Frequently Asked Questions

Plaintiffs Lauren Dann, Kathryn Cude, and Mary Yoon are former R+F Consultants.  Plaintiff Dann filed this lawsuit on March 1, 2024, and Plaintiffs Cude and Yoon joined the suit in the Amended Complaint filed on June 25, 2025. Additionally, six other Class Members
(Aja Forner, Elizabeth Garcia-Flynn, Marlem Jalomo, Elyzabeth Michael, Catrice Miles, and Amy Somer) (“Other Settling Individuals”), retained counsel prior to the July 5, 2024 mediation and contributed to the resolution of this lawsuit through their efforts supplying documents and information relevant to the claims.

The Action accuses Defendants of violating California labor laws by misclassifying the Consultants as independent contractors, and failing to pay wages, overtime wages, minimum wages, wages due upon termination and reimbursable expenses, and failing to provide meal periods, rest breaks and accurate itemized wage statements. Based on the same claims, Plaintiffs have also asserted a claim for civil penalties under the California Private Attorneys General Act (Labor Code §§ 2698, et seq.) (“PAGA”).

Plaintiffs are represented by attorneys in the Action: Glenn Danas and Kristen Simplicio of Clarkson Law Firm P.C., and Shana Khader of Tycko & Zavareei LLP (“Class Counsel”).

Defendants strongly deny violating any laws or failing to pay any wages and contends they complied with all applicable laws.

So far, the Court has made no determination whether Defendants or Plaintiffs are correct on the merits. In the meantime, Plaintiffs and Defendants hired an experienced, neutral mediator, a retired judge, Hon. Louis Messinger, in an effort to resolve the Action by negotiating an end to the case by agreement (settle the case) rather than continuing the expensive and time-consuming process of litigation. The negotiations were successful. By signing a lengthy written settlement agreement (“Agreement”) and agreeing to jointly ask the Court to enter a judgment ending the Action and enforcing the Agreement, Plaintiffs and Defendants have negotiated a proposed Settlement that is subject to the Court’s Final Approval. Both sides agree the proposed Settlement is a compromise of disputed claims. By agreeing to settle, Defendants do not admit any violations or concede the merit of any claims.

Plaintiffs and Class Counsel strongly believe the Settlement is a good deal for you because they believe that: (1) Defendants have agreed to pay a fair, reasonable and adequate amount considering the strength of the claims and the risks and uncertainties of continued litigation, including the risk of an inability to pay significant penalties or damages award; and (2) Settlement is in the best interests of the Class Members and PAGA Claimants. The Court preliminarily approved the proposed Settlement as fair, reasonable and adequate, authorized this Notice, and scheduled a hearing to determine Final Approval.

1. Defendants Will Pay $8,000,000 as the Maximum Settlement Amount.

Defendants have agreed to deposit the Maximum Settlement Amount into an account controlled by the Administrator of the Settlement in three installments, the last of which shall be paid 365 days from June 20, 2025. Final approval is currently scheduled for October 31, 2025. Assuming the Court grants Final Approval, and final Judgment is entered at the currently scheduled final Approval Hearing, Defendants will complete the funding of the Maximum Settlement by June 20, 2026. The Judgment will be final on the date the Court enters Judgment, or a later date if Participating Class Members object to the proposed Settlement or the Judgment is appealed.

After receipt of the final installment, the Administrator will use the Maximum Settlement Amount to pay the Individual Class Payments, Individual PAGA Payments, Class Representatives’ Service Payments, Other Settling Individuals’ Payments, Class Counsel’s attorney’s fees and expenses, the Administrator’s expenses, and penalties to be paid to the California Labor and Workforce Development Agency (“LWDA”).

1. Court-Approved Deductions from Maximum Settlement. At the Final Approval Hearing, Plaintiffs and/or Class Counsel will ask the Court to approve the following deductions from the Maximum Settlement, the amounts of which will be decided by the Court at the Final Approval Hearing:

                               i.          Up to $ 2,666,666.67 (33.33% of the Maximum Settlement) to Class Counsel for attorneys’ fees as well as additional costs to be supported by declaration for their litigation expenses, up to $30,000. To date, Class Counsel have worked and incurred expenses on the Action without payment.

