Notice of Class and Collective Action Settlement
All individuals employed by Drata Inc. in California as Sales Development Representatives between May 1, 2021 and September 1, 2025, and all individuals employed by Drata Inc. in the United States, except in California, as Sales Development Representatives between June 11, 2021 and September 1, 2025.
This Notice may affect your rights. Please read it carefully.
A Settlement has been proposed in a class, collective, and representative action pending in the Supreme Court of the State of New York, County of Nassau titled Topping, et al. v. Drata Inc., Case No. 606167/2026. This website summarizes the key terms of the proposed Settlement and your rights and options.
If you have any questions about your legal rights, please contact the lawyers representing the class at Drata@outtengolden.com or 1-202-847-4423 and Msalas@flsalaw.com or 1-312-487-5221. For other questions, please contact the Settlement Administrator at support@apexclassaction.com or 1-800-355-0700.
Important things to know:
- You are eligible to receive an estimated payment from this Settlement, subject to applicable taxes and withholdings. The estimated amount of your payment is stated in the Notice mailed to you.
- You may elect electronic payment or update your mailing address to ensure receipt of the settlement payment on the Electronic Payment Election page.
- The Court still needs to enter final approval of the Settlement. Settlement payments will be made if and after the Settlement becomes final. Please be patient.
Important Dates
October 13, 2026
Deadline to Opt Out or Object
Applies to California Settlement Class Members. Opt-out statements and objections must be postmarked by this date.
Final Effective Date
Deadline to Request Electronic Payment
Class and collective members have until the Final Effective Date to elect electronic payment or update their mailing address through this website.
To Be Determined
Final Fairness Hearing
The Court may hold a final fairness hearing to determine whether the Settlement should be approved. Any date set by the Court will be posted on this website.
About This Notice
What is the Lawsuit about?
Several former Drata employees, called Plaintiffs, filed an action claiming that the Company misclassified Sales Development Representatives as “exempt” from overtime laws. Plaintiffs allege that the Company failed to pay overtime wages, provide required meal and rest breaks or premium payments in lieu thereof, pay wages timely during employment and at separation, pay all wages owed, provide legally compliant wage statements, maintain accurate wage records, and reimburse necessary business expenses in accordance with California state law. Two Plaintiffs also alleged claims for penalties under the California Private Attorneys General Act of 2004 (“PAGA”).
The Court has not made any judgment or determination about Plaintiffs’ allegations. The Company denies and disputes the allegations and maintains that it complies with applicable laws in good faith. The Company also denies that Plaintiffs’ allegations are appropriate for resolution as a class or collective action or representative PAGA action, other than for Settlement purposes only.
The issuance of this Notice is not an expression of the Court’s opinion on the merits or the lack of merits of Plaintiffs’ claims or allegations in the Lawsuit. The Court has not decided this case in favor of either side. However, both sides have agreed to resolve the claims to avoid the risk and expense of litigation.
Why did I get this Notice?
This Notice is to tell you about the Settlement of a Lawsuit brought on behalf of all employees who work or have worked as Sales Development Representatives for Drata in California during the relevant period.
You received this Notice because Drata’s records show that you are part of the proposed Settlement class. This Notice gives you a summary of the Settlement terms and explains your rights and options.
This Notice is to tell you about the Settlement of a Lawsuit brought on behalf of all employees who work or have worked as Sales Development Representatives for Drata during the relevant period.
You received this Notice because Drata’s records show that you are part of the proposed Settlement collective. This Notice gives you a summary of the terms of the Settlement terms and explains your rights and options.
What do I do next?
Read this Notice carefully to understand the Settlement terms and to determine if you are a class member or a collective member. Then, decide what you want to do.
You are a member of the Settlement class if you were employed by Drata Inc. in California as a Sales Development Representative between May 1, 2021 and September 1, 2025.
You are a member of the Settlement collective if you were employed by Drata Inc. in the United States, except in California, as a Sales Development Representative between June 11, 2021 and September 1, 2025.
If you are unsure which applies to you, contact the Settlement Administrator at 1-800-355-0700.
