• Refills Investigation Sign Up

    Refills Investigation Sign Up

    Welcome from Class Action U! We've partnered with Milberg PLLC to help you join the lawsuit involving Refills. Please fill out the form below.

  • Milberg is investigating claims involving the illegal distribution of personal data tied to individuals who visited the Refills site and purchased a weight-loss drug. 


    Please complete this form to help us determine whether you may qualify as a claimant. 

  • Date
     - -
  • Did you personally visit or use Refills.com?*
  • Please complete the sentence below by selecting the answer that best describes your timeframe. I personally used Refills.com within approximately the last:*
  • Did you personally answer any Refills "Quiz" questions such as the Refills Weight-Loss Quiz, Better Intimacy Quiz, Hair Health Quiz, or Daily Health Quiz?*

  • Tip: You may have been directed to the quiz by clicking on a medication or product page and hitting the "Get Started", "See If You Qualify", or "Start Your Journey Today" buttons.

  • What kind of information did you provide? Select all that apply.*

  • Privacy Policy

  • Congratulations!

    Good news! Based on your answers, you may qualify to pursue a claim. Please provide your contact information below.
  • Did you create a Refills account?*
  • If yes to the above, is the email address you provided above the same email address you used to create a Refills account?*
  • Format: (000) 000-0000.

  • There appears to be an issue with your phone number. Please ensure the number is correct without country codes.

  • Your data privacy and security are important to us. Click here to review our Privacy Policy: Milberg Privacy Policy

  • Which answer best describes your use of Refills?*

  • Thank you for submitting the final question. The following screen asks you to upload documents relating to your claim. If you do not have documents to upload now, a secure link will be sent to the email address you provided for a secure upload later.

  • Help us verify your claim

    You’re almost done! Add any proof you have now, then continue to the final confirmation
  • Do you have proof of your Refills use, such as screenshot(s) from Refills showing your quiz results, account profile information, order/purchase confirmation, marketing emails, personalized treatment communications, and/or your Refills subscriptions?*
  • Browse Files
    Drag and drop files here
    Choose a file
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  • Helpful proof includes:

    • Refills website screenshots showing your quiz results, account profile information, saved searches, or other account-identifying information.
    • Refills emails or text messages showing quiz results, account profile information, order/purchase confirmations, marketing emails, personalized treatment communications, subscription details, or other communications from Refills.
    • Browser history or device records showing visits to the Refills website or participation in the Refills Quiz, if available.
    • Other records showing that you visited or viewed pages on the Refills website, or otherwise participated in the Refills Quiz.

  • You may leave this section blank for now, and we’ll send you a secure link by email so you can upload documents later. Please note, however, that your claim may not be able to proceed automatically without supporting documents, and missing documents may delay review.

  • Privacy Policy

  • Thank you for completing the questionnaire. Please confirm the statements below.

  • Have you previously received any money, settlement payment, arbitration payment, or other compensation for this dispute against Refills?*
  • The information I provided is true and accurate to the best of my knowledge.*
  • I authorize Milberg to contact me about this investigation.*
  • If necessary, I am prepared to provide documents or testimony confirming this information.*

  • Select Save My Info to save your information. It will not be reviewed until you complete and electronically sign the Attorney-Client Agreement.

  • You will now be asked to electronically sign our Attorney-Client Agreement. This is essential in order to give us the permission we need to pursue this claim on your behalf.

    You pay nothing out of pocket.
    You will not be asked for any credit card information to hire our firm.
    If we win, our fee is paid from a percentage of the money we recover for you.
    If we do not win, you pay nothing.

  • Privacy Policy

  • Client Name: {legalName}
    Client Email: {typeA206}

    Re: {legalName} v. REFILLS HEALTH LLC.

    Dear {legalName}:

    This Attorney-Client Agreement (“Agreement”) outlines the nature of our engagement, along with our mutual responsibilities and expectations. Kindly take a moment to carefully review this letter and feel free to contact us if you have any questions or require additional clarification.

    Scope of the Engagement: This Agreement is between Milberg, LLC (the “Firm”, “We”, “Us”) and you (“Client” or “You”) for the purpose of legal representation in connection with your potential claims against Refills Health LLC, together with its subsidiaries, affiliates, agents, and related entities  (collectively, “Respondents” or “Refills”), arising from alleged violations of federal and state anti-wiretapping laws. 

