Thorne - Intake & Retainer

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• Screenshots of your Thorne profile that show your name, email address, mailing address or other contact details that match the details you provided Milberg.

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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.

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CONFIDENTIAL ATTORNEY-CLIENT

CONTINGENCY-FEE RETAINER AGREEMENT

Client: {full_name}
Client Email | Phone: {email} | {phone}
Adverse Party: Manufacturers and Traders Trust Company ("Company")
Covered Matter: Client’s use of Company’s website/mobile application and the alleged collection, interception, or transmission of Client’s online activity and related data during the last two years.

READ THIS AGREEMENT CAREFULLY: This Agreement defines the Firm’s work, fees, expenses, settlement authority, communications, and each party’s rights, responsibilities, and expectations. No result is guaranteed. Client should ask questions before signing and may seek independent legal advice.

This Confidential Attorney-Client Contingency Fee Agreement (the “Agreement”) is between Milberg LLC (the “Firm”, “We” or “Us”) and the client identified above (“Client” or “You”).

Covered Matter, Scope of Legal Services. The Firm represents Client only concerning Client’s potential individual claims against the Company arising from the facts and conduct identified above (the “Covered Matter”). This representation covers investigation and, if appropriate, pursuing the claims described above through pre-suit resolution, negotiation, mediation, arbitration, or litigation as appropriate. Arbitration is a process for resolving legal claims before a neutral arbitrator rather than a judge or jury, generally with more limited discovery and court review. The Firm may pursue the Covered Matter through arbitration, litigation, or resolution before any formal filing, and this Agreement remains in effect regardless of the forum.

Excluded Services and Matters. Unless otherwise agreed in writing, the representation does not include unrelated matters or claims, appeals, judgment or award enforcement, bankruptcy, individualized tax advice, or other services outside the Covered Matter.

No Extension or Tolling of Deadlines. Entering into this Agreement does not extend, toll, or otherwise affect any statute of limitations, contractual deadline, or other deadline applicable to Client’s claims. Client is responsible for promptly informing the Firm of any known or suspected deadline that may affect the Covered Matter and providing information reasonably necessary for the Firm to evaluate applicable deadlines.

Continuing Claim Verification. The Firm’s acceptance of this Agreement does not mean it has completed its investigation or determined that Client’s claim is eligible, viable, or suitable for pursuit or settlement. After this Agreement becomes effective, the Firm may continue investigating and verifying Client’s eligibility and other material aspects of the Covered Matter. You authorize the Firm to communicate with the Company concerning your account and the Covered Matter and to request, obtain, and review related records and information.

Client Responsibilities. You agree to assist and cooperate with the Firm; provide truthful, accurate, and reasonably complete information and authentic supporting documents when reasonably requested; preserve relevant evidence and correct material inaccuracies or omissions; keep your contact information current; and be reasonably available for discussions, meetings, and any required court or arbitration proceedings.

Our Contingency Fee. You will not owe us an attorney fee unless we successfully collect a financial recovery for You by settlement, award, judgment, or other monetary recovery on the covered claim. Our contingency fee is forty percent (40%) of your total gross recovery, calculated before deducting costs or expenses. If the state where you resides at the time of signing this Agreement does not permit a contingency fee of forty percent (40%) for the Covered Matter, the contingency fee will instead be the maximum percentage permitted under that state’s law, and the Firm will notify Client in writing of the adjusted percentage. Where required by law, the fee is negotiable between Client and the Firm. If a recovery includes non-cash consideration (for example, injunctive relief, in-kind benefits, or coupons), the Firm will determine the value of that consideration in good faith, using a reasonable and customary valuation method, for purposes of calculating the contingency fee, and will disclose that valuation to You in writing.

Separate Attorneys’ Fees. Where legally permitted, the Firm may seek, negotiate, be awarded, or receive attorneys’ fees separately from your Recovery. Separate attorneys’ fees are not part of your Recovery, and, when paid for the same covered work, will be credited against the contingency fee otherwise due from You, rather than added to it, unless applicable law requires different treatment or You and the Firm agree in writing to another legally permitted arrangement.

