Frequently Asked Questions

  1. Why did I get a Notice?

    The Court directed that the Notice be mailed to you because you or someone in your family or an investment account for which you serve as a custodian may have purchased or otherwise acquired HIIQ common stock during the period from September 25, 2017 through April 11, 2019, inclusive. The Court has directed us to send you the Notice because, as a potential Class Member or Settlement Class Member, you have a right to know about your options before the Court rules on the proposed Settlement.

    A copy of the Notice can be found here.

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  2. Is this the same Settlement as HIIQ Securities Litigation?

    No. HIIQ Securities Litigation is also known as “In Re Health Insurance Innovations Securities Litigation, Case No. 8:17-cv-02186 TPB-SPF” is a different settlement. While the primary defendant is the same, this is a separate and distinct matter. If your intent was to inquire about the HIIQ Securities Litigation, you may visit www.HIIQSecuritiesLitigation.com or call the Claims Administrator at 1-855-914-4697.

  3. What is this case about?

    The Complaint alleges, among other things, that Defendants made allegedly false and misleading statements or omissions claiming HIIQ had “best-in-class” and “market leading” compliance; and made allegedly false and misleading statements or omissions about the purportedly “incredibly low” number of customer complaints upheld by state departments of insurance.

    The Complaint further alleges that HIIQ’s stock price was artificially inflated as a result of Defendants’ alleged false and misleading statements, and that HIIQ’s stock price declined when the truth regarding Defendants’ alleged misrepresentations was revealed.

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  4. Who is included in the Settlement Class? Are there exceptions to being included in the Settlement Class?

    If you are a member of the Class or Settlement Class, you are subject to the Settlement, unless you timely request to be excluded.

    As set forth in the Notice the Class consists of:

    All persons or entities that purchased or otherwise acquired HIIQ common stock between September 25, 2017 and February 18, 2019, inclusive, and who were damaged thereby.

    As set forth in the Notice, the Settlement Class consists of:

    All persons or entities that purchased or otherwise acquired HIIQ common stock between September 25, 2017 and April 11, 2019, inclusive, and who were damaged thereby.

    Excluded from both the Class and Settlement Class are Defendants, the officers and directors of HIIQ, members of their immediate families and their legal representatives, heirs, agents, affiliates, successors or assigns, Defendants’ liability insurance carriers, and any affiliates or subsidiaries thereof, and any entity in which Defendants or their immediate families have or had a controlling interest. Also excluded are any persons and entities who or which exclude themselves by submitting a timely and valid request for exclusion that is accepted by the Court.

    If you are still not sure whether you are included, you can call 1-855-914-4697 for more information.

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  5. What are Lead Plaintiff’s reasons for the Settlement?

    Lead Plaintiffs and Co-Lead Counsel believe that the claims asserted against Defendants have merit. They recognize, however, the expense and length of continued proceedings necessary to pursue their claims against Defendants through further motion practice, trial and appeals, as well as the very substantial risks they would face in establishing liability and damages.

    In light of these risks, the amount of the Settlement and the immediacy of recovery to the Class and Settlement Class, Lead Plaintiffs and Lead Counsel believe that the proposed Settlement is fair, reasonable and adequate, and in the best interests of the Class and Settlement Class. Lead Plaintiffs and Lead Counsel believe that the Settlement provides a substantial benefit to the Class and Settlement Class, namely $11,000,000 in cash (less the various deductions described in the Notice), as compared to the risk that the claims in the Action would produce a smaller or no recovery after summary judgment, trial and appeals, possibly years in the future.

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  6. What might happen if there were no Settlement?

    If there were no Settlement and Lead Plaintiffs failed to establish any essential legal or factual element of their claims against Defendants, neither Lead Plaintiffs nor the other members of the Class or Settlement Class would recover anything from Defendants. Also, if Defendants were successful in proving any of their defenses, either at summary judgment, at trial or on appeal, the Class and/or the Settlement Class could recover substantially less than the amount provided in the Settlement, or nothing at all.