                             ii.          Up to $15,000 to Lauren Dann; up to $5,000 each to Mary Yoon and Catherine Cude; as a Class Representative Award for filing the Action, working with Class Counsel and representing the Class. Additionally, up to $1,500 each to the six Other Settling Individuals. These Class Representative Awards will be the only monies Plaintiffs and the Other Settling Individuals will receive.

                            iii.          Up to $150,000 to the Administrator for services administering the Settlement.

                           iv.           Up to $500,000 for PAGA Penalties, allocated 75% to the LWDA PAGA Payment and 25% in Individual PAGA Payments to the PAGA Claimants pro-rata based on their PAGA Period Pay Periods.

The remaining amount (“Net Settlement Amount”) shall be distributed to Class Members pro-rata,
as explained below. The exact amount of the Net Settlement Amount will be determined at Final Approval. Based on the above data, it is currently estimated that the Net Settlement Fund will be around $4,500,000,
but the final number may be more or less.

Participating Class Members have the right to object to any of these deductions. The Court will consider all objections.

The amount you receive under the Settlement is determined based on a point system.

After making the above deductions in amounts approved by the Court, the Administrator will distribute the Net Settlement by making Individual Class Payments to Participating Class Members based on each Class Member’s relative number of points. The point system is explained below.

1. Automatic Points

Every Class Member will receive points automatically based on information in R+F’s records, as follows:

1. Supplemental Points

Class Members who elect to complete a Claim Form on the Settlement Website can receive additional points by reporting, under penalty of perjury, information about their time spent and expenses incurred, as follows:

To submit this information, you will need your Unique ID number appearing on the first page of the notice that was sent to you. If you need assistance locating your Unique ID number, you can contact the Settlement Administrator. Section 15 of this Notice has the Administrator’s contact information.

1. Point System Illustrated

Below is an example of how the point system works for a hypothetical Class Member, Connie Consultant. Connie worked as a R+F Consultant for one year (52 weeks), paid the annual fee and a Pulse Pro fee each month, made three purchases from R+F, and six sales to customers.

Connie would automatically be assigned 31.05 points, calculated as follows:

Connie is automatically entitled to receive a pro-rata share of the Net Settlement Fund based on her assigned 31.05 points.

Connie can increase her point value by completing a Claim Form on the Settlement Website.  

Connie completed a Claim Form to report that she spent an average of 3 hours a week on sales efforts, bought a camera to create better Instagram posts, purchased business cards to promote the business, and incurred expenses for home internet and cell phone use. Connie will receive supplemental points as follows:

Thus, by completing a Claim Form, Connie will receive a pro-rata share of the Net Settlement Fund based on a 50.05 point value instead of a 31.05 point value.  

1. Dollar Value of Points

To determine the amount each Class Member shall receive, the Settlement Administrator will total up the total value of all Class Members’ points (including automatic and supplemental points). Each Class Member will receive a share of the Net Settlement Fund based on the relative percentage value of their points.

There are an estimated 43,000 Class Members. Those who were Consultants for only a few months and had few or no sales will receive fewer points than those who were Consultants for several years and had many sales and paid a large amount of fees.  The dollar value of points will not be known until (1) all fees and costs associated with the Settlement have been approved by the Court and deducted from the Maximum Settlement Fund; and (2) all claims have been processed. 

To illustrate using the hypothetical Connie Consultant:

Assuming there are 43,000 Class Members, if the total number of points (automatic + supplemental) for all Class Members is 4,300,000 (average of 100 points per Class Member), Connie’s 50.05 points is .001164 % of the total.
In this scenario, Connie would receive .001552% of the Net Settlement Amount.  If that amount is $4,500,000, Connie will receive $52.38.

If the total number of points for all Class Members is higher and/or the Court approves a lower Net Settlement Amount, Connie will receive less.  If the total number of points for all Class Members is lower and/or the Court approves a higher Net Settlement Amount, Connie will receive more.

California’s Private Attorneys General Act (“PAGA”) authorizes additional penalties for workers who experienced certain violations of the California Labor Code. The Parties have agreed to set aside $500,000 of the $8,000,000 Maximum Settlement Amount for payment of penalties. 75% of the penalties must be paid to California’s Labor and Workforce Development Commission, and the remaining 25% ($125,000) will be distributed to eligible Consultants. To be eligible, you must have been a Consultant between March 1, 2023 and June 20, 2025 (“PAGA Claimants”).

