The Agency will pay $20 million into the settlement fund if 350 or more Class Members submit bona fide claim forms by May 10, 2017.  If fewer than 350 women submit valid claim forms by the deadline, the amount to be paid will be reduced by $40,000 times the difference between 350 and the number who submit bona fide forms.  For example, if 300 women submit bona fide forms, the Agency will pay $18 million.

The Agency’s payment will be used to make awards to Class Members who submit valid Claim Forms by May 10, 2017, and to pay the fees and expenses of Class Counsel and of the Claims Administrator.


While it is possible to fill out the form and return it by mail, email, or fax, we strongly urge you to fill out the form online as this is the only way to ensure that your form is not lost and that your entries are accurate.  You can access the Claim Form by clicking HERE.

Class members MUST submit a Claim Form by May 10, 2017, in order to be eligible for an award of money damages.


It is impossible to predict how much money any Class Member will receive.  It will depend on factors such as the number of Class Members who submit valid Claim Forms and the information that is contained in each form.  For more information about the process for determining how much money each class member will receive, please review pages 2 to 5 of the Attachment A to the Notice, which you can access on this site.


The table below shows the largest judicial settlements of gender discrimination cases per Class Member during the past decade:

Case Year of Settlement Settlement Amount No. of Class Members Amount per Class Member
White v. Lynch (this case) 2017 $20.0M 524 $38,168
Brown v. Medicis 2016 $7.1M 225 $32,000
Moore v. Publicis Groupe 2015 $2.9M About 100 $29,000
Velez v. Novartis 2010 $152M 5,600 $27,000
Carter v. Wells Fargo 2011 $32M 1,200 $27,000
Aviles v. BAE Systems 2016 $3M 177 $17,000
Augst-Johnson v. Morgan Stanley 2007 $46M 2,867 $16,000
Amochaev v. Citigroup Global Markets d/b/a Smith Barney 2008 $33M About 2,400 $15,000

Obviously, every case is different, and a fair monetary settlement depends on the unique facts of each case. But, however measured, this is one of the largest resolutions per class member in the 50-year history of Title VII gender discrimination class action cases.

Important Dates Regarding Monetary Relief in Settlement Agreement

Judge Preliminarily Approves Settlement January 17, 2017
Notice Emailed and Mailed to Class Members February 9, 2017
Deadline for Class Members to Submit Objections March 13, 2017 
Deadline for Class Members to Submit Claim Form May 10, 2017
Claims Administrator to Send Notice of Receipt of Claim Form Within 21 days of receiving Claim Form, provided that all such notifications shall be sent within 105 days after the Notice is sent to Class Members
Claims Administrator’s Declaration (to include number of Bona Fide Claimants and Formula for Determining Awards) August 8, 2017
Judge Approves Settlement Probably about September 15, 2017
Effective Date* Probably about October 15, 2017
Claims Administrator to Send Bona Fide Claimants Notice of Award and First Award Payment of 90% of Award 45 days after Effective Date (probably about December 1, 2017)
Deadline for Valid Late Claimants 180 days after Effective Date*
Second Award Payment of 10% of Award to Bona Fide Claimants 1 year after Effective Date*

*The Effective Date means the date on which all of the following have occurred: (1) the Administrative Judge has granted Final Approval to this Settlement Agreement and entered an order so indicating; (2) the Administrative Judge has dismissed the Matter other than to enforce this Settlement Agreement, address settlement administration matters, and address such post-decision matters as may be appropriate; and (3) the time for appeal has either run without an appeal being filed or any appeal has been finally resolved.

If you have questions about the monetary relief in the Settlement Agreement,
please contact Class Counsel:

Heidi Burakiewicz
Kalijarvi, Chuzi, Newman & Fitch, PC
1901 19th Street, N.W.
Suite 610
Washington, D.C. 20036
Phone – 202-331-9260
Fax – 877-219-7127

You should NOT contact the Agency or the Judge with any questions about the case or settlement.