1. Why did I receive the Notice?
2. What is this lawsuit about?
3. What is a class action?
4. Why is there a settlement?
5. What does the settlement provide?
6. How much is my payment and how was it calculated?
7. How do I get my payment?
8. What am I giving up as part of the settlement?
9. What if I do not want to participate in the Settlement?
10. What if I want to object to the Settlement?
11. Do I have a lawyer in the case?
12. When will the Settlement be final and when will I receive my settlement payment?
13. Are there more details about the settlement?
14. How do I get more information?
15. What if my name or address changes before I receive my settlement payment?
California Institute of Technology’s (“Caltech”) and Simplilearn America, Inc.’s (“Simplilearn”) records show that you enrolled in the online education program known as the Caltech Cybersecurity Bootcamp and were a California resident anytime between July 20, 2019, and July 1, 2025, and did not previously receive a full refund for the Bootcamp’s tuition and fees. You may have received the Notice because you are entitled to a Settlement Payment under the proposed Settlement of a class action lawsuit. The Notice explains the lawsuit, the Settlement, and your rights and options. This is not a lawsuit against you, and you are not being sued.
The Court supervising this case is the Superior Court of California, San Francisco County. The case is known as Lopez v. California Institute of Technology, et al., Case No. CGC-23-607810. The individual who sued is called the Plaintiff and the entities they sued, Caltech and Simplilearn, are called the Defendants.
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The lawsuit claims that Defendants deceptively advertised the Caltech Cybersecurity Bootcamp by failing to accurately disclose the full extent of Simplilearn’s (and previously, Fullstack Academy’s) involvement in the Bootcamp and by overstating Caltech’s involvement. The lawsuit alleges that Defendants have violated the False Advertising Law, Cal. Bus. & Prof. Code §17500 et seq., the Consumers Legal Remedies Act, Cal. Civil Code §1770 et seq., and the Unfair Competition Law, Bus. & Profs. Code §17200 et seq. Defendants deny Plaintiff’s allegations and contend that Simplilearn’s and Fullstack Academy’s involvement was disclosed. The Court has not decided on the merits of the case.
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Plaintiff asserts the above claims as a class action under California law. A class action allows one individual plaintiff to represent a group of similarly situated people with similar claims against a defendant in a single case. The decisions to let a class proceed as a class action and to approve a class action settlement are made by the Court. Here, the Court has preliminarily determined that for settlement purposes Plaintiff’s claims are suitable to proceed as a class action and that, preliminarily, the settlement is fair, reasonable, and adequate such that this Notice of the Settlement should be sent to class members like you.
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The Court did not decide in favor of Plaintiff or Defendants. The Parties agreed to the Settlement to avoid further disputes and the risk, expense, and inconvenience of litigation.
On October 29, 2025, the Court granted preliminary approval of the proposed Settlement. The Court will decide whether to give final approval to the proposed settlement in a hearing scheduled for June 1, 2026 (“Final Approval Hearing”). See Section 12 below for details.
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The proposed Settlement includes money and required business practice changes to resolve the claims for the Class.
Money
The Settlement money to be provided to the Class is Four Hundred Thousand Dollars ($400,000.00) (“Class Settlement Amount”). If the Court approves, the following items will be paid from the Class Settlement Amount before distribution of the funds to Class Members: up to $13,000.00 in costs of independent settlement administration (e.g., this notice, contact tracing, check distribution, etc.) and a service award of up to $4,500 to Plaintiff Elva Lopez in recognition of the time, effort, and risks this individual Plaintiff took to come forward and prosecute the case. The amount left in the Class Settlement Amount after the payment of those items (“the Net Settlement Fund”) will be approximately $382,500.00 and will be allocated to Class Members as set forth in Section 6.
The Settlement money to be provided to Class Counsel, who represented Plaintiff and the proposed class in prosecuting this case, is Three Hundred Twenty-Five Thousand Dollars ($325,000.00) (“Attorneys’ Fees Amount”). This amount, which is partial reimbursement for litigation expenses and time that Class Counsel incurred in litigating this case, is separate and independent from the $400,000.00 Class Settlement Amount and is subject to Court approval.
