Fuchs, et al. v. SpecialtyCare, Inc.
Class Action Settlement

This notice is to tell you about the settlement of a class action lawsuit, Fuchs, et al. v. SpecialtyCare, Inc. brought on behalf of certain surgical neurophysiologists (“SNs”). You received this notice because you may be a member of the group of people affected, called the “class.” This notice gives you a summary of the terms of the proposed settlement agreement, explains what rights class members have, and helps class members make informed decisions about what action to take.

Read this notice to understand the settlement and to determine if you are a class member. Then, decide if you want to:

Read on to understand the specifics of the settlement and what each choice would mean for you.

Your deadline to object or opt out: November 2, 2026
Settlement approval hearing: December 11, 2026

In 2023, a class action lawsuit was filed against SpecialtyCare. The lawsuit was brought on behalf of SNs who dispute SpecialtyCare’s practice of requiring payment from SNs who leave prior to working three years. The existing claims in the lawsuit allege SpecialtyCare’s conduct constitutes an unlawful restraint of trade under Tennessee law and violates the Truth in Lending Act (“TILA”).

SpecialtyCare denies all allegations of wrongdoing and liability. SpecialtyCare maintains that its practices were lawful and that it has complied with all applicable laws.

The Court has not decided the case on behalf of either side.

In 2026, the parties agreed to settle, which means they have reached an agreement to resolve the lawsuit. Both sides want to avoid the risk and expense of further litigation.

The Court will hold a Fairness hearing to decide whether to approve the settlement. The hearing will be held at:

Where: Fred D. Thompson U.S. Courthouse and Federal Building, 719 Church Street, Courtroom 6B, Nashville, TN 37203.

When: 1:30 p.m. on December 11, 2026.

The Court has directed the parties to send you this notice about the proposed settlement. Because the settlement of a class action decides the rights of all members of the proposed class, the Court must give final approval to the settlement before it can take effect. Payments will only be made and debt relief will only happen if the Court approves the settlement.

You don’t have to attend, but you may at your own expense. You may also ask the Court for permission to speak and express your opinion about the settlement. If the Court does not approve the settlement or the parties decide to end it, it will be void and the lawsuit will continue. The date of the hearing may change without further notice to members of the class. To learn more and confirm the hearing date, go to SpecialtyCareIncSettlement.com

SpecialtyCare has agreed to pay $725,000 into a settlement fund and to not collect any amounts it contends are due or could be due from class members under the Training Repayment Agreement.

The money will be divided among the class members and will also be used to pay for costs and fees approved by the Court, including the cost of administering this settlement. Members of the settlement class will “release” their claims as part of the settlement, which means they cannot sue SpecialtyCare for the same issues in this lawsuit. The full terms of the release can be found here.

You are a part of this settlement and considered a “class member” if you fall within one or both of the following subclasses:

Restraint of Trade Settlement Subclass means all SNs who are or were employed by SpecialtyCare and subject to the training repayment agreement (also known as the Associate Repayment Agreement) at any point from August 23, 2017 to June 10, 2026, excluding (1) any SNs who signed general releases waiving any claims they may have had against SpecialtyCare; (2) SNs who resigned their employment within 30 days; or (3) SNs who qualified for a contractual exception to the repayment obligation as set forth in Paragraph 2 of the Associate Repayment Agreement.

TILA Settlement Subclass means all SNs who are or were employed by SpecialtyCare and subject to the training repayment agreement (also known as the Associate Repayment Agreement) at any point from August 23, 2022 to June 10, 2026, excluding any SNs who signed general releases waiving any claims they may have had against SpecialtyCare.

The settlement provides money to all class members. Additionally, if SpecialtyCare has agreed not to collect any debt it contends class members owe under the Associate Repayment Agreement. This means that if the settlement is approved and you have an outstanding balance with SpecialtyCare, you will not have to pay it. And if, as of June 10, 2026, you were a current employee and if the settlement is approved, you would not have to pay SpecialtyCare if you leave before completing three years of work.

The monetary amounts are expected to range from at least $100 to approximately $10,727 and were determined using the following steps:

For the purpose of these allocations, the amount any settlement class member paid under the Training Repayment Agreement is that amount as of June 10, 2026, whether a settlement class member worked at least three years is based on their status as of June 10, 2026, and current employees’ length of employment is based on their status as of June 10, 2026.

You have three options. This chart shows the effects of each option:

You do not need to do anything to receive a check. If you wish to verify or update your address or request a different method of payment, please contact the Settlement Administrator at claims@ilymgroup.com or (888) 250-6810. If SpecialtyCare contends you have a balance due or if you could have a balance due if you were to leave SpecialtyCare before completing three years of work, you do not have to do anything because SpecialtyCare will not try to collect from you.

In a class action, the court appoints class representatives and lawyers to work on the case and represent the interests of all the class members. For this settlement, the Court has appointed the following individuals and lawyers.

Your lawyers: Anna Prakash and Joshua O’Neill of Nichols Kaster, PLLP, Juno Turner and Rachel Dempsey of Towards Justice, and Bryce Ashby of Donati Law. These are the lawyers who negotiated this settlement on your behalf.

If you want to be represented by your own lawyer, you may hire one at your own expense.

Lawyers' fees and costs will be paid from the settlement fund. You will not have to pay the lawyers directly.

To date, your lawyers have not been paid any money for their work or the expenses that they have paid for the case. To pay for some of their time and risk in bringing this case without any guarantee of payment unless they were successful, your lawyers will request, as part of the final approval of this Settlement, that the Court approve a payment of up to $241,667 total in attorneys’ fees plus up to $206,000 for the reimbursement of out-of-pocket expenses.

Lawyers' fees and expenses will only be awarded if approved by the Court as a fair and reasonable amount. You have the right to object to the lawyers' fees even if you think the settlement terms are fair.

Your lawyers will also ask the Court to approve a payment of $5,000 to each of the Class Representatives for the time and effort they contributed to the case.

And the costs of the Settlement Administrator are expected to be $7,999.99, which the lawyers will request reimbursement for as well.

If approved by the Court, these amounts will be paid from the settlement fund.

You can opt out. If you do, you will not receive payment or debt relief and cannot object to the settlement. However, you will not be bound or affected by anything that happens in this lawsuit and may be able to file your own case. You cannot exclude yourself from the program changes called for by the proposed settlement.

To opt out of the settlement, you must complete the opt out form included with this notice and mail it by November 2, 2026 to the Settlement Administrator at:

Be sure to include your name, address, telephone number, and signature.

If you disagree with any part of the settlement (including the lawyers' fees) but don’t want to opt out, you may object. You must give reasons why you think the Court should not approve it and say whether your objection applies to just you, a part of the class, or the entire class. The Court will consider your views. The Court can only approve or deny the settlement — it cannot change the terms of the settlement. You may, but don’t need to, hire your own lawyer to help you.

To object, you must send a letter to the Court that:

Mail the letter to:

If you do nothing, you will receive settlement benefits, and you will be bound by the settlement and its “release” provisions. That means you won’t be able to start, continue, or be part of any other lawsuit against SpecialtyCare about the issues in this case. A full description of the claims and persons who will be released if this settlement is approved can be found here.