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Your rights may be affected by a collective action lawsuit regarding overtime compensation.
If you have been an Account Executive or Sales Development Representative at LinkSquares at any time since October 17, 2021, please read this notice.
A collective action lawsuit may affect your legal rights.
This is a court-authorized notice. This is not a solicitation from a lawyer.
Your legal rights may be affected, and you have a choice to make now:
YOUR LEGAL RIGHTS AND OPTIONS IN THIS LAWSUIT
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ASK TO BE INCLUDED
If you choose to be included, you will share in any monetary recovery that might come from a trial or a settlement for the federal claims in this lawsuit. You give up any rights to separately sue LinkSquares about the same legal claims in this lawsuit.
If you wish to be included, you must complete and submit the “Consent to Join” form included with this Notice on or before (if by mail, postmarked on or before) September 8, 2025.
“Join the Case” button/link to online consent form]
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DO NOTHING
By doing nothing, you will not be included in the federal claims this lawsuit. This means that you give up the possibility of a monetary recovery that may come from a trial or settlement if those bringