Tan v. Quick Box, LLC

If you were billed for La Pura Products between June 12, 2016 and October 10, 2024, you are a member of a Settlement Class.

This website and the Notice explain the class action lawsuit, the proposed Settlement, your legal rights, what benefits are available, who is eligible for the benefits, and how to get the benefits.

The Court in charge of this case is the United States District Court for the Southern District of California. The lawsuit is known as Tan v. Quick Box, LLC, Case No. 3:20-cv-01082-LL-DDL. You may obtain additional updates on the status of the case by contacting Class Counsel (listed in FAQ 11), checking back to this website for updates, or viewing case information through the Court’s system at www.Pacer.gov.

This lawsuit is about whether La Pura Products were marketed in a false or misleading way. “La Pura Products” is a defined term under the Settlement Agreement, meaning “any product manufactured, marketed, sold, or otherwise promoted under the La Pura brand name or any variation thereof, including (but not limited to) La’Pura and LaPura.” The suit alleges that Konnektive Defendants supplied computer systems used to assist in selling La Pura Products.

Plaintiffs have reached this Settlement with the Konnektive Defendants and a prior settlement with the Quick Box Defendants. Recently, you may have received notice of the Quick Box Settlement.

Plaintiffs’ lawsuit is still ongoing against other Defendants. If applicable, you may receive a separate notice regarding the progress of the lawsuit and any resolution of legal claims against the other Defendants.

The Konnektive Defendants deny that they did anything wrong. This Settlement is not an admission of any liability. The Court has not decided who is right.

In a class action lawsuit, one or more people called “Class Representatives” sue on behalf of other people who have similar claims. The people together are a “Class” or “Class Members.” The people who sue – and all the Class Members like them – are called the “Plaintiffs.” The compaies the Plaintiffs are called the “Defendants.” One court resolves the issues for everyone in the Class – except for those people who choose to exclude themselves from the Class. U.S. District Judge Linda Lopez is in charge of this class action.

The Court did not decide in favor of Plaintiffs or the Konnektive Defendants. Instead, both sides agreed to a settlement. By agreeing to settle, both sides avoid the cost and risk of a full trial and guarantee some amount of money will be paid to the class. Therefore, people who submit valid claims will get compensation. The Class Representative and their attorneys believe the Settlement is best for the Settlement Class and its members.

You are a Class Member if you are a consumer in the United States and were billed for products advertised, marketed, offered for sale, sold, shipped, or caused to be sold or shipped under the La Pura La’Pura, LaPura brand names or any similar brand name, including any La Pura Product advertised, marketed, offered for sale, sold, shipped, or caused to be advertised, marketed, offered for sale, sold or shipped, by the La Pura and Rocket Management Group Parties between June 12, 2016 and October 10, 2024.

Excluded from the Settlement are:

1. jurists and mediators who are or have presided over the Action, Plaintiff’s Counsel and Defendants’ Counsel, their employees, legal representatives, heirs, successors, assigns, or any members of their immediate family;
2. any government entity;
3. the Konnektive Parties and any entity in which the Konnektive Parties have a controlling interest, any of their subsidiaries, parents, affiliates, and officers, directors, employees, legal representatives, heirs, successors, or assigns, or any members of their immediate family; and
4. any persons who timely opt out of the Settlement Class.

The Settlement Fund will provide Monetary Payments to Class Members who submit valid claims. Class notice and claim administration expenses, Plaintiffs’ Counsel’s attorneys’ fees and expenses and any service award to the Class Representative (discussed below) will also be paid out of the Settlement Fund, if approved by the Court. The settlement distribution process will be administered by an independent Settlement Administrator approved by the Court.

If you file a Pre-Populated Claim Form, you will be provided a Monetary Payment based on your purchases of La Pura Products as reflected in purchase records. Regardless of whether you file or filed a Claim Form for the Quick Box Settlement, you must file a separate Claim Form to receive a Monetary Payment from this Settlement with the Konnektive Defendants. The Monetary Payment is subject to the ultimate amount the Konnektive Defendants pay to the Settlement Fund and is subject to a pro rata increase or decrease depending upon the amount remaining in the Net Fund after all eligible Claims are determined.

Based on the applicable purchase records, the Settlement Administrator will determine and notify Class Members of the Monetary Payment Class Members can receive via this Settlement Agreement.

Any money remaining in the Settlement Fund after payment of settlement notice and administration, attorneys’ fees and costs (FAQ 12), and Class Representative service awards (FAQ 12) ordered by the Court, and valid Class Member Claims, will be paid pursuant to the cy pres doctrine to the National Consumer Law Center.