Expenses, Costs, and Liens. After attorneys’ fees are deducted, authorized costs and expenses, liens, taxes, and other properly chargeable amounts will be deducted from Client’s remaining recovery, and the balance will be paid to Client. Expenses may be incurred specifically for Client or advanced on behalf of similarly situated clients for their collective benefit. Shared expenses will be allocated pro rata based on each client’s relative share of the total group recovery, or on another reasonable and consistently applied basis if individual recoveries have not yet been determined. Amounts paid to third-party vendors, arbitrators, experts, or other service providers assisting with the Covered Matter are passed through at cost and are not retained by the Firm. The Firm will inform Client in writing of the nature and amount of any deductions from Client’s recovery.

Co-Counsel and Service Providers. You acknowledge that We may associate qualified co-counsel in connection with your claim. If governing law requires later disclosure or consent concerning an actual division of fees, we will provide it. Association of co-counsel will not, by itself, increase your overall 40% contingency fee obligation. To improve efficiency, the Firm may use AI-assisted or other technology for appropriate tasks under lawyer supervision and with reasonable confidentiality and security safeguards

Consent to Joint Representation and Collective Proceedings. You understand that the Firm represents, or may represent, other clients who have similar claims against the same Company. Coordinated representation may allow the Firm to pool resources, centralize common work, reduce duplication, and pursue a more efficient overall strategy. At the same time, clients may differ in their facts and objectives, which may create actual or potential conflicts among jointly represented clients. You consent to the Firm’s joint representation of You and other similarly situated clients and authorize the Firm, when appropriate, to investigate and pursue your claim through individual, multi-party, coordinated, collective, representative, mass-arbitration, or court proceedings. This consent does not authorize the Firm to favor another client’s interests over yours or waive every conflict that may arise. Some settlements may require acceptance by a specified number or percentage of participating clients. If so, the Firm will obtain any informed consent required by law before the settlement binds You.

Limited Opt-Out Authorization. I authorize the Firm to opt me out of any amendment or modification to the arbitration agreement in the Company’s terms applicable to the Covered Matter. I also authorize the Firm, upon advance notice to me, to opt me out of any class or collective settlement applicable to the Covered Matter if the Firm determines in good faith that doing so is in my best interest.

Communications. The Firm may use email, text/SMS, telephone, portals, electronic forms, mail, and other reasonable systems. Email will ordinarily be our primary means of communication.

Settlement Authority and Decisions. You authorize the Firm to act as your exclusive legal representative in settlement negotiations concerning the Covered Matter, including individual, group, portfolio, or coordinated negotiations; make and respond to nonbinding demands and counterproposals; participate in mediation; and make reasonable negotiation and settlement-strategy decisions. The Firm may recommend that You accept or reject a settlement and explain the consequences of either decision. Client’s disagreement with the Firm’s recommendation does not itself end the representation or limit the Firm’s right to withdraw when legally permitted. Except as expressly authorized below under the Advance Settlement and Implementation Authorization or in another writing, the final decision whether to accept a settlement is Yours.

Advance Settlement and Implementation Authorization

By signing this Agreement and initialing where indicated below, Client decides in advance to accept any individual settlement that provides at least $100 in gross cash consideration (the “Settlement Floor”) and satisfies the terms below (a “Qualifying Settlement”).
Initials
The $100 Settlement Floor is a minimum, not a target: in determining whether a proposed settlement is a Qualifying Settlement, the Firm will evaluate the offer in good faith in light of the value, strength, and risks of Client’s claims, and the reasonableness of the offer. Firm will not accept an offer at or near the Settlement Floor if it believes in good faith the claim is worth materially more without first reasonably attempting to consult Client where practicable.

A Qualifying Settlement may include a customary release of claims arising from the Covered Matter, dismissal, confidentiality or non-disparagement terms, and reasonable cooperation needed to process payment or resolve liens. It may not require Client to admit wrongdoing, release unrelated claims, provide indemnification, materially restrict Client’s future conduct, or undertake another material affirmative obligation.

