On December 9, 2016, a class action lawsuit was filed in the United States District Court for the Northern District of Illinois, Eastern Division, now entitled CS Wang & Associate, et al. v. Wells Fargo Bank, N.A., et al., Case No. 1:16-cv-11223 (the “Lawsuit”). The Lawsuit alleged that an independent sales organization named International Payment Services, LLC (“IPS”) recorded certain calls to California businesses without disclosing the fact that the call was being recorded in violation of Sections 632 and 632.7 of the California Invasion of Privacy Act (“CIPA”). The Lawsuit further alleged that the purpose of these calls was to set in-person sales appointments with the businesses to sell credit card processing equipment and services on behalf of Wells Fargo Bank, N.A. (“Wells Fargo”) and First Data Merchant Services, LLC (“First Data”) (collectively, “the Wells Fargo Defendants”), both of whom are named as defendants in the Lawsuit. The Wells Fargo Defendants deny any wrongdoing or liability in connection with the Lawsuit.


Under the proposed settlement, the Wells Fargo Defendants will make a payment of $28,000,000 to create a fund on behalf of the Settlement Class Members (the “Settlement Fund”). Settlement Class Members who do not exclude themselves from the Lawsuit are eligible for a cash payment from the Settlement Fund for each call that is covered under the class definition set forth in Section VII of the Class Notice (an “Eligible Call” as defined in the Settlement Agreement). Settlement Class Members who received multiple Eligible Calls are entitled to a cash payment for each Eligible Call. The minimum cash payment for each Eligible Call is estimated to be approximately $40, but could be as high as $5,000 per call depending on how many claims are submitted. It is not possible at this time, however, to know the exact amount of each payment.


On August 16, 2021, the Court certified the Lawsuit as a class action for settlement purposes and defined the class as follows:

All businesses that received a telephone call from a call center operated by International Payment Services, LLC or one of its affiliates between March 7, 2011 through May 7, 2014, while the call recipient was physically present in California, and who did not sign a contract for merchant processing services with First Data Merchant Services, LLC.

Any business meeting this definition shall be referred to herein as a “Settlement Class Member” and, collectively, as the “Settlement Class” or “Settlement Class Members.”






In order to receive the cash payment, you must complete and sign a Claim Form for your business and mail it to the Settlement Administrator, by the DUE DATE of November 1, 2021. A pre-paid, self-addressed envelope is provided with the Notice that you can use to mail in your Claim Form.

Regardless of whether you mail the Claim Form or submit a claim online, you must do so by the DUE DATE of November 1, 2021 to be eligible to receive a payment. Settlement payments will be issued only if the proposed settlement is granted final approval by the Court.





Any Settlement Class Member has the right to be excluded from the Lawsuit by written request. If you wish for your business to be excluded from the case, you must mail a written request to the Settlement Administrator. A Settlement Class Member’s exclusion request must be postmarked no later than the DUE DATE of October 25, 2021 and sent to the following address: CS Wang v. Wells Fargo Bank Settlement Administrator, P.O. Box 43160, Providence, RI 02940-3160.

You can find more information about how to request an exlcusion on this website.



If your business does not exclude itself from the Lawsuit, it can comment in opposition to the settlement, including the amount requested for attorneys’ fees and costs or the requested incentive awards, which is known as an objection, and your business has the right to appear before the Court to express its opposition. Your written objection must be submitted in writing and filed with the Clerk of Court by the DUE DATE of October 25, 2021.

You can find more information about how to object on this website.


The Notice provides only a summary of the Lawsuit. You can view the settlement agreement and obtain more information about the settlement on this website. In order to see the complete case file, including the settlement agreement and all other pleadings and papers filed in the Lawsuit, you may also examine the court file at the office of the Clerk of the Court in the Everett McKinley Dirksen Building, 219 South Dearborn Street, Chicago, IL 60604.