If you worked in California
Settlement Class Members — employed between May 1, 2021 and September 1, 2025
| Your Rights and Choices | Deadline | |
|---|---|---|
| Do Nothing | You will receive payment in the amount stated in your mailed Notice and you will be included in the Settlement. You can receive this payment by check or request an electronic payment on this website. | No action required |
| Opt Out | You will receive no payment in the Settlement. Opting out is the only option that allows you to bring or maintain your own lawsuit against Drata about the same allegations or claims in the Lawsuit. | October 13, 2026 |
| Object | Tell the Court if you do not like the Settlement by submitting an Objection to the Settlement Administrator. Submitting an Objection does not exclude you from the Settlement. | October 13, 2026 |
If you worked outside California
Settlement Collective Members — employed between June 11, 2021 and September 1, 2025
| Your Rights and Choices | Deadline | |
|---|---|---|
| Accept Payment | Accept the Settlement payment by electing to receive an electronic payment on this website or by cashing or depositing the check. You will be included in the Settlement and release the claims in the Lawsuit. | Final Effective Date to elect electronic payment |
| Do Nothing | Decline the Settlement payment and choose not to cash or deposit the check. You will not be included in the Settlement. | No action required |
Read on to understand the specifics of the Settlement and what each choice would mean for you.
The Court still needs to enter final approval of the Settlement. Settlement payments will be made if and after the Settlement becomes final.
Learning About the Settlement
What does the Settlement provide?
The Company has agreed to pay $1,366,690 into a Settlement fund. This money will be divided among the collective and class members and will also be used to pay costs and attorneys’ fees approved by the Court, any service payments awarded to Plaintiffs who filed the Lawsuit (up to $7,500 each), the amount allocated under PAGA to the state of California, and the cost of administration of the Settlement. Members of the Settlement collective and class will “release” their claims as part of the Settlement, which means they cannot sue Drata for the same issues or claims raised by the Lawsuit. The full terms of the release can be found in the Settlement Agreement. You can review the complete Settlement Agreement on the Case Documents page.
The Settlement allows the Plaintiffs who brought this Lawsuit to request a service award of up to $7,500 each to compensate them for their work on the case. These are called “service payments.” The Court will make the final decision as to any amount to be paid to Plaintiffs as service payments.
How was my estimated payment calculated?
The calculation of your payment depends on the amount of money you earned as a Sales Development Representative in California from May 1, 2021 through September 1, 2025.
The calculation of your payment depends on your total compensation as a Sales Development Representative between June 11, 2021 through September 1, 2025.
The Settlement Administrator used information from Drata’s records to calculate your payment based on the total compensation you received during the relevant period in an eligible role. The Notice mailed to you states:
- The dates Drata’s records show you worked as an eligible employee during the relevant period, and any period of leave of absence;
- The number of eligible weeks this resulted in for you; and
- The approximate amount of the individual Settlement payment you will receive, based on the allocation formula, if the Court approves the Settlement.
Eligible employees who worked in California received a higher amount for each week worked compared with employees who worked in other states because there are more claims alleged under California law than under federal law alone.
How will my payment be taxed?
One third (1/3) of your individual Settlement payment is treated as wages and subject to tax withholdings and deductions (paid on IRS Form W2) and two thirds (2/3) is treated as non-wage compensation with no taxes withheld (paid on IRS Form 1099).
One half (1/2) of your individual Settlement payment is treated as wages and subject to tax withholdings and deductions (paid on IRS Form W2) and one half (1/2) is treated as non-wage compensation with no taxes withheld (paid on IRS Form 1099).
The Settlement Administrator and lawyers in the case cannot advise you on taxes associated with this payment. Please seek your own personal tax advice.
Do I have a lawyer in this case?
In a class action settlement, the Court approves lawyers to represent the class and its members. In a collective action settlement, the Court approves lawyers to represent the collective and its members. For this Settlement, the Court has preliminarily approved the following lawyers as class counsel and collective counsel:
Class and Collective Counsel
Melissa L. Stewart · Aaron Bryce LeeOUTTEN & GOLDEN LLP
685 Third Avenue, 25th Floor
New York, NY 10017
202-847-4423
Drata@outtengolden.com Maureen Salas
WERMAN SALAS P.C.
77 W Washington St Ste 1402
Chicago, IL 60602
312-487-5221
Msalas@flsalaw.com
These are the lawyers who negotiated the Settlement on behalf of the class and the collective.
If you want to be represented by your own lawyer, you may hire one at your own expense.
Do I have to pay the lawyers?
No. These lawyers’ fees and costs will be paid from the Settlement fund.
To date, class counsel has not been paid any money for their work or the expenses that they have paid for the case. To pay for their time and risk in bringing this case without any guarantee of payment, class counsel will request, as part of the final approval of this Settlement, that the Court approve a payment of up to one-third of the Settlement fund, or $433,333.33 total in lawyers’ fees, plus reimbursement of out-of-pocket costs.