For any Qualifying Settlement, Client expressly authorizes Milberg, without further consultation with or approval from Client before acceptance, to:
- Accept Settlement. Communicate binding acceptance of the Qualifying Settlement on Client’s behalf.
- Sign as Counsel. Execute settlement agreements, releases, stipulations, dismissals, and related documents in the Firm’s capacity as Client’s counsel where counsel’s signature is legally sufficient, and take other non-substantive, ministerial actions reasonably necessary to implement the settlement.
- Sign for Client. To the extent permitted by applicable law and any required power-of-attorney formalities, execute settlement agreements, releases, and related documents in Client’s name and on Client’s behalf as Client’s attorney-in-fact.
- Handle Settlement Funds. Receive, endorse where permitted, safeguard, deposit, and disburse settlement proceeds; deduct authorized attorneys’ fees, expenses, liens, and other properly payable amounts; and remit the balance to Client.
Client may revoke or modify this authorization at any time before Firm communicates binding acceptance. Firm will not rely on this authorization following a material change in circumstances that reasonably calls into question whether it continues to reflect Client’s settlement decision. This authorization does not apply to an aggregate settlement where applicable law requires your separate informed consent, a settlement requiring court approval, or any sworn certification or other act that applicable law requires Client personally to perform. The Firm will provide any post-settlement notices and accounting required by applicable law or professional obligations.

Confidentiality. Please protect privileged, settlement-confidential, or other confidential case information and do not post it publicly or on social media unless We advise otherwise or applicable law permits disclosure. Even if Client ultimately does not settle, receives no Recovery, or the representation ends, Client may remain obligated to keep nonpublic or confidential information concerning the Matter confidential. Nothing in this Agreement or in any resulting settlement restricts Client’s right to report conduct to, or communicate and cooperate with, any government agency (including the EEOC, SEC, or a state attorney general) or otherwise limits protections available under applicable whistleblower laws, and any nondisclosure or non-disparagement provision will be applied consistent with applicable law, including any restrictions on such provisions in settlements involving claims of sexual harassment or sexual assault.

Ending the Representation. Client may end this Agreement at any time by giving the Firm written notice. The Firm may withdraw or terminate the representation when applicable law permits or requires, including for continued material failure to cooperate after reasonable notice; materially false, misleading, fabricated, contradictory, incomplete, or reasonably unverifiable information; prolonged inability to communicate with You; a conflict of interest; a legal or ethical restriction; a determination that the claim is not viable or should not reasonably be pursued; an unreasonable financial burden or other circumstance recognized by applicable professional rules; or another legally sufficient reason. After this representation ends, the Firm will have no obligation to provide further legal advice or services concerning the Matter unless We separately agree in writing or applicable law requires otherwise. If the representation ends before a Recovery is obtained, the Firm reserves the right to seek a fee for services performed and reimbursement of expenses advanced, determined under applicable law (for example, on a quantum meruit or pro rata contingency basis), and to assert any lien available under applicable law to secure that amount.

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. By agreeing to arbitrate disputes with the Firm, including any future malpractice or fee dispute, Client gives up the right to a jury trial or court proceeding on those disputes and accepts arbitration’s generally more limited discovery and appellate review. Client is encouraged to ask the Firm questions about this provision, and may wish to consult independent counsel, before agreeing to it.

Entire Agreement. This Agreement constitutes the entire agreement between the Firm and You concerning the subject matter and supersedes prior or contemporaneous understandings on that subject. All other provisions of this Agreement remain unchanged. If any provision is invalid, illegal, or unenforceable in a jurisdiction, that does not affect the remaining provisions to the extent permitted by law.

Acknowledgement and Agreement

By signing, I confirm that:
- I have read and understand this Agreement, had an opportunity to ask questions and seek independent legal advice, and will receive a completed copy after the Firm accepts it.
- I understand that I have decided in advance that a Qualifying Settlement meeting the $100 Settlement Floor may be accepted on my behalf without further approval, subject to the conditions above, and that I may revoke or modify that authority before the Firm communicates binding acceptance.
- I understand that the $100 Settlement Floor is the minimum gross settlement amount, not the amount I will receive after attorneys’ fees and authorized deductions.
- I understand that the contractual attorney’s fee is 40% of my gross Recovery, calculated before costs, expenses, or liens are deducted, unless the law of my state of residence at signing requires a lower maximum percentage, in which case the lower percentage applies.
If You agree with these terms, please sign and return this 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

Agreed to on this _____ day of _________________, 2026.