If you are a Class Member, you must fill out and submit a Claim Form to qualify for a Monetary Payment. You can easily file your Claim online here. The completed Claim Form must be submitted online by May 27, 2025, or by mail at the address below, received by May 27, 2025.

Tan v. Konnektive
Settlement Administrator
P.O. Box 2449
Portland, OR 97208-2449

Regardless of whether you file or filed a Claim Form for the Quick Box Settlement, you must file a separate Claim Form to receive a Monetary Payment from this Settlement with the Konnektive Defendants.

Upon receiving a completed claim form, the Settlement Administrator will review the documentation and confirm or deny your eligibility for an award.

The Court will hold a hearing on February 6, 2025 (which is subject to change), to decide whether to approve the Settlement with the Konnektive Defendants. Even if the Court approves the Settlement, there may be appeals. The appeal process can take time, perhaps more than a year. You will not receive your Monetary Payment until any appeals are resolved. Please be patient.

Unless you exclude yourself (“opt out”) from the Settlement Class by timely submitting an Exclusion Request (see 13-14), you will remain in the Settlement Class. By remaining in the Settlement Class you “release” and can’t sue, continue to sue, or be part of any other lawsuit against the Konnektive Defendants about the “Released Claims” in this case. These Released Claims are only those claims that you could have brought based on the identical factual predicate of those claims brought in this case about the alleged misleading marketing and labeling of La Pura Products between June 12, 2016 and October 10, 2024.

You are not releasing your legal claims against any Defendant other than the Konnektive Defendants as part of this Settlement by staying in the Settlement Class.

The Settlement Agreement at Section VIII (titled “Releases”) describes these “Released Claims” and the “Released Parties” in necessary legal terminology, so read these sections carefully. The Settlement Agreement is available on this website here, or in the public court records on file in this lawsuit. For questions regarding the Releases or what they mean, you can also talk to one of the lawyers listed in FAQ 11 below for free, or you can, talk to your own lawyer at your own expense.

The Court has appointed attorneys from the law firm Kneupper & Covey, PC of Huntington Beach, CA, to represent you and the other 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 the Notice or the Settlement. Please do not contact the Court.

Class Counsel:
Kevin Kneupper
Cyclone Covey
KNEUPPER & COVEY, PC
17011 Beach Blvd., Ste. 900
Huntington Beach, CA 92647-5998
Tel: 512-420-8407512-420-8407
Email: cyclone@kneuppercovey.com
Website: www.kneuppercovey.com

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Class Counsel will ask the Court for an award of attorneys’ fees of 1/3 of the ultimate Settlement Fund (either $666,666.66 or $1,666,666.66 depending on the final amount the Konnektive Defendants are to pay) and for reimbursement of expenses (approximately $180,000). Any award of attorneys’ fees and costs will be paid from the Settlement Fund. Class Counsel will also ask the Court for a service award for the Class Representative. The purpose of the service award is to compensate the Plaintiff for her time, efforts and risks taken on behalf of the Settlement Class. Any award of payment to the Class Representative will be paid from the Settlement Fund.

If you don’t want a Monetary Payment, but want to keep the right to sue or continue to sue the Quick Box Defendants on your own, on the basis of the legal issues in this case, then you must take steps to exclude yourself from the Settlement (get out of the Settlement). This is called “excluding yourself”—or is sometimes referred to as “opting out” of the Settlement Class.

To exclude yourself from the Settlement, you must send a “Request for Exclusion” in the form of a letter or Request for Exclusion form stating that you want to be excluded from the Konnektive Settlement in Tan v. Quick Box LLC, Case No. 3:20-cv-01082-LL-DDL. Be sure to include your name, address, telephone number, and basis upon which you are a Class Member. You must mail your Request for Exclusion received by January 23, 2025 to: Tan v. Konnektive Settlement Administrator, P.O. Box 5439, Portland, OR 97228-5439. Request for Exclusion forms can be obtained on the Documents section of this website or by clicking here.

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

Regardless of whether you requested exclusion for the Quick Box Settlement, if you do not want to be bound by the Settlement with the Konnektive Defendants, you must request exclusion from this Settlement with the Konnektive Defendants.

Excluding yourself from this Settlement will not affect your rights related to the other Defendants in this lawsuit.

No. If you exclude yourself, you cannot receive Monetary Payments. But, you may sue, continue to sue, or be part of a different lawsuit against the Konnektive Defendants about the legal issues in this case.

Excluding yourself from this Settlement will not affect your rights related to the other Defendants in this lawsuit.

