Bright Horizons Settlement

Summary

Chelsea Rutter and Magdalena Chavez (“Plaintiffs”) have sued Bright Horizons Children’s Centers LLC. (“Bright Horizons” or “Defendant”) on behalf of themselves and a class of similarly situated employees. The lawsuit, Chelsea Rutter and Magdalena Chavez v. Bright Horizons Family Solutions, Inc. is currently pending in King County Superior Court. Plaintiffs claimed in the lawsuit that Defendant’s placement fee provision in its enrollment contracts with client families, in which client families agreed to pay Bright Horizons a placement fee of $5,000 if they employed a Bright Horizons’ employee within six months of their departure, was in violation of (1) Washington’s law prohibiting unlawful noncompetition covenants and (2) Washington’s Consumer Protection Act.

Defendant denies each of these allegations and contends that it has always complied with all state laws.

The Court has not made any determinations regarding the merits of Plaintiffs’ claims and has made no finding that Defendant violated the law.

Defendant has agreed to pay $3,000,000—which will be used to make payments to members of the Settlement Class, service awards to the Settlement Class Representatives, settlement administration costs, and attorneys’ fees and costs—to settle this action. On March 5, 2026, the Court issued an order preliminarily approving the settlement and authorizing the Settlement Administrator, RG/2 Claims Administration LLC (“Settlement Administrator”), to issue this Notice.

You are receiving this Notice because Defendant’s records indicate you are eligible to participate in the settlement as a Settlement Class Member.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT:
What you do	What happens
DO NOTHING	Stay in the Settlement Class. Receive payment. Give up certain rights. By doing nothing, you will receive a settlement payment if you meet the definition of a Settlement Class Member, and the settlement is finally approved by the Court. But you will be bound by the settlement, including the Release of Claims. “Release of Claims” means that, upon final approval by the Court, Plaintiffs and Participating Settlement Class Members will dismiss the lawsuit and release Defendant and other Released Parties from all claims that were or could have been brought against them based on the allegations asserted in the operative complaint filed in this lawsuit. This releases Defendant from liability related to any claims made in this lawsuit or that could have been made in this lawsuit that arise out of or relate in any way to Defendant’s use of a Placement Fee Provision in its Parent Enrollment Agreements between January 1, 2020, and March 5, 2026. By staying in this lawsuit, you give up any rights to sue Defendant separately about the same legal claims in this lawsuit.
ASK TO BE EXCLUDED	HOW TO EXCLUDE YOURSELF Get out of the Settlement Class. Get no payment for the class action claims. Keep your legal right to sue about the same legal claims. If you ask to be excluded from the class, you will not share in the portion of the settlement allocated to those class action claims. You will keep any rights to sue Defendant separately about the same legal claims and you will not be bound by the settlement (including the Release of Claims). You must submit a request to be excluded no later than June 1, 2026. See below for instructions on how to exclude yourself. How to Exclude Yourself: If you exclude yourself, you will not be paid under the Settlement Agreement. If you exclude yourself, you may not object to the settlement. To ask to be excluded, you must mail a written letter to the Settlement Administrator at the address provided below or email your request to the Settlement Administrator at the email address provided below. The request for exclusion must include your name, current address, and telephone number, as well as a statement clearly asking to be excluded (for example: “I want to be excluded from the settlement in Chelsea Rutter and Magalena Chavez v. Bright Horizons Family Solutions, Inc.”). The letter must be signed by you and postmarked no later than June 1, 2026. The Settlement Administrator is RG/2 Claims Administration LLC. You can mail exclusion requests to RG/2 Claims Administration LLC at the following address: Rutter, et al. v. Bright Horizons Family Solutions c/o RG/2 Claims Administration LLC P.O. Box 59479 Philadelphia, PA 19102-9479 You can email exclusion requests to RG/2 Claims Administration LLC at the following address: BrightHorizonsSettlement@rg2claims.com
OBJECT	HOW TO OBJECT TO THE SETTLEMENT Challenge the settlement terms. If you don’t like the settlement or don’t want it to be approved, you may object and tell the Court why. You may either submit an objection yourself or enter an appearance through an attorney who may submit an objection on your behalf. You may ask the Court for permission for you or your attorney to speak about your objection at the Final Approval Hearing. The Final Approval Hearing will be held on July 24, 2026, at 9:00 am. If the Court approves the settlement despite your objection, you will still be bound by the settlement. If you request exclusion from the settlement, you cannot also object to it. You must submit an objection no later than June 1, 2026. See below for instructions on how to submit an objection. How to Object to the Settlement: If you wish to object, you must submit a written objection with the Court and serve on counsel for the Parties. The letter must include (1) your name, address, and telephone number; (2) the name of the case, Chelsea Rutter and Magalena Chavez v. Bright Horizons Family Solutions, Inc, Case No. 22-2-19810-9 SEA; (3) the reasons why you think the Court should not approve the settlement; (4) any supporting documentation you wish the Court to consider; (5) a request to appear at the Final Approval Hearing if you or your attorney wish to appear; and (6) your signature. The letter must be postmarked no later than June 1, 2026. If the settlement is approved, you will still receive a payment under the settlement even if you object. You can file objections with the Court at the following address: The Honorable Haydee Vargas King County Superior Court Courtroom: C-203 516 3rd Ave Seattle, WA 98104 You can serve objections on Parties’ Counsel using the following addresses: Beth E. Terrell Toby J. Marshall Elizabeth A. Adams TERRELL MARSHALL LAW GROUP PLLC 1700 Westlake Ave N., Suite 300 Seattle, WA 98109 David Seligman Juno Turner Valerie Collins TOWARDS JUSTICE P.O. Box 371680, PMB44465 Denver, CO 80237 Derek Bishop Laura Davis LITTLER MENDLESON, P.C. One Union Square 600 University Street, Suite 3200 Seattle, Washington 98101

Important Dates for Class Members:
Request Exclusion: June 1, 2026
Object to the Settlement: June 1, 2026
Final Approval Hearing: July 24, 2026, at 9:00 a.m.

Location:
The Honorable Haydee Vargas
King County Superior Court
Courtroom: C-203
516 3rd Ave
Seattle, WA 98104