_______________________________
Signature
Date

MonthDayYear
2 digit month, 2 digit day, 4 digit yearDate
Consent E-Signature

By checking this box and electronically signing below, I understand and agree that my electronic signature will have the effect of: 1. Signing the Attorney-Client Agreement; 2. Signing the Certification; and 3. Providing my electronic signature and consent for the Firm to prepare and send a notice letter with my electronic signature on my behalf to the company identified in the Attorney-Client Agreement, as necessary to begin the dispute resolution process.
Communications Disclosure

By checking this box, you consent to receive emails, text messages, and phone calls from Milberg, including via automated technology, to the email address and phone number provided. For SMS and calls, you understand that consent is not a condition of receiving legal services. Milberg may share my email address and phone number with its service providers for the purpose of sending these emails and/or making these calls or texts. Message and data rates may apply. Message frequency varies. For SMS, you can opt-out by replying “STOP” to any message. For calls, you can request to be placed on our Do Not Call list.
VIA CERTIFIED MAIL—RETURN RECEIPT REQUESTED

Thorne Research, Inc., Attn: Legal Department,
620 Omni Industrial Blvd,
Summerville, SC 29486

Pre-Arbitration Notice of Individual Consumer Privacy Dispute

To Whom It May Concern:

I am sending this Notice of Dispute to notify Thorne Research, Inc., together with its subsidiaries, affiliates, agents, and related entities (collectively, “Thorne”), of my individual dispute arising from my use of Thorne’s websites, mobile applications, and related digital services (collectively, the “Thorne Services”) and Thorne’s installation, use, or enablement of third-party tracking code and related technologies that recorded or decoded information associated with my electronic communications and interactions with Thorne.

Nature and Basis of the Dispute

I personally used the Thorne Services while physically located in {answer_2}. During my use of those services, I {answer_3} and otherwise communicated and interacted with Thorne. To the best of my recollection, this use occurred within the applicable limitations period.

Based on my current understanding and counsel’s investigation into Thorne's tracking practices, Thorne deployed, enabled, or caused the deployment of tracking code associated with Google, Microsoft, Quantum Metric, and other third-parties, including on thorne.com. That investigation showed that the tracking code caused or permitted the contents of electronic communications with Thorne, or information reflecting the substance and meaning of those communications, to be contemporaneously transmitted or otherwise made available to Google, Microsoft, Quantum Metric, or other third parties. Depending on the interaction, the information transmitted or made available included or reflected search terms entered into Thorne’s site-search field; the search-results pages viewed; page titles constructed from the search terms entered; and the pages from which a user navigated. For example, a search term entered through Thorne’s site-search functionality was transmitted to Google in a labeled search-term field, as “ep.search_term=magnesium supplement”; that same search term was transmitted in a single request carrying the event name “site_search” together with the results-page URL, the page title “Search results for magnesium supplement | Thorne,” and the referring page “https://www.thorne.com/take-5-daily”; and the same search term, carried in the results-page URL and page title, was separately transmitted to Microsoft, TikTok, Spotify, AppLovin, and Dynamic Yield. The investigation also observed that Thorne’s session-replay technology recorded the site-search request itself, transmitting search request URLs to Quantum Metric, and observed a common client identifier and session identifier being carried across those transmissions, together with Microsoft’s visitor and session identifiers, TikTok’s anonymous identifier, and Dynamic Yield’s user identifier. Taken together, these findings support a reasonable inference that Thorne deployed or enabled the challenged tracking code not merely to process communications between consumers and Thorne, but to associate information reflecting the contents or substance of those communications with consumer identifiers or persistent behavioral profiles and to facilitate the subsequent profiling, use, disclosure, targeted advertising, marketing, commercial exploitation, or other unlawful downstream use of that information.