If you’re a Class Member, you can object to the Settlement with the Konnektive Defendants if you don’t like 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 can’t ask the Court to order a different Settlement; the Court can only approve or reject the Settlement. If the Court denies approval, no settlement awards will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

To object, you must send a letter. Be sure to include the following information:

1. The case name and number (Tan v. Quick Box, LLC, Case No. 3:20-cv-01082-LL-DDL);
2. Your name, address, telephone number and, if represented by counsel, the name, address, and telephone number of your counsel;
3. A statement under oath that you are a Class Member;
4. A statement whether you intend to appear at the Final Approval Hearing, either in person or through counsel;
5. A statement of all your objections and the specific grounds supporting your objections;
6. A statement whether the objection applies only to you, to a specific subset of the Settlement Class, or to the entire Settlement Class;
7. Copies of any papers, briefs, or other documents upon which your objection is based; and
8. Your handwritten, dated signature (the signature of your counsel, an electronic signature, and the annotation “/s” or similar annotation will not suffice).

Your objection must be submitted to the Court either by mailing (or by filing it at any location of the United States District Court for the Southern District of California) and served on Class Counsel and Konnektive Defendant’s Counsel received no later than December 23, 2024, to the following addresses:

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

The Court will require substantial compliance with these requirements above. If you do not submit a written objection in accordance with the deadline and procedure set forth above, you will waive your right to be heard at the Final Approval Hearing. However, the Court may excuse your failure to file a written objection upon a showing of good cause, which, if granted, would permit you to still appear at the Final Approval Hearing and object to the Settlement.

Objecting is simply telling the Court that you don’t like something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you don’t want to be part of the Settlement Class. If you exclude yourself, you have no basis to object because you are no longer part of the case.

The Court will hold the Joint Final Approval Hearing via Zoom on June 10, 2025, at 10:30 A.M. PST.

The Zoom Link is as follows:
https://casd-uscourts-gov.zoomgov.com/j/1616446778?pwd=n1vdSbGlasjCQj17iTHbIXc7Kb3dT9.1
Meeting ID: 161 644 6778
Passcode: 2025

Please include your full name and party represented when joining. Please continue to check back to this website for further updates. The Court's Order Setting the Joint Final Approval Hearing Via Zoom can be accessed here.

At the hearing, the Court will hear any comments, objections, and arguments concerning the fairness of the proposed Konnektive Settlement, including the amount requested by Class Counsel for attorneys’ fees and expenses. 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. We do not know how long these decisions will take.

Note: The date and time of the Final Approval Hearing are subject to change by Court Order. Any change will be posted on this website. You should check this website or the Court’s PACER website to confirm that the date and/or time have not changed.

No. Class Counsel will answer all questions Judge Lopez 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.

As long as you do not exclude yourself, you can (but do not have to) participate and speak for yourself in this lawsuit and 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 want to appear, or if you want your own lawyer instead of Class Counsel to speak for you in this lawsuit, you must send a letter saying that it is your “Notice of Intention to Appear in Tan v. Quick Box, LLC.” Be sure to include your name, address, telephone number, and your signature. Your Notice of Intention to Appear must be received by January 30, 2025, and be sent to the Clerk of Court at the address listed in FAQ 15.

If you want to speak at the Final Approval Hearing without having followed these procedures, you may do so if you demonstrate good cause to the Court.

If you do nothing, you’ll be part of the Settlement Class, but get no Monetary Payment from the Konnektive Settlement. Unless you exclude yourself, you will not be permitted to continue to assert Released Claims in any other lawsuit against the Konnektive Defendants about the legal issues in this case, ever again.

If you filed a timely and valid Claim Form for the Quick Box Settlement, you may receive a Monetary Payment under that Settlement if approved by the Court.

If you do nothing for the Konnektive Settlement, your rights related to the other Defendants in this lawsuit will not be affected.

The Notice and this website summarize the proposed Settlement. More details are in the Settlement Agreement. You can get a copy of the Settlement Agreement here, or by contacting Class Counsel by email or telephone at the address or number listed in response to FAQ 11.

You can call toll-free 1-877-658-02931-877-658-0293; write to Tan v. Quick Box Settlement Administrator, P.O. Box 2449, Portland, OR 97208-2449; or review this website, where you will find answers to common questions about the Settlement, a Claim Form, motions for approval of the Settlement and Class Counsel’s request for attorneys’ fees and expenses, and other important documents in the case.

You can also access information about this case through the Court’s Public Access to Court Electronic Records (PACER) system. To learn about PACER and register for a PACER account, go to https://www.Pacer.gov/. Once you have a PACER account, you can access and retrieve documents from the Court’s docket for the Action at https://ecf.casd.uscourts.gov/. You can also access and retrieve documents from the Court’s docket by visiting the Clerk’s Office located at United States District Court for the Southern District of California, 221 West Broadway, San Diego, CA 92101, during business hours.

Please do not telephone the Court or the Court’s clerk to inquire about this Settlement or the claim process.