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  7. How are the Settlement Class Members Affected by the Action and the Settlement?

    As a Class Member or Settlement Class Member, you are represented by Lead Plaintiffs and Lead Counsel, unless you enter an appearance through counsel of your own choice at your own expense. You are not required to retain your own counsel, but if you choose to do so, such counsel must file a notice of appearance on your behalf and must serve copies of his or her appearance to the attorneys for this matter

    If you are a Class Member or Settlement Class Member and do not wish to remain a a Class Member or Settlement Class Member, you may exclude yourself from the Class or the Settlement Class by following the instructions in FAQ 11.

    If you are a Class Member or Settlement Class Member and you wish to object to the Settlement, the Plan of Allocation, or Lead Counsel’s application for attorneys’ fees and reimbursement of Litigation Expenses, and if you do not exclude yourself from the Class or Settlement Class, you may present your objections by following the instructions listed in FAQ 12.

    If you are a Class Member or Settlement Class Member and you do not exclude yourself from the Class or the Settlement Class, you will be bound by any orders issued by the Court. If the Settlement is approved, the Court will enter a judgment (the “Judgment”). The Judgment will dismiss with prejudice the claims against the Defendants.

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  8. How do I participate in the Settlement?

    To be potentially eligible for a payment from the proceeds of the Settlement, you must be a member of the Class or the Settlement Class, and you must timely complete and return the Claim Form with adequate supporting documentation. The Claim Form and documentation can be submitted by mail or online here. The Claim Form must be postmarked or submitted online no later than May 11, 2021.

    A Claim Form is included with the Notice, downloadable here, or you may request that a Claim Form be mailed to you from the Claims Administrator by calling 1-855-914-4697 (Toll-Free).

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  9. How much will my payment be?

    At this time, it is not possible to make any determination as to how much any individual Class Member or Settlement Class Member may receive from the Settlement.

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  10. How will the attorneys be paid?

    Plaintiffs’ Counsel have not received any payment for their services in pursuing claims against the Defendants, nor have Plaintiffs’ Counsel been reimbursed for their out-of-pocket expenses. Before final approval of the Settlement, Lead Counsel will apply to the Court for an award of attorneys’ fees for all Plaintiffs’ Counsel in an amount not to exceed one-third (33–1/3%) of the Settlement Fund. At the same time, Lead Counsel also intends to apply for reimbursement of Litigation Expenses in an amount not to exceed $450,000.00, which may include an application for reimbursement of the reasonable lost wages, costs and expenses incurred by Lead Plaintiffs directly related to their prosecution of this Action. The Court will determine the amount of any award of attorneys’ fees or reimbursement of Litigation Expenses. Such sums as may be approved by the Court will be paid from the Settlement Fund. Class Members are not personally liable for any such fees or expenses.

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  11. How do I exclude myself?

    Each Class Member and Settlement Class Member will be bound by all determinations and judgments in this lawsuit, whether favorable or unfavorable, unless such person or entity mails or delivers a written request for exclusion addressed to:

    Health Insurance Innovations Securities Settlement, Exclusion
    c/o Claims Administrator
    P.O. Box 5657
    Portland, OR 97228-5657

    The request for exclusion must be received no later than March 2, 2021. You will not be able to exclude yourself from the Class or the Settlement Class after that date.

    Each request for exclusion must include:

    1. your name, address, and telephone number;
    2. the date(s), price(s), and number(s) of shares of all your purchases, sales and other dispositions of HIIQ common stock during the Settlement Class Period;
    3. a statement that such person or entity “requests exclusion from the Class and/or Settlement Class in Keippel v. Health Insurance Innovations, Inc. n/k/a Benefytt Technologies, Inc., et al., 8:19-CV-00421-WFJ-CPT”; and
    4. your signature.

    A request for exclusion shall not be effective unless it provides all the information mentioned above and is received no later than March 2, 2021 or is otherwise accepted by the Court.

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  12. How do I object to the Settlement?