    This representation covers investigation and, if appropriate, pursuing the claims described above. It does not include any other actual or potential causes of action, appeals, or legal services arising from this or any other matter. After this engagement concludes, the Firm will have no further obligation to advise or provide any legal services on your behalf, unless agreed in writing. You expressly authorize the Firm to discuss your account and obtain your account records from Respondent. Client further represents to the Firm that Client has not signed an agreement with any other attorney(s) to pursue claims against Respondent(s).

    Arbitration and Consolidation. Arbitration is a simplified means of pursuing legal claims, where disputes are resolved by a neutral arbitrator instead of a judge or jury, discovery is more limited, and the arbitrator’s decision is subject to limited court review. While we anticipate arbitration, this Agreement remains in effect regardless of whether the claims are ultimately brought in arbitration, litigated in court, or resolved by settlement before any formal filing. By signing this Agreement, You provide us with a limited, enduring power of attorney to sign legal documents that are related to the arbitration, litigation, or settlement of the claims described above, on your behalf. You or We may terminate this limited, enduring power of attorney by terminating this representation, as described below.

    Express Settlement Authority: You give us exclusive authorization to negotiate settlements with the Respondents, including as part of a group settlement with other similar claims, and to make decisions about litigation or settlement tactics on your behalf. You give us the right to reject any settlement offer that is not equal to your actual loss, or the maximum allowable damages, whichever is greater, unless we believe that we have achieved the likely best settlement possible under the circumstances. If we bring you a settlement offer from the Respondents or about your claim, the final decision on whether to accept the offer is yours. However, we may advise you that we feel the settlement is fair and reasonable, and if you disagree with our advice, we may withdraw as counsel after giving you reasonable notice or ask the arbitral panel for permission to withdraw as your attorneys consistent with the applicable ethics rules. 

    Attorney’s Fees & Costs: You won’t owe us any fees unless we successfully collect a financial recovery for you by payment of an award or settlement of your claim. We agree to represent You on a contingency basis, which means that our fees are a percentage of the settlement, award, or recovery, or other monetary benefit You receive. In the event your claim settles or results in a recovery or award, our fee will be forty percent (40%) of the total gross recovery obtained on Your behalf, unless an arbitrator or court awards a higher fee, in which case the higher amount will apply. If there is no recovery, You owe no fees or costs. 

    After our fees are deducted, we deduct expenses from your gross recovery. Expenses can include expenses specific to your individual arbitration or expenses that we advance on behalf of all our clients with similar cases for the benefit of the whole group of clients. These expenses may include our usual and customary fees for copying, messenger services and similar items, as well as travel expenses. Additionally, to improve efficiency and lower costs, the Firm may use AI-driven solutions for select tasks, e.g. fact investigations, document review, and other routine activities, under the supervision of licensed attorneys, while taking reasonable steps to safeguard client confidentiality. Expenses that we pay to vendors, arbitrators, experts, or others who assist in the arbitration claim process are not kept by us and are billed at cost. Once there is a recovery, settlement, or judgment in your favor, we will inform you in writing of the amount of expenses to be deducted from your award and the nature of the expense.

    If there is recovery or settlement in this case, you grant us the right to receive any monies resulting therefrom, deduct fees and expenses, and send you the remainder. We will do so as soon as practicable. If we cannot locate you or an authorized representative within 90 days of receipt of the funds, we may either hold such funds in escrow or deposit them with the court. In the event you do not elect how to receive your settlement award, you agree that we may disburse your funds as an electronic debit/credit card to the email address we have on file. You understand that we may have a lien upon any amount recovered for you.

    You acknowledge that we may associate with other counsel in connection with your claim, in which event we will split our attorney’s fee with co-counsel. It will not increase your overall fee obligation. 

    Cooperation: You agree to fully assist and cooperate with us regarding your case. You agree to be truthful and to promptly, accurately, and completely provide us with all relevant facts, preserving all pertinent evidence, and being available for discussions, meetings, and any required court or arbitration proceedings. The representations by Client in the Certification below are material terms of this Agreement.

    Consent to Joint Representation and Collective Proceedings: You understand and acknowledge that the Firm represents other clients with similar claims against the same Respondent(s). By jointly representing multiple clients, the Firm can pool resources and potentially offer a more effective overall strategy; however, this approach may not maximize your individual share of any recovery. The Firm will not favor one client’s interest over another. Client further understands that some settlements may be conditioned upon a certain percentage of participants agreeing to resolve their claims through settlement. You understand and acknowledge these benefits and risks, consent to the Firm’s joint representation of you alongside other similarly situated clients and waive any conflicts that might arise from such representation. Accordingly, you authorize the Firm to pursue your case in individual, multi-party, collective, representative, or mass arbitration or court proceedings, and to negotiate classwide, collective, mass, coordinated, or representative settlements of claims.

    Communications and Confidentiality: You have certain responsibilities as a client, including the responsibility to keep us updated as to your contact information, to promptly respond to our communications, and provide information and documents we need for your claim electronically. Email will be our primary means of communicating with you. It is your duty to keep your contact information up to date and promptly inform us of any changes to personal information. You may receive text messages from us or on our behalf in connection with providing our services to you. All communications and case-related information must be kept strictly confidential. This includes refraining from sharing any information on social media or public platforms.

    Termination of the Representation: You have the right to end this Agreement at any time, provided you give the Firm timely written notice. Similarly, the Firm reserves the right to terminate our representation for good cause, including but not limited to, your failure to comply with this Agreement, lack of cooperation, refusal to follow our substantive advice, if continuing to represent you would be unlawful, unethical, ineffective, if there is little or no likelihood of success on the claims’ merits, if continued representation would result in an unreasonable financial burden, or for any other reason that is permissible under relevant professional or ethical guidelines.

    Arbitration between You and Us. The relationship between You and Us will be governed by New York law, without regard to its conflict of law rules. Any disputes between You and Us will be decided in arbitration by the JAMS, under its Streamlined Rules, which can be found here: https://www.jamsadr.com/rules-streamlined-arbitration/, in your county of residence or in New York County, unless the dispute is subject to arbitration under the Part 137 Fee Dispute Resolution program. More information about that program is available here: https://ww2.nycourts.gov/rules/chiefadmin/137.shtml. 

    Entire Agreement: This Agreement constitutes the sole and entire agreement between the Firm and You and supersedes all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, with respect to the subject matter. If any term or provision of this Agreement is invalid, illegal, or unenforceable in any jurisdiction, it shall not affect any other term or provision of this Agreement or in any other jurisdiction. 

    Acknowledgment and Agreement: Client hereby acknowledges having read and fully understanding the terms of this Agreement and having had opportunity to seek independent legal advice before signing this document. 

    If You agree with the outlined terms, we kindly ask that you sign and return this document to indicate your agreement. We look forward to working with you and advocating on your behalf in this matter.

    Sincerely,


    /s/ Douglas H. Sanders 
    Douglas H. Sanders 
    MILBERG LLC 
    1311 Avenida Juan Ponce de León 
    San Juan, Puerto Rico 00907 
    Tel: (516) 741-5600 
    dsanders@milberg.com 

    CERTIFICATION

    I, the undersigned client, hereby certify that I am 18 years or older, and: 

    ■ I am submitting this information based on my own experience, not on behalf of someone else. 

    ■  I am eligible to pursue the claims outlined above based on my present recollection, the documents currently available to me, and counsel’s investigation to date.

    ■ This is my first time submitting information about {campaign} to Milberg or any other law firm or attorney. 

    ■ I understand that if I have retained, or do retain, another attorney or law firm to pursue such claims, the Firm reserves the right to terminate its representation of me.

    ■  I am not a party to any other active lawsuit, class action, arbitration, or legal proceeding asserting such claims against {campaign}. 

    Accordingly, I authorize the Firm to evaluate the claims described above and, if the Firm determines that further action is warranted, to pursue those claims in the appropriate forum seeking monetary compensation, including statutory damages, as well as other available relief. 

    Furthermore, I authorize the Firm to opt me out of any future modifications to the arbitration agreement in {campaign}’s Terms applicable to my claim, and/or, upon advance notice from the Firm, opt me out of a classwide settlement of claims if the Firm determines it is in my best interest. 

    If necessary, I am prepared to provide documentation or testify to confirm this statement.



    Agreed to on this _____ day of _________________, 2026.

