asks to speak regarding his or her Objection. If you plan to have your attorney speak for you at the Final Approval Hearing, your Objection must also include your attorney’s name, address, and phone number.
P.O. Box 1389
Baton Rouge, LA 70821
1-855-706-1956
The Lawyers Representing You
Yes. The Court appointed the Law Offices of Todd M. Friedman, P.C. and Reese LLP to represent you and the other Settlement Class Members. They are called “Class Counsel.” More information about this law firm, their practices, and their lawyers is available at http://www.toddflaw.com and http://www.reesellp.com. You do not need to hire your own lawyer because Class Counsel is working on your behalf. However, you may hire an attorney at your own expense who can enter an appearance on your behalf to represent you and speak on your behalf. If the Court approves the Settlement Agreement at the Final Approval Hearing, then Class Counsel will ask the Court for an award of reasonable attorneys’ fees in an amount not to exceed one third of the gross Settlement Amount ($3,000,000.00), plus reasonable costs and expenses of suit, up to a maximum of $50,000. The Law Offices of Todd M. Friedman and Reese LLP have agreed to an equal split of the attorney fees on a 50/50 basis. Yes. The Class Representatives in this class action are named Victor Guzman, Perry Bruno, Lauren Fleming, David Plowden, Karen Betzag, and Jaime Napolitano. Class Counsel will request that the Court grant an incentive award of up to $40,000 total for the Class Representatives.
More Information
The Notice summarizes the proposed Settlement. For the precise terms and conditions of the Settlement, please see the Settlement Agreement here. If you have further questions, you may: Dr. Squatch Settlement Administrator Law Offices of Todd M. Friedman, P.C. Adrian R. Bacon, Esq. Reese LLP Michael R. Reese, Esq. PLEASE DO NOT CONTACT THE COURT, DEFENDANT OR DEFENSE COUNSEL REGARDING THIS SETTLEMENT. THEY CANNOT PROVIDE YOU ANY ADVICE.
P.O. Box 1389
Baton Rouge, LA 70821
23586 Calabasas Rd., Suite 105
Calabasas, California 91302
Phone: (323) 306-4234
abacon@toddflaw.com
100 West 93rd Street, 16th Floor
New York, New York 10025
Phone: (212) 643-0500
mreese@reesellp.com