Class Members may be eligible for a payment estimated to be $95.35 from a class action settlement relating to their application for employment with Defendants Jeff, Pat, Chris, LLC; Farmer Pies, Inc.; and Farmer Co-op LLC (collectively, "Defendants" or "Domino's Pizza").
Peter Corwin, Kyle Mitchell, Leila Vandiver, Nicole Yount, and Vanessa Herold (collectively, "Plaintiffs" or "Class Representatives") filed a lawsuit against Defendants on behalf of themselves and a class of similarly situated applicants for employment. The lawsuit, styled Corwin et al. v. Jeff, Pat, Chris, LLC et al., King County Superior Court Case No. 25-2-05696-1 SEA (the "Lawsuit") is pending in King County Superior Court.
Plaintiffs claim in the Lawsuit that Defendants' job postings for open positions in the State of Washington did not disclose the wage scale or salary range being offered in violation of the pay transparency provision of the Washington Equal Pay and Opportunities Act, RCW 49.58.110. Defendants dispute Plaintiffs' claims and contend they have not violated the law. The Court has not made any determinations regarding the merits of Plaintiffs' claims, nor has it decided whether Defendants violated the law.
Plaintiffs and Defendants (collectively, the "Parties") have reached a proposed Class Action Settlement, which includes a total payment by Defendants of $900,000 ("Common Fund"). On August 22, 2025, the Court issued an order preliminarily approving the settlement and authorizing Simpluris, Inc. (the "Settlement Administrator") to issue the Notice.
Class Members received the Notice because Defendants' records indicate they are eligible to participate in the settlement as a member of the Settlement Class. "Settlement Class Members" include "All individuals who, from January 1, 2023, through August 22, 2025, applied for a job opening in the State of Washington with Jeff, Pat, Chris, LLC; Farmer Pies, Inc.; or Farmer Co-op LLC, where the job posting did not disclose a wage scale or salary range."
The Court still has to decide whether to approve the settlement. No settlement benefits or payments will be provided unless the Court approves the settlement and it becomes final.
Read the Notice carefully. Class Member legal rights are affected regardless of whether they act or not. For complete details, please see the Settlement Agreement, the terms of which control, available here.
Your Legal Rights and Options in this Settlement | |
Do Nothing | You will remain in the Settlement Class, receive a settlement payment upon confirmation of address, and will release certain claims against Defendants. |
Provide/Update Valid Mailing Address | If you have moved or did not receive a Notice by mail, you must ensure the Settlement Administrator has your updated and valid mailing address. Please contact the Settlement Administrator to provide your valid mailing address or submit the Address Form enclosed with this Notice. |
Exclude Yourself from the Settlement | If you request to be excluded, you will no longer be in the Settlement Class and will not receive a settlement payment. This is the only option that allows you to keep any right to sue Defendants about the legal claims in this Lawsuit. The deadline to request exclusion from the settlement is October 30, 2025. |
Object To The Settlement | Write to the Court explaining why you do not agree with the settlement. You must not exclude yourself if you wish to object. The deadline to object is October 30, 2025. |
Attend The Final Approval Hearing | 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 December 12, 2025, at 9:00 a.m. |
Upcoming Important Dates
Objection Deadline
10/30/2025
Opt Out Deadline
10/30/2025
Final Approval Hearing
12/12/2025 at 9:00 a.m.