    _______________________________

    {legalName}

  • Date*
     - -

  • VIA EMAIL AND CERTIFIED MAIL – RETURN RECEIPT REQUESTED

    Refills.com 
    Attn: Legal Department
    1401 Pennsylvania Ave, Suite 105
    Wilmington, DE 19806
    support@refills.com 

    Re: Notice of Dispute Concerning Refills’ Privacy Violations 

    To Whom It May Concern:

    I hereby provide notice of my individual dispute with Refills Health LLC, together with its subsidiaries, affiliates, agents, and related entities (collectively, “Refills”), arising out of my use of Refills’ website, health-intake flow, quiz, and/or product-matching flow and its use of third-party code, software processes, and similar technologies on its digital platforms (collectively, the “Tracking Tools”) that caused or permitted third parties to receive, read, attempt to read, learn, capture, transmit, disclose, share, or use information associated with my electronic communications with Refills and my activity on its digital platforms, without my prior, informed consent or legal authorization. 

    Nature and Basis of Dispute

    I used Refills’ website one or more times during the period relevant to this dispute while I was located in {state}. To the best of my recollection, this occurred approximately within the past {typeA156} before this Notice.

    When I visited Refills’ website, I was not presented with a typical shopping or browsing experience. Instead, Refills promptly directed me toward prompts such as “Get Started,” “Explore” or similar calls to action. Those prompts led me into a structured health-intake flow that asked me to provide personal and medical information before I could meaningfully evaluate, access, or obtain Refills’ products or services.

    As part of that intake process, Refills asked me questions about sensitive health-related topics, including my medication use, health and sexual health history, health goals, and related information. I understood that I was providing this information to Refills so Refills could evaluate my eligibility, generate recommendations, or offer prescription-related products or services. I was not clearly told, before providing my health-intake information, that my sensitive health-intake answers, the health-related pages I viewed, or identifiers linked to me or my device would be captured or transmitted in real time to TikTok, ByteDance, Mountain, or other third parties. 

    Based on my current understanding, Refills caused or permitted the contents of my website communications, together with persistent identifiers and session data linked to me or my device, to be captured, accessed, disclosed, or transmitted in real time to one or more third parties, including but not limited to TikTok, ByteDance, Mountain, Microsoft Bing, Snapchat, Taboola, Facebook, Reddit, and Twitter/X. These transmissions included or revealed the contents, substance, or meaning of my communications and activity on Refills.com, including my health-intake answers, the specific medication names and medication types I selected or was shown, my health-related goals, and descriptive page URLs and page titles identifying specific medications and conditions as applicable. Separately, and in the alternative, the same transmissions included non-content routing, addressing, signaling, source-identifying, browser-identifying, device-identifying, and session-identifying information associated with my interactions with Refills.com—e.g., page URLs, referrer information, pageview and event information, timestamps, IP-address information, browser and device information, user-agent information, persistent identifiers, cookies, and session-related identifiers—sufficient to identify, profile, retarget, or link me across platforms and sessions.

    I would not have knowingly agreed—and did not knowingly agree—to have my Refills health-intake communications, identifiers, URLs, cookies, IP-related data, or session activity sent in real time to TikTok, or any of the other third-party vendors identified above. I am also not aware of any court order authorizing Refills, TikTok, or any related vendor to install, deploy, or use tracking tools to decode, access, transmit, or otherwise process information associated with my website communications. Additionally, TikTok, its relationship with ByteDance, and the Chinese government have been the subject of serious congressional, executive, and Supreme Court-recognized national-security concerns involving large-scale data collection, profiling, and potential foreign-adversary access to U.S. users’ personal information. Those concerns would have been especially important to me because I was not merely browsing a general retail site—I was providing sensitive health-related information in what I understood to be a prescription-related intake process.

    Refills did not provide me with clear, conspicuous, and meaningful prior notice that my health-intake communications and related identifiers would be captured, disclosed, or transmitted to TikTok, Mountain, or the other vendors identified above. To the extent Refills presented any privacy disclosure, terms, or other notice later in the process, that later notice did not provide meaningful prior authorization and could not retroactively authorize information that had already been captured, accessed, disclosed, or transmitted.