The Court will determine the propriety of all payments allocated from the Settlement at final settlement approval. No money will revert to Defendants. Any amount that is not approved by the Court will be returned to the Net Class Settlement Fund to be distributed to Class Members.
Required Business Practice Changes
To the extent that Defendants continue to collaborate to present the Caltech Cybersecurity Bootcamp, the Settlement requires that, among other things, the Caltech Center for Technology and Management Education (“CTME”) will review and approve in advance the curriculum and instructors for the Bootcamp and that Defendants’ websites and advertisements concerning the Bootcamp will include an accurate and prominent description of Caltech’s and Simplilearn’s respective roles in the Bootcamp. A full list of the required practices can be found in Section IX of the Settlement Agreement.
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Individual Settlement Payments will be allocated to each Class Member based on an objective formula approved by the Court. The purpose of the formula is to account for differences in the tuition charged to different Class Members. Under the formula, the Net Class Settlement Fund will be allocated to Class Members in proportion to the tuition that each Class Member paid. It is estimated that you are entitled to receive an estimated Individual Settlement Payment of the amount set forth in the notice you received.
This number is based on data and documents provided by Defendants and the allocation formula approved by the Court, and thus the calculation of this amount is not subject to challenge by you. The amount of your actual Individual Settlement Payment may vary slightly from this estimate based on several factors, including the number of Class Members who opt out and the amount of fees and costs approved by the Court. All Class Members will receive an Individual Settlement Payment unless they opt out.
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To receive proceeds from the Settlement, you do not have to do anything in response to the Notice. If you do nothing in response to the Notice, you will receive your payment automatically.
The Settlement Administrator requests that you complete an IRS Form W-9 to satisfy IRS tax reporting obligations related to the payment and avoid backup tax withholding. You may complete the Form W-9 that was included with the Notice, or download the Form W-9 here, and return it by mail or email to the Settlement Administrator at the information listed in Section 10. Completing the Form W-9 now will ensure that you receive your full payment as soon as possible. If you do not submit a Form W-9 to the Settlement Administrator, you will receive an individual settlement amount that is subject to standard tax withholdings.
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In exchange for receiving a payment under the settlement, you will not be able to sue, continue to sue, or be part of any other lawsuit against Caltech or Simplilearn for claims that are reasonably related to any matter or fact set forth or referred to in this lawsuit (unless you exclude yourself from the Settlement). The exact language of the release is as follows:
All Participating Class Members who do not timely opt out will fully release and forever discharge Defendants and the Released Parties from any and all claims, both potential and actual, that could have been alleged by reason of or in connection with or that are reasonably related to any matter or fact set forth or referred to in the Action. The released claims include but are not limited to claims under False Advertising Law, Business and Professions Code §17500 et seq., Consumers Legal Remedies Act, Civil Code §1770 et seq., Unfair Competition Law Business and Professions Code §17200 et seq., and unjust enrichment.
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If you do not want to participate in the Settlement and wish to retain your right to pursue your own independent action, you must return or electronically submit an Opt-out Request by January 29, 2026. An Opt-out Request means a written and signed request (e.g., letter) submitted by a Settlement Class Member to be excluded from the Settlement or electronic Opt-out Request using your Unique ID and PIN (listed on the notice you may have received).
If you desire to exclude yourself from the settlement and wish to submit your Opt-out Request by U.S. Mail, the Opt-out Request must: (a) be signed by the Class Member; (b) contain the full name, address, and telephone number; (c) clearly state that the Class Member does not wish to be included in the Settlement; and (d) be returned by mail to the Settlement Administrator at the following address, postmarked on or before January 29, 2026:
CTME Boot Camp Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Alternatively, if you desire to exclude yourself from the settlement and wish to submit your Opt-out Request electronically, you can do so here. You will need your Unique Class Member ID and PIN from the first page of the Notice you received to submit your opt out request electronically. Other than the written signature and postmark, the substance of the Opt-out Request submitted electronically is the same as that set out above for submitting an Opt-out Request by U.S. Mail. You can submit your Opt-Out Request electronically through the following link.