    Any Class Member or Settlement Class Member who or which does not request exclusion may object to the Settlement, the proposed Plan of Allocation or Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses. Objections must be in writing. You must also serve the papers on the Lead Counsel representatives and on the Defendants’ Counsel representative at the addresses set forth below so that the papers are received on or before March 2, 2021.

    Clerk’s Office Lead Counsel Representatives Defendants’ Counsel Representative
    U.S. District Court,
    Middle District of Florida
    No. 8:19-cv-00421
    Sam Gibbons United States Courthouse
    801 N. Florida Ave.
    Tampa, FL 33602
    Brandon T. Grzandziel
    Adam D. Warden
    Saxena White P.A.
    7777 Glades Road
    Suite 300
    Boca Raton, FL 33434
    Michael Matthews
    Lauren Valiente
    Foley & Lardner LLP
    100 North Tampa Street
    Suite 2700
    Tampa, FL 33602-5810

    Any objection must:

    1. state the name, address, and telephone number of the person or entity objecting;
    2. contain a statement of the objection or objections, and the specific reasons for each objection, including any legal and evidentiary support the Class Member or Settlement Class Member wishes to bring to the Court’s attention;
    3. include documents sufficient to prove membership in the Class or Settlement Class, including the number of HIIQ shares that the objecting Class Member or Settlement Class Member purchased/acquired and/or sold during the Class Period or Settlement Class Period, as well as the dates and prices of each such purchase/acquisition and sale, and the number of HIIQ shares held at the beginning of the Class Period or Settlement Class Period; and
    4. be signed by the objector;

    You may not object to the Settlement, the Plan of Allocation or Lead Counsel’s motion for attorneys’ fees and reimbursement of Litigation Expenses if you exclude yourself from the Class or Settlement Class or if you are not a member of the Class or Settlement Class.

    You may file a written objection without having to appear at the Settlement Hearing. You may not, however, appear at the Settlement Hearing to present your objection unless you first file and serve a written objection in accordance with the procedures described above, unless the Court orders otherwise.

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  13. When and where will the Court decide to approve the Settlement?

    Class Members or Settlement Class Members do not need to attend the Settlement Hearing. The Court will consider any submission made in accordance with the provisions in the Notice even if a Class Member or Settlement Class Member does not attend the hearing. You can participate in the Settlement without attending the Settlement Hearing.

    The Settlement Hearing will be held on March 23, 2021, at 9:30 a.m ET., by telephonic means by calling the reserved conference toll-free number at 1-888-557-8511, then entering the access code: 4744914, followed by the # (pound) key, then entering the security code: 0421, followed by the # (pound) key.

    The Court reserves the right to approve the Settlement, the Plan of Allocation, Lead Counsel’s motion for an award of attorneys’ fees and reimbursement of Litigation Expenses and/or any other matter related to the Settlement at or after the Settlement Hearing without further notice to the members of the Class or Settlement Class. Please check this website for updates.

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  14. What if I bought HIIQ common stock on someone else’s behalf?

    If you purchased or otherwise acquired HIIQ common stock during the Class Period or Settlement Class Period for the beneficial interest of persons or organizations other than yourself, please visit the Nominees page.

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  15. Whom should I contact if I have questions?

    If you have questions about the Settlement, please contact the Claims Administrator at:

    Health Insurance Innovations Securities Settlement
    c/o Claims Administrator
    P.O. Box 5657
    Portland, OR 97228-5657
    phoneIcon 855-914-4697
    emailIcon info@HealthInsuranceInnovationsSecuritiesSettlement.com

    DO NOT CALL OR WRITE THE COURT, THE OFFICE OF THE CLERK OF THE COURT, DEFENDANTS, OR THEIR COUNSEL REGARDING THIS WEBSITE OR THE NOTICE.

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  16. What is the ticker and CUSIP for the relevant security?

    The CUSIP for HIIQ during the Class Period and Settlement Class Period was 42225K106. The ticker symbol from September 25, 2017 through April 11, 2019, inclusive, was HIIQ

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