Upon information and belief, the challenged tracking code operated in the manner described above in connection with my electronic communications and interactions with Thorne, causing or permitting the contents or substance of my communications to be contemporaneously transmitted or otherwise made available to Google, Microsoft, Quantum Metric, or other third parties. I did not provide legally sufficient prior consent or authorization for these, or other, third parties to contemporaneously receive, read, learn, or otherwise acquire the contents of my electronic communications with Thorne as described above.

Separately, the investigation showed that the challenged tracking code and related technology recorded or decoded non-content dialing, routing, addressing, signaling, or related information associated with electronic communications and interactions with Thorne. This information included or reflected, as applicable, IP addresses, page and referrer URLs, page titles, pageview and event signals, and browser-, device-, cookie-, session-, and request identifiers, including the Google client identifier “cid” and session identifier “sid,” Microsoft’s “vid” and “sid” identifiers, TikTok’s anonymous identifier, and Dynamic Yield's user identifier, associated with the source, destination, routing, addressing, or transmission of those communications. Upon information and belief, the challenged tracking technology operated in this manner in connection with my electronic communications and interactions with Thorne, thereby recording or decoding non-content dialing, routing, addressing, signaling, or related information associated with my communications, without first obtaining the required court order and without any applicable statutory exception or other lawful authorization.

I contend that the conduct described above violated applicable federal and state anti-wiretapping, interception, eavesdropping, and electronic-surveillance laws, including the federal Wiretap Act, as amended by the Electronic Communications Privacy Act of 1986, 18 U.S.C. §§ 2510 to 2523, including 18 U.S.C. § 2511, by intentionally intercepting, endeavoring to intercept, procuring, enabling, or otherwise causing the interception of my electronic communications in violation of federal law. These claims include any applicable theories concerning interception, procurement or assistance of interception, and use or disclosure of unlawfully intercepted communications recognized under the law governing my communications.

I further contend that Thorne violated California Penal Code §§ 638.50 to 638.51 by installing, using, enabling, or causing the use of a pen-register device or process that recorded or decoded non-content dialing, routing, addressing, signaling, or related information associated with my electronic communications, without first obtaining the required court order and without any applicable statutory exception or other lawful authorization. Additionally, I contend that Thorne violated California Penal Code § 631(a) by aiding, agreeing with, employing, or conspiring with Google, Microsoft, Quantum Metric, TikTok, Spotify, AppLovin, and Dynamic Yield to willfully and without my consent read, attempt to read, or learn the contents or meaning of my electronic communications with Thorne while those communications were in transit, and to use or communicate information obtained through that conduct, without my valid consent or other lawful authorization

I reserve all other statutory, common-law, contractual, consumer-protection, privacy, equitable, or related claims, theories, rights, and remedies supported by the facts and applicable law.

Relief Sought

I presently seek $5,000 in monetary relief to resolve this dispute. This amount reflects my present good-faith settlement demand based on the information currently available, including the claims asserted and the remedies potentially available under the federal Wiretap Act, applicable state anti-wiretapping law, and, where applicable, California Penal Code §§ 638.50–638.51 and California Penal Code § 631(a), including the statutory damages available under California Penal Code § 637.2, and other applicable law. I also seek injunctive relief requiring Thorne to cease the challenged tracking practices unless and until Thorne brings those practices into compliance with applicable law.

Nothing in this Notice waives any claim, remedy, or right to seek different or additional relief if subsequently discovered facts, applicable law, or the course of proceedings establishes entitlement to such relief. Nor does this Notice constitute any concession concerning the number, measure, or proper unit of violations or damages.

Informal Resolution

I am providing this Notice in good faith to afford Thorne an opportunity to resolve this dispute before formal proceedings become necessary. I am willing to engage in good-faith resolution discussions during the 60 days following Thorne’s receipt of this Notice. If the dispute is not resolved, I am prepared to pursue arbitration before AAA and pursue any other available remedy.