The Administrator will calculate Individual PAGA Payments by (a) dividing $125,000 by the total number of PAGA Registered Periods worked by all PAGA Claimants and multiplying the result by the number of PAGA Registered Periods worked by each individual Aggrieved Employee. The Individual PAGA Payment is in addition to the Individual Settlement Payment described in Section 4.

If you choose to opt out of the Class, you will not receive the Individual Settlement Payment described in Section 4. But because you cannot opt out of the PAGA portion of this Settlement, you will still receive the Individual PAGA Payment.

The number of Class Workweeks you worked during the Class Period and the number of PAGA Pay Periods you worked during the PAGA Period as recorded in Defendants’ records, as well as your history of sales, purchases, and fees paid are stated in the first page of this Notice.  

You have until September 26, 2025 to challenge the number of Registered Weeks and/or Registered PAGA Periods credited to you as well as the other data discussed above. You can submit your challenge by signing and sending a letter to the Administrator via mail, or email at [email protected].

You need to support your challenge by sending copies of pay stubs or other records evidencing your work for Defendants and associated dates. This may include records reflecting the dates of your working relationship with Defendants, such as records showing the date you enrolled, terminated your relationship, or interacted with customers, other Consultants, or the public as a Consultant (such as communications with customers, social media posts, etc.). The Administrator will accept Defendants’ calculation of Registered Weeks and/or Registered PAGA Periods based on Defendants’ records as accurate unless you send copies of records containing contrary information. You should send copies rather than originals because the documents will not be returned to you.
The Administrator will resolve challenges based on your submission and on input from Class Counsel (who will advocate on behalf of Participating Class Members) and Defendants’ Counsel. The Administrator’s decision is final. You can’t appeal or otherwise challenge its final decision.

Participating Class Members assume full responsibility and liability for any taxes owed on their Individual Class Payment.
The Administrator will report Individual Class Payments that exceed $600 on IRS 1099 Forms.

The Administrator will report the Individual PAGA Payments that exceed $600 on IRS 1099 Forms.

Although Plaintiffs and Defendants have agreed to these allocations, neither side is giving you any advice on whether your Payments are taxable or how much you might owe in taxes. You are responsible for paying all taxes (including penalties and interest on back taxes) on any Payments received from the proposed Settlement. You should consult a tax advisor if you have any questions about the tax consequences of the proposed Settlement.

After the Court grants Final Approval and the Settlement Administrator determines each Aggrieved Employee’s and Class Member’s pro rata share, payments will be sent to you.

PAGA Claimants and Class Members can visit the Settlement Website to elect their preferred payment method and/or update their contact information on the Claim Form.

Unless you provide alternative information and instructions, the Settlement Administrator will first send the payment to you via PayPal using the email address you provided to R+F. If you have a PayPal account associated with that email address, funds will be automatically deposited with no further action required from you.

If you do not have a PayPal account, or if your PayPal account is associated with a different email address, you will receive an email with instructions on how to claim your funds.  If you do not respond within 28 days, a check will be prepared and mailed to you.

The front of every check issued for Individual Class Payments and Individual PAGA Payments will show the date when the check expires (the void date). If you don’t cash it by the void date, your check will be automatically cancelled, and the monies will be irrevocably lost to you because they will be paid to a non-profit organization or foundation (“Cy Pres”).

The Proposed Settlement will be Void if the Court denies Final Approval. It is possible the Court will decline to grant Final Approval of the Settlement or decline to enter a Judgment. It is also possible the Court will enter a Judgment that is reversed on appeal. Plaintiffs and Defendants have agreed that, in either case, the Settlement will be void: Defendants will not pay any money and Class Members will not release any claims against Defendants.

The Court has appointed a neutral company, Verita Global LLC (the “Administrator”), to send this Notice, calculate and make payments, and process Class Members’ Requests for Exclusion. The Administrator will also decide Class Member Challenges over Registered Weeks, mail settlement checks and tax forms, and perform other tasks necessary to administer the Settlement. The Administrator’s contact information is contained in the 'Contact Information' tab of this website.