The date of the postmark on the return mailing envelope or the date of the electronic submission of the Opt-out Request will be the exclusive means to determine whether an Opt-out Request has been timely submitted.
If you ask to be excluded, you will not get any Settlement payment, and you cannot object to the Settlement. You will not be bound by anything that happens in this lawsuit. A Class Member who does not request to opt out from the Settlement will remain a Class Member and will be bound by all terms of the Agreement if the Settlement is granted Final Approval by the Court.
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If you do not request exclusion from the Settlement but believe the proposed Settlement is unfair or inadequate in any respect, you may object to the Settlement. The deadline to object to the Settlement in writing is January 29, 2026.
If you want to object to the settlement and wish to submit your objection by U.S. Mail, the objection must provide: (a) the objector’s full name, signature, address, and telephone number; (b) a written statement of all grounds for the objection accompanied by any legal support for such objection (if any); (c) copies of any papers, briefs, or other documents upon which the objection is based (if any); and (d) be returned by mail to the Settlement Administrator at the following address, postmarked on or before January 29, 2026.
CTME Boot Camp Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
Alternatively, if you want to object to the settlement and wish to submit your objection electronically, you can do so here. You will need your Unique Class Member ID and PIN from the first page of the Notice you received to submit your objection electronically. Other than the written signature and postmark, the requirements to submit an objection electronically are the same as that set out above for submitting an objection by U.S. Mail. You can submit your objection electronically through the following link.
You may also appear at the Final Approval Hearing and object to the settlement orally without having filed a written objection. See Section 12 for the time and date of the hearing.
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The Court has preliminarily determined for settlement purposes that the lawyers at the law firm of Altshuler Berzon LLP and the National Student Legal Defense Network are qualified to represent you and all individuals covered by this Settlement. These lawyers are called “Class Counsel.” Class Counsel’s contact information is below in Section 14.
You will not be separately charged for these attorneys. Class Counsel will ask the Court to approve and award the Attorneys’ Fees Amount of $325,000.00 as partial reimbursement for the time and litigation expenses that Class Counsel incurred in litigating this case.
You do not need to retain your own attorney to participate in this Settlement. However, you may consult with any attorney you choose at your own expense.
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If the Court grants Final Approval of the settlement, and you did not request exclusion from the settlement, your Individual Settlement Payment will be mailed to you within 45 days of the Effective Date.
The Court will hold a Final Approval Hearing on the fairness and adequacy of the proposed Settlement, the plan of distribution, Class Counsel’s request for attorneys’ fees and costs, the service payment to each Named Plaintiff, and the Settlement Administrator’s expenses on June 1, 2026, at 10:00 a.m. in Department 304 of the Superior Court of California, County of San Francisco, 400 McAllister Street, San Francisco, CA, 94102. You are not required to appear at the hearing to participate in or to opt-out of the Settlement.
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This website summarizes the proposed settlement. More details are in the Settlement Agreement. You are encouraged to read it. To the extent there is any inconsistency between the website, the Notice and the Settlement Agreement, the provisions in the Settlement Agreement control. You may obtain a copy of the Settlement Agreement by contacting Class Counsel (see contact information below in Section 14).
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If you have other questions about the settlement, including about the timing of payments, to update your contact information, or for general information, you should contact the Settlement Administrator at:
CTME Boot Camp Settlement Administrator
P.O. Box 25226
Santa Ana, CA 92799
(833) 417-4953
info@CTMEBootCampSettlement.com
If you have other questions, you can also contact Class Counsel. These are the lawyers acting as Class Counsel, one of whom will respond to your questions:
Eve Cervantez | Eric Rothschild |
Please do not call or write the court about this website or the Notice.
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If, for future reference and mailings from the Court or the Parties, you wish to change the name or address listed on the envelope in which the Notice was first mailed to you, then you must advise the Settlement Administrator of the necessary changes. You have two options. You may mail notice of your change of address to the Settlement Administrator at CTME Boot Camp Settlement Administrator, P.O. Box 25226, Santa Ana, CA 92799 or you can complete the Change of Name and/or Address Information Form on the Settlement Website at this link.
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