Nothing in this Notice constitutes a concession or waiver concerning the existence, formation, assent to, notice of, applicable version, applicability, scope, interpretation, or enforceability of any arbitration, dispute-resolution, or related procedural provision Thorne may invoke, including any procedures or conditions governing the initiation, administration, or resolution of a dispute. I expressly reject—and do not consent to—any unilateral amendment or modification to Thorne’s terms unless I affirmatively agree in a separate, signed writing. I further reserve all arguments that any purported requirement has been satisfied or substantially complied with, waived or forfeited, excused, inapplicable, or unenforceable. Nothing in this Notice waives any claim, remedy, defense, objection, or right to proceed in any forum otherwise available under applicable law.

This Notice is based on the information currently available and is not intended as an exhaustive statement of all facts, claims, theories, or remedies. I reserve the right to supplement this Notice as additional information becomes available.

Thorne should take reasonable steps to preserve documents and electronically stored information relevant to this dispute, including information concerning the challenged tracking technologies, their configuration and operation, my relevant interactions with Thorne’s services, and the information collected, recorded, or transmitted in connection with those interactions.

If Thorne considers this Notice deficient in any manner, please notify my attorneys so that they may consider and respond during the informal-resolution process.

I authorize Thorne to communicate with my counsel identified below and to produce to them all records and information associated with me that are reasonably necessary to evaluate and resolve this dispute.

Please direct all communications concerning this matter to my counsel identified below.

Sincerely,
VIA CERTIFIED MAIL—RETURN RECEIPT REQUESTED

Thorne Research, Inc., Attn: Legal Department,
620 Omni Industrial Blvd,
Summerville, SC 29486

Pre-Arbitration Notice of Individual Consumer Privacy Dispute

To Whom It May Concern:

I am sending this Notice of Dispute to notify Thorne Research, Inc., together with its subsidiaries, affiliates, agents, and related entities (collectively, “Thorne”), of my individual dispute arising from my use of Thorne’s websites, mobile applications, and related digital services (collectively, the “Thorne Services”) and Thorne’s installation, use, or enablement of third-party tracking code and related technologies that recorded or decoded information associated with my electronic communications and interactions with Thorne.

Nature and Basis of the Dispute

I personally used the Thorne Services while physically located in {answer_2}. During my use of those services, I {answer_3} and otherwise communicated and interacted with Thorne. To the best of my recollection, this use occurred within the applicable limitations period.

Based on my current understanding and counsel’s investigation into Thorne's tracking practices, Thorne deployed, enabled, or caused the deployment of tracking code associated with Google, Microsoft, Quantum Metric, and other third-parties, including on thorne.com. That investigation showed that the tracking code caused or permitted the contents of electronic communications with Thorne, or information reflecting the substance and meaning of those communications, to be contemporaneously transmitted or otherwise made available to Google, Microsoft, Quantum Metric, or other third parties. Depending on the interaction, the information transmitted or made available included or reflected search terms entered into Thorne’s site-search field; the search-results pages viewed; page titles constructed from the search terms entered; and the pages from which a user navigated. For example, a search term entered through Thorne’s site-search functionality was transmitted to Google in a labeled search-term field, as “ep.search_term=magnesium supplement”; that same search term was transmitted in a single request carrying the event name “site_search” together with the results-page URL, the page title “Search results for magnesium supplement | Thorne,” and the referring page “https://www.thorne.com/take-5-daily”; and the same search term, carried in the results-page URL and page title, was separately transmitted to Microsoft, TikTok, Spotify, AppLovin, and Dynamic Yield. The investigation also observed that Thorne’s session-replay technology recorded the site-search request itself, transmitting search request URLs to Quantum Metric, and observed a common client identifier and session identifier being carried across those transmissions, together with Microsoft’s visitor and session identifiers, TikTok’s anonymous identifier, and Dynamic Yield’s user identifier. Taken together, these findings support a reasonable inference that Thorne deployed or enabled the challenged tracking code not merely to process communications between consumers and Thorne, but to associate information reflecting the contents or substance of those communications with consumer identifiers or persistent behavioral profiles and to facilitate the subsequent profiling, use, disclosure, targeted advertising, marketing, commercial exploitation, or other unlawful downstream use of that information.