    I was harmed because Refills allowed sensitive health-related information and identifiers associated with me to be shared with third parties without my prior, informed, and meaningful consent. This deprived me of control over my private information, exposed my health-related website communications to third-party tracking and advertising systems, and subjected me to the risk that my information could be used for profiling, targeting, or other commercial purposes unrelated to the treatment or prescription-related reason I believed I was providing the information.

    I contend this conduct violates applicable federal law, including the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510 et seq., and state privacy, wiretapping, consumer-protection, or electronic-surveillance laws, including laws prohibiting the unauthorized collection, interception, disclosure, sharing, sale, marketing use, or other non-treatment use of health-related or individually identifiable information without valid notice, consent, authorization, or other lawful basis. These claims include, where applicable, statutory and common-law privacy remedies, unfair or deceptive acts and practices remedies, and remedies under the laws of my state and any other applicable jurisdiction.

    Relief Sought

    I seek all individual relief available to me under federal law, the laws of my home state, and any other applicable jurisdiction, including statutory, liquidated, punitive, and nominal damages; restitution or disgorgement where available; injunctive and declaratory relief; attorneys’ fees, costs, and interest; and any other relief available at law, in equity, or by contract. I seek relief available under California law, including but not limited to the California Invasion of Privacy Act, Penal Code §§ 631(a), 638.51, and 637.2; California's Confidentiality of Medical Information Act, Civil Code §§ 56.10, 56.101, 56.36, and 56 et seq.; and related California privacy and consumer-protection laws, to the extent applicable.

    I also preserve all additional and non-waivable rights and remedies available under the laws of my state and any other applicable jurisdiction. I further seek non-monetary relief requiring Refills to stop using the Tracking Tools or similar technologies to collect, disclose, profile, or monetize my health-intake data and to delete improperly collected data associated with me. Because the precise number of violations and available remedies depend on records in Refills’, TikTok’s, ByteDance’s, Mountain’s, and related vendors’ possession, I reserve the right to supplement this demand and damages calculation after those records are provided.

    I ask that Refills preserve all records relevant to my claim and provide sufficient information for my counsel and me to evaluate an informal resolution. I authorize Refills to communicate with my counsel identified below regarding this dispute and to disclose to my counsel records and information concerning my account or associated with my use of Refills.com that are reasonably necessary to identify my relevant interactions, determine what tracking technologies were active during those interactions, evaluate what information was collected or transmitted, calculate relief, and discuss informal resolution.

    Request for Informal / Pre-Arbitration Resolution

    I am providing this Notice in good faith as my written description of the Dispute before initiating formal proceedings and to afford Refills an opportunity to discuss an informal resolution of my dispute. If this dispute is not resolved informally within 30 days after Refills receives this Notice, I intend to pursue all available rights and remedies in any available forum and through any available procedure, including individual arbitration before the American Arbitration Association. If I initiate individual arbitration, I will request that Refills pay all AAA filing, administrative, and arbitrator fees pursuant to Refills’ own Terms, Terms of Service (June 2026), https://www.refills.com/terms-conditions. In pursuing individual arbitration under Refills’ Terms, I reserve all objections to any interpretation, application, or provision of Refills’ Terms that is unlawful, unconscionable, non-mutual, procedurally defective, inconsistent with applicable law, or used to limit my substantive rights, remedies, fees, costs, discovery, limitations periods, representative or non-waivable rights, or ability to obtain relief available under applicable law. I also reject, and do not consent to, any unilateral modification of Refills’ terms, privacy policy, or any other purportedly applicable terms unless I affirmatively agree in a separate signed writing.

    This Notice is not a complete statement of all facts, claims, legal theories, damages, remedies, defenses, responses, objections, or grounds. I reserve the right to amend, supplement, refine, or expand this Notice and my requested relief based on additional information, Refills’ records, vendor records, arbitration, litigation, discovery, motion practice, expert analysis, or further investigation. I reserve all rights, claims, remedies, arguments, and objections.

    Please confirm receipt of this Notice and direct all communications regarding this dispute to my counsel listed below.