After the Judgment is final and Defendants have fully funded the Maximum Settlement, Participating Class Members will be legally barred from asserting any of the claims released under the Settlement. This means that unless you opted out by validly excluding yourself from the Class Settlement, you cannot sue, continue to sue, or be part of any other lawsuit against Defendants or related entities for wages or business expenses based on the Class Period facts and PAGA penalties based on PAGA Period facts, as alleged in the Action and resolved by this Settlement.

The Participating Class Members will be bound by the following release:

All Settlement Class Members release the Released Parties from all claims that were asserted or could have been asserted in the PAGA notices, the operative complaint, and any future amendments to the operative complaint up through the date a final judgment is issued finally approving the Settlement to the extent such claims arise out of and/or relate to the facts and claims alleged by Plaintiffs in this case.

The PAGA Claimants’ PAGA Release. After the Court’s judgment is final, and Defendants have paid the Maximum Settlement, all PAGA Claimants will be barred from asserting PAGA claims against Defendants, whether or not they exclude themselves from the Settlement. This means that all PAGA Claimants, including those who are Participating Class Members and those who opt out of the Class Settlement, cannot sue, continue to sue, or participate in any other PAGA claim against Defendants or its related entities based on the PAGA Period facts alleged in the Action and resolved by this Settlement.

The PAGA Claimants’ Releases for Participating and Non-Participating Class Members are as follows:

All Participating and Non-Participating Class Members who are PAGA Claimants are deemed to release, on behalf of themselves and their respective former and present representatives, agents, attorneys, heirs, administrators, successors, and assigns, the Released Parties from all claims for PAGA penalties that were alleged, or reasonably could have been alleged, based on the PAGA Period facts stated in the Operative Complaint relating to the employment status and classification and related violations.

You will be treated as a Participating Class Member, participating fully in the Class Settlement, unless you notify the Administrator in writing, not later than September 26, 2025, that you wish to opt out. The easiest way to notify the Administrator is to send a written and signed Request for Exclusion by the September 26, 2025 Response Deadline.

If you choose to opt out, you must submit a written and signed letter with your name, current address, telephone number, and a simple statement that you do not want to participate in the Settlement. The Administrator will exclude you based on any writing communicating your request be excluded. Be sure to personally sign your request, identify that you are writing in regards to the Dann v. Rodan + Fields litigation, and include your identifying information (full name, address, telephone number, and approximate dates of employment for verification purposes). You must make the request yourself. If someone else makes the request for you, it will not be valid. The request must be postmarked by September 26, 2025, or it will be invalid. Section 15 has the Administrator’s contact information.

Class Members who opt out of the Settlement (i.e., Non-Participating Class Members) will not receive Individual Class Payments, but will preserve their rights to personally pursue wage and hour claims against Defendants.

You cannot opt out of the PAGA portion of the Settlement. Class Members who exclude themselves from the Class Settlement
(Non-Participating Class Members) remain eligible for Individual PAGA Payments and are required to give up their right to assert PAGA claims against Defendants based on the PAGA Period facts alleged in the Action.

Only Participating Class Members have the right to object to the Settlement. Before deciding whether to object, you may wish to see what Plaintiffs and Defendants are asking the Court to approve. At least 49 days before the October 31, 2025 Final Approval Hearing, Class Counsel and/or Plaintiffs will file in Court (1) a Motion for Final Approval that includes, among other things, the reasons why the proposed Settlement is fair, and (2) a Motion for Fees, Litigation Expenses and Service Award stating (i) the amount Class Counsel is requesting for attorneys’ fees and litigation expenses; and (ii) the amount Plaintiffs are requesting as a Class Representative Service Award. Upon reasonable request, Class Counsel (whose contact information is in Section 15 of this Notice) will send you copies of these documents at no cost to you. You can also view them on the Case Documents tab of this website.

A Participating Class Member who disagrees with any aspect of the Agreement, the Motion for Final Approval and/or Motion for Fees, Litigation Expenses and Service Award may wish to object, for example, that the proposed Settlement is unfair, or that the amounts requested by Class Counsel or Plaintiffs are too high or too low. The deadline for filing written objections with the Clerk of the Court and providing a copy to the Administrator is September 26, 2025. Be sure to tell the Administrator what you object to, why you object, and any facts that support your objection. Make sure you identify the Action, Dann v. The Rodan + Fields Company, et al. Case No. CGC-24-612800, and include your name, current address, telephone number, approximate dates of your role as a Consultant for R+F, and sign the objection. Section 15 of this Notice has the Administrator’s contact information.