Upon information and belief, the challenged tracking code operated in the manner described above in connection with my electronic communications and interactions with Thorne, causing or permitting the contents or substance of my communications to be contemporaneously transmitted or otherwise made available to Google, Microsoft, Quantum Metric, or other third parties. I did not provide legally sufficient prior consent or authorization for these, or other, third parties to contemporaneously receive, read, learn, or otherwise acquire the contents of my electronic communications with Thorne as described above.

I contend that the conduct described above violated applicable federal and state anti-wiretapping, interception, eavesdropping, and electronic-surveillance laws, including the federal Wiretap Act, as amended by the Electronic Communications Privacy Act of 1986, 18 U.S.C. §§ 2510 to 2523, including 18 U.S.C. § 2511, by intentionally intercepting, endeavoring to intercept, procuring, enabling, or otherwise causing the interception of my electronic communications in violation of federal law. These claims include any applicable theories concerning interception, procurement or assistance of interception, and use or disclosure of unlawfully intercepted communications recognized under the law governing my communications.

I reserve all other statutory, common-law, contractual, consumer-protection, privacy, equitable, or related claims, theories, rights, and remedies supported by the facts and applicable law.

Relief Sought

I presently seek $5,000 in monetary relief to resolve this dispute. This amount reflects my present good-faith settlement demand based on the information currently available, including the claims asserted and the remedies potentially available under the federal Wiretap Act, applicable state anti-wiretapping law, and, where applicable, California Penal Code §§ 638.50–638.51 and California Penal Code § 631(a), including the statutory damages available under California Penal Code § 637.2, and other applicable law. I also seek injunctive relief requiring Thorne to cease the challenged tracking practices unless and until Thorne brings those practices into compliance with applicable law.

Nothing in this Notice waives any claim, remedy, or right to seek different or additional relief if subsequently discovered facts, applicable law, or the course of proceedings establishes entitlement to such relief. Nor does this Notice constitute any concession concerning the number, measure, or proper unit of violations or damages.

Informal Resolution

I am providing this Notice in good faith to afford Thorne an opportunity to resolve this dispute before formal proceedings become necessary. I am willing to engage in good-faith resolution discussions during the 60 days following Thorne’s receipt of this Notice. If the dispute is not resolved, I am prepared to pursue arbitration before AAA and pursue any other available remedy.

Nothing in this Notice constitutes a concession or waiver concerning the existence, formation, assent to, notice of, applicable version, applicability, scope, interpretation, or enforceability of any arbitration, dispute-resolution, or related procedural provision Thorne may invoke, including any procedures or conditions governing the initiation, administration, or resolution of a dispute. I expressly reject—and do not consent to—any unilateral amendment or modification to Thorne’s terms unless I affirmatively agree in a separate, signed writing. I further reserve all arguments that any purported requirement has been satisfied or substantially complied with, waived or forfeited, excused, inapplicable, or unenforceable. Nothing in this Notice waives any claim, remedy, defense, objection, or right to proceed in any forum otherwise available under applicable law.

This Notice is based on the information currently available and is not intended as an exhaustive statement of all facts, claims, theories, or remedies. I reserve the right to supplement this Notice as additional information becomes available.

Thorne should take reasonable steps to preserve documents and electronically stored information relevant to this dispute, including information concerning the challenged tracking technologies, their configuration and operation, my relevant interactions with Thorne’s services, and the information collected, recorded, or transmitted in connection with those interactions.

If Thorne considers this Notice deficient in any manner, please notify my attorneys so that they may consider and respond during the informal-resolution process.

I authorize Thorne to communicate with my counsel identified below and to produce to them all records and information associated with me that are reasonably necessary to evaluate and resolve this dispute.

Please direct all communications concerning this matter to my counsel identified below.

Sincerely,
By and through counsel,

Christian K. Torres

Ruby Moscone

MILBERG PLLC

405 E. 50th Street

New York, NY 10022

ctorres@milberg.com

rmoscone@milberg.com

Tel. (865) 412-2700

Gary M. Klinger

MILBERG PLLC

227 W. Monroe Street, Suite 2100

Chicago, IL 60606

gklinger@milberg.com

Attorneys for Claimant
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