Themis Class Action Settlement: Payouts, Deadlines, and Releases

The Themis class action settlement is a $2.25 million non-reversionary fund resolving claims that Themis Bar Review shared its subscribers’ video-viewing activity with Facebook without consent, in alleged violation of the federal Video Privacy Protection Act. Judge Steven C. Seeger of the U.S. District Court for the Northern District of Illinois granted final approval on March 18, 2026, in Sahagún v. Themis Bar Review, LLC, No. 1:24-cv-02065. The window to file a claim closed on February 6, 2026.¹

What the Lawsuit Claimed Themis Did

Sophia Sahagún filed the case on March 12, 2024, alleging that Themis embedded Meta’s tracking pixel on themisbar.com. When a subscriber watched a video lecture while logged into Facebook, the pixel allegedly captured the lecture’s URL along with the user’s Facebook ID from browser cookies and sent both to Meta, letting Facebook tie specific videos to specific people. The complaint said Themis did this knowingly to build advertising audiences and retarget users, without ever obtaining subscriber consent.²

The Video Privacy Protection Act is a 1988 federal statute that bars video service providers from knowingly disclosing consumers’ personally identifiable information to third parties without consent.³ Themis denied doing anything unlawful and said it settled to avoid the cost and uncertainty of continued litigation.⁴

Who Was Eligible

The settlement class covered anyone in the United States who, at any point between March 12, 2022, and August 22, 2024, met all three of these conditions:

Had an active Facebook account,
Held a digital subscription to Themis Bar Review, and
Watched videos on the Themis website while their Facebook account was active.

The judge and his family, Themis’s officers, directors, employees, and attorneys, and anyone who timely opted out were excluded.⁵

How Much Class Members Get

The $2,250,000 fund is non-reversionary, so no unclaimed money returns to Themis. It pays out class member claims, notice and administration costs, attorneys’ fees, and an incentive award for the class representative.⁶

Class counsel Bursor & Fisher, P.A. — attorneys Philip Fraietta and Alec Leslie — was authorized to seek up to 35% of the fund for fees and costs, subject to court approval.⁵ Sophia Sahagún could seek up to $5,000 as an incentive award.¹ Whatever remains after those deductions is split equally among class members with valid claims. Class counsel estimated per-claim payments of roughly $263 to $526, depending on the claim volume.⁶

Under the agreement, payments go out within 90 days of final approval, provided no appeals are filed.⁴ With final approval entered on March 18, 2026, that puts payments on track for distribution in mid-2026 absent an appeal.

Key Deadlines

The deadlines in this case have already run:

Class counsel’s fee application was due January 23, 2026.
The deadline to submit a claim, opt out, or file an objection was February 6, 2026.
The final approval hearing took place on March 16, 2026.
Final approval was entered on March 18, 2026.¹

If you did not submit a claim by February 6, 2026, you cannot collect from this settlement. Claims could be filed online through the settlement website or by mail during the claim period.¹

What Class Members Gave Up

Anyone who stayed in the class and accepted a payment released Themis from all claims, known or unknown, arising from the alleged disclosure of their personal information and video-viewing behavior to Facebook, including any VPPA claims. The release included an express waiver of California Civil Code § 1542, which otherwise preserves rights to unknown claims.⁵ Class members who timely opted out kept the right to sue Themis on their own.

How This Case Fits the Broader VPPA Pixel Wave

The Themis suit is one of many class actions targeting websites that use Meta’s tracking pixel. Plaintiffs argue the pixel transmits users’ Facebook IDs alongside the titles or URLs of videos they watch, amounting to unauthorized disclosure of personally identifiable information under the VPPA. A comparable case against BuzzFeed produced a $9 million settlement that received final approval in late 2024, though per-claimant payouts topped out at $8 plus a one-year BuzzFeed+ subscription because the class was far larger.⁷

Federal appeals courts have split on two questions driving these cases. On what counts as “personally identifiable information,” the Second Circuit held in 2025 that data buried in the pixel’s complex code strings is not information an “ordinary person” could use to identify someone’s viewing habits, effectively shutting down pixel-based VPPA claims in that circuit.⁸

On who qualifies as a “consumer,” the Seventh Circuit, which covers the district where the Themis case was filed, took a broad view in Gardner v. Me-TV National Limited Partnership (March 2025). Judge Easterbrook wrote that a person becomes a VPPA “consumer” by subscribing to any good or service from a video service provider, calling it “immaterial whether the goods or services bought by the complaining purchaser are actually videos.”⁹ The Sixth Circuit reached the opposite conclusion in Salazar v. Paramount Global (2025), requiring a subscription specifically to audiovisual goods or services. The Supreme Court agreed in January 2026 to hear Salazar and resolve the split, with a ruling expected in late 2026 or 2027.⁸ That Seventh Circuit reading likely strengthened the plaintiff’s position in the Themis case, where subscribers paid for a service built around video lectures.

1
Themis VPPA Settlement. Settlement FAQ
2
ClassAction.org. Sahagún v. Themis Bar Review, LLC, Class Action Complaint
3
CourtListener. Sahagún v. Themis Bar Review, LLC, Case No. 1:24-cv-02065
4
Themis VPPA Settlement. Themis VPPA Settlement Home
5
Themis VPPA Settlement. Settlement Agreement
6
Themis VPPA Settlement. Long Form Notice
7
BF VPPA Settlement. BuzzFeed VPPA Settlement Home
8
Business Law Today. Pixel Tools Spur a New Wave of Class Action Litigation Under the VPPA
9
U.S. Court of Appeals for the Seventh Circuit. Gardner v. Me-TV National Limited Partnership, No. 24-1290