Lawyers’ fees and costs will only be awarded if approved by the Court. You have the right to object to the lawyers’ fees or costs even if you think the other Settlement terms are fair.
Are there more details about the Settlement?
This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement. A copy of the Settlement Agreement is available on the Case Documents page.
What happens next?
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 approval to the Settlement before it can take effect. The Court may hold a final fairness hearing to determine whether the Settlement should be approved. Payments will be made if and after the Settlement becomes final.
Option 1: Get a Payment and Release Claims Settlement Class Members: do nothing, get a payment, and release claims. Settlement Collective Members: deposit or cash a settlement check, or receive electronic payment.
How do I participate in the Settlement?
If you wish to participate in the Settlement and receive a payment, you do not need to take any action. If the Court grants final approval of the Settlement, you will receive a settlement payment in the approximate amount stated in your mailed Notice by check in the mail or by electronic payment. If you wish to receive an electronic payment, you must submit your request on this website by the Final Effective Date.
If you wish to participate in the Settlement and receive a payment, you do not need to take any action. If the Settlement becomes final, you will receive a Settlement payment in the approximate amount stated in your mailed Notice by check in the mail or you can also elect to receive an electronic payment on this website by the Final Effective Date.
If your mailing address has changed, please contact the Settlement Administrator at 1-800-355-0700.
Elect electronic payment or update your mailing address here.
When will I receive the money?
If the Settlement becomes final, payments are anticipated to be distributed approximately two months after the Settlement becomes final. Please be patient and update the Settlement Administrator if your contact information changes.
What am I giving up to obtain payment under the Settlement?
If the Court approves the proposed Settlement and you participate in the Settlement, you will be releasing claims against the Company. This generally means that you will not be able to file your own lawsuit or continue prosecuting or participating in another lawsuit regarding the claims and allegations in the Lawsuit.
If the Court approves the proposed Settlement and you participate in the Settlement by cashing your check or receiving electronic payment, you will be releasing claims against the Company. This generally means that you will not be able to file your own lawsuit or continue prosecuting or participating in another lawsuit regarding the claims and allegations in the Lawsuit.
Option 2: Exclude Yourself (“Opt Out”) Settlement Collective Members: your Option 2 is to do nothing and not cash the check.
What if I don’t want to be part of this Settlement?
You can opt out. If you do, you will not receive any payment and you cannot object to the Settlement. You will not be affected by anything that happens in this case.
You do not have to be part of this Settlement. If the Settlement becomes final, you will receive a notice with a settlement check enclosed. If you do not want to be a part of the Settlement, do NOT deposit or cash the check, and you will not be a part of the Settlement or release anything. There is no opt-out form to mail.
How do I opt out?
California Settlement Class Members Only
To opt out of the Settlement, you must mail an opt out statement by October 13, 2026 to the Settlement Administrator at the address listed on the Contact page.
You must include your name, address, telephone number, and a signed statement indicating your intent to opt out, such as “I opt out of the Drata settlement.”
Option 3: Object to the Settlement Applies to California Settlement Class Members only.
California Settlement Class Members Only
What if I disagree with the Settlement?
If you disagree with any part of the Settlement, 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 are not required to, hire your own lawyer to help you at your own expense.
To object, you must mail a letter to the Settlement Administrator listed on the Contact page that:
- is postmarked by October 13, 2026;
- includes your full name, address and telephone number;
- states all the reasons for your objection and any supporting documentation; and
- includes your signature.
What is the difference between opting out and objecting to the Settlement?
Opting out is telling the Court that you do not want to be part of the Settlement class. If you opt out, you cannot object because the Settlement no longer affects you. Objecting is telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement class.
Key Resources
How do I get more information?
This Notice summarizes the settlement. There are more details in the case documents. To get a copy of the case documents, you can contact the Settlement Administrator or Class Counsel:
Settlement Administrator
Apex Class Action, LLCPO Box 54668
Irvine, CA 92619
1-800-355-0700
support@apexclassaction.com
Class Counsel
Melissa L. Stewart · Aaron Bryce LeeOutten & Golden LLP
685 Third Avenue, 25th Floor
New York, NY 10017
1-202-847-4423
Drata@outtengolden.com Maureen Salas
Werman Salas P.C.
77 W Washington St Ste 1402
Chicago, IL 60602
312-487-5221
Msalas@flsalaw.com
PLEASE DO NOT CONTACT THE COURT REGARDING THIS NOTICE OR THE SETTLEMENT.