Alternatively, a Participating Class Member can object (or personally retain a lawyer to object at your own cost) by attending the Final Approval Hearing. You (or your attorney) should be ready to tell the Court what you object to, why you object, and any facts that support your objection. See Section 14 of this Notice (immediately below) for specifics regarding the Final Approval Hearing.

You can, but don’t have to, attend the Final Approval Hearing on October 31, 2025 at 2:30 p.m. in Department 606 of the San Francisco Superior Court, located at 400 McAllister Street, San Francisco, CA 94102. At the Hearing, the judge will decide whether to grant Final Approval of the Settlement and how much of the Maximum Settlement will be paid to Class Counsel, Plaintiffs, and the Administrator. The Court will invite comment from objectors, Class Counsel and Defense Counsel before making a decision.
You can attend (or hire a lawyer to attend). Check the Court’s website for the most current information. You can appear in person or via Zoom. It’s possible the Court will reschedule the Final Approval Hearing. You should check the Settlement Website beforehand or contact Class Counsel to verify the date and time of the Final Approval Hearing. If the Court authorizes a virtual hearing, information on how to participate virtually will also be provided on this website. 

The Agreement sets forth everything Defendants and Plaintiffs have promised to do under the proposed Settlement. The easiest way to read the Agreement, the Judgment or any other Settlement documents is to go to the Settlement Website. You can also send an email to Class Counsel or the Administrator found in the Contact Information tab of this website, or consult the Superior Court website by going to:

 https://webapps.sftc.org/ci/CaseInfo.dll?&SessionID=79B7B43679F3735ADF903686760DD379DC23B788

and entering the Case Number for the Action, Case No. CGC-24-612800.

DO NOT TELEPHONE THE SUPERIOR COURT TO OBTAIN INFORMATION ABOUT THE SETTLEMENT.

You can also contact counsel below:

Class Counsel:

CLARKSON LAW FIRM                                           TYCKO & ZAVAREEI LLP

Glenn A. Danas                                                               Shana Khader

[email protected]                                      [email protected]

22525 Pacific Coast Highway                                       2000 Pennsylvania Avenue, NW

Malibu, CA 90265                                                          Suite 1010

Kristen G. Simplicio                                                       Washington, DC 20006

[email protected]                                   Telephone: (202) 973-0900

1050 Connecticut Avenue, NW, Suite 500                     Facsimile: (202) 973-0950

Washington, DC 20036                                                 

Telephone: (213) 788-4050

Facsimile: (213) 788-4070

Counsel for Defendants:

Eric M. George (State Bar No. 166403)

Christopher T. Berg (State Bar No. 344565)

ELLIS GEORGE LLP

2121 Avenue of the Stars, Suite 3000

Los Angeles, CA  90067

[email protected]

[email protected]

Settlement Administrator:

Dann v. Rodan + Fields Settlement Administrator

P.O. Box 301130

Los Angeles, CA 90030-1130

The court has appointed a settlement administrator to manage this process. For further details regarding the settlement process, including how to receive a class benefit, how to file a claim form to challenge the calculations of your class benefit, and important settlement deadlines, please read through this website and if further questions remail, please contact the settlement administrator at [email protected] 

Rodan + Fields provided data to the settlement administrator for all class members covering the period of March 1, 2020 to June 20, 2025, including dates of enrollment, sales made by class members during this time period and commissions earned on those sales, as well as any fees paid to Rodan + Fields or purchases from Rodan + Fields by class members during this time period.

The court has appointed a settlement administrator to manage this process. If you have questions related to the data, please do not contact Rodan + Fields for this information as it has already been provided to the settlement administrator. For further details, please reach out to the settlement administrator at [email protected]. 

The class benefit allocation process was determined as part of the settlement agreement by the parties and has been preliminarily approved by the Court.  For further details regarding the settlement process, including how to receive a class benefit, and important settlement deadlines, please review the settlement website and if questions remain, please reach out to the settlement administrator at [email protected].