    Sincerely,

  • VIA EMAIL AND CERTIFIED MAIL – RETURN RECEIPT REQUESTED

    Refills.com 
    Attn: Legal Department
    1401 Pennsylvania Ave, Suite 105
    Wilmington, DE 19806
    support@refills.com 

    Re: Notice of Dispute Concerning Refills’ Privacy Violations 

    To Whom It May Concern:

    I hereby provide notice of my individual dispute with Refills Health LLC, together with its subsidiaries, affiliates, agents, and related entities (collectively, “Refills”), arising out of my use of Refills’ website, health-intake flow, quiz, and/or product-matching flow and its use of third-party code, software processes, and similar technologies on its digital platforms (collectively, the “Tracking Tools”) that caused or permitted third parties to receive, read, attempt to read, learn, capture, transmit, disclose, share, or use information associated with my electronic communications with Refills and my activity on its digital platforms, without my prior, informed consent or legal authorization. 

    Nature and Basis of Dispute

    I used Refills’ website one or more times during the period relevant to this dispute while I was located in {state}. To the best of my recollection, this occurred approximately within the past {typeA156} before this Notice.

    When I visited Refills’ website, I was not presented with a typical shopping or browsing experience. Instead, Refills promptly directed me toward prompts such as “Get Started,” “Explore” or similar calls to action. Those prompts led me into a structured health-intake flow that asked me to provide personal and medical information before I could meaningfully evaluate, access, or obtain Refills’ products or services.

    As part of that intake process, Refills asked me questions about sensitive health-related topics, including my medication use, health and sexual health history, health goals, and related information. I understood that I was providing this information to Refills so Refills could evaluate my eligibility, generate recommendations, or offer prescription-related products or services. I was not clearly told, before providing my health-intake information, that my sensitive health-intake answers, the health-related pages I viewed, or identifiers linked to me or my device would be captured or transmitted in real time to TikTok, ByteDance, Mountain, or other third parties. 

    Based on my current understanding, Refills caused or permitted the contents of my website communications, together with persistent identifiers and session data linked to me or my device, to be captured, accessed, disclosed, or transmitted in real time to one or more third parties, including but not limited to TikTok, ByteDance, Mountain, Microsoft Bing, Snapchat, Taboola, Facebook, Reddit, and Twitter/X. These transmissions included or revealed the contents, substance, or meaning of my communications and activity on Refills.com, including my health-intake answers, the specific medication names and medication types I selected or was shown, my health-related goals, and descriptive page URLs and page titles identifying specific medications and conditions as applicable. Separately, and in the alternative, the same transmissions included non-content routing, addressing, signaling, source-identifying, browser-identifying, device-identifying, and session-identifying information associated with my interactions with Refills.com—e.g., page URLs, referrer information, pageview and event information, timestamps, IP-address information, browser and device information, user-agent information, persistent identifiers, cookies, and session-related identifiers—sufficient to identify, profile, retarget, or link me across platforms and sessions.

    I would not have knowingly agreed—and did not knowingly agree—to have my Refills health-intake communications, identifiers, URLs, cookies, IP-related data, or session activity sent in real time to TikTok, or any of the other third-party vendors identified above. I am also not aware of any court order authorizing Refills, TikTok, or any related vendor to install, deploy, or use tracking tools to decode, access, transmit, or otherwise process information associated with my website communications. Additionally, TikTok, its relationship with ByteDance, and the Chinese government have been the subject of serious congressional, executive, and Supreme Court-recognized national-security concerns involving large-scale data collection, profiling, and potential foreign-adversary access to U.S. users’ personal information. Those concerns would have been especially important to me because I was not merely browsing a general retail site—I was providing sensitive health-related information in what I understood to be a prescription-related intake process.

    Refills did not provide me with clear, conspicuous, and meaningful prior notice that my health-intake communications and related identifiers would be captured, disclosed, or transmitted to TikTok, Mountain, or the other vendors identified above. To the extent Refills presented any privacy disclosure, terms, or other notice later in the process, that later notice did not provide meaningful prior authorization and could not retroactively authorize information that had already been captured, accessed, disclosed, or transmitted.

    I was harmed because Refills allowed sensitive health-related information and identifiers associated with me to be shared with third parties without my prior, informed, and meaningful consent. This deprived me of control over my private information, exposed my health-related website communications to third-party tracking and advertising systems, and subjected me to the risk that my information could be used for profiling, targeting, or other commercial purposes unrelated to the treatment or prescription-related reason I believed I was providing the information.

    I contend this conduct violates applicable federal law, including the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510 et seq., and state privacy, wiretapping, consumer-protection, or electronic-surveillance laws, including laws prohibiting the unauthorized collection, interception, disclosure, sharing, sale, marketing use, or other non-treatment use of health-related or individually identifiable information without valid notice, consent, authorization, or other lawful basis. These claims include, where applicable, statutory and common-law privacy remedies, unfair or deceptive acts and practices remedies, and remedies under the laws of my state and any other applicable jurisdiction.

    Relief Sought

    I seek all individual relief available to me under federal law, the laws of my home state, and any other applicable jurisdiction, including statutory, liquidated, punitive, and nominal damages; restitution or disgorgement where available; injunctive and declaratory relief; attorneys’ fees, costs, and interest; and any other relief available at law, in equity, or by contract. To the extent the law of my state of residence or the state where my data was collected separately protects against the unauthorized collection, use, disclosure, release, sharing, sale, retention, or failure to protect medical information, confidential medical information, consumer health data, sensitive health information, prescription- or medication-related information, sexual-health information, or other health-related information about me, I also seek all individual relief available under those laws.

    I also preserve all additional and non-waivable rights and remedies available under the laws of my state and any other applicable jurisdiction. I further seek non-monetary relief requiring Refills to stop using the Tracking Tools or similar technologies to collect, disclose, profile, or monetize my health-intake data and to delete improperly collected data associated with me. Because the precise number of violations and available remedies depend on records in Refills’, TikTok’s, ByteDance’s, Mountain’s, and related vendors’ possession, I reserve the right to supplement this demand and damages calculation after those records are provided.

    I ask that Refills preserve all records relevant to my claim and provide sufficient information for my counsel and me to evaluate an informal resolution. I authorize Refills to communicate with my counsel identified below regarding this dispute and to disclose to my counsel records and information concerning my account or associated with my use of Refills.com that are reasonably necessary to identify my relevant interactions, determine what tracking technologies were active during those interactions, evaluate what information was collected or transmitted, calculate relief, and discuss informal resolution.

    Request for Informal / Pre-Arbitration Resolution

    I am providing this Notice in good faith as my written description of the Dispute before initiating formal proceedings and to afford Refills an opportunity to discuss an informal resolution of my dispute. If this dispute is not resolved informally within 30 days after Refills receives this Notice, I intend to pursue all available rights and remedies in any available forum and through any available procedure, including individual arbitration before the American Arbitration Association. If I initiate individual arbitration, I will request that Refills pay all AAA filing, administrative, and arbitrator fees pursuant to Refills’ own Terms, Terms of Service (June 2026), https://www.refills.com/terms-conditions. In pursuing individual arbitration under Refills’ Terms, I reserve all objections to any interpretation, application, or provision of Refills’ Terms that is unlawful, unconscionable, non-mutual, procedurally defective, inconsistent with applicable law, or used to limit my substantive rights, remedies, fees, costs, discovery, limitations periods, representative or non-waivable rights, or ability to obtain relief available under applicable law. I also reject, and do not consent to, any unilateral modification of Refills’ terms, privacy policy, or any other purportedly applicable terms unless I affirmatively agree in a separate signed writing.

    This Notice is not a complete statement of all facts, claims, legal theories, damages, remedies, defenses, responses, objections, or grounds. I reserve the right to amend, supplement, refine, or expand this Notice and my requested relief based on additional information, Refills’ records, vendor records, arbitration, litigation, discovery, motion practice, expert analysis, or further investigation. I reserve all rights, claims, remedies, arguments, and objections.

    Please confirm receipt of this Notice and direct all communications regarding this dispute to my counsel listed below.

    Sincerely,

  • cc: 
    Gary M. Klinger
    MILBERG PLLC
    227 W Monroe Street, Suite 2100
    Chicago, IL 60606
    gklinger@milberg.com 
    Tel. (865) 412-2700

    Christian K. Torres
    Ruby Moscone
    MILBERG PLLC
    405 E 50th Street
    New York, New York 10022
    ctorres@milberg.com 
    rmoscone@milberg.com 
    Tel. (865) 412-2700

    Attorneys for Claimant

  • Privacy Policy

  • Thank you for letting us review your potential claim.

    After review of the information provided, our firm has decided to respectfully decline representation.

  • Privacy Policy

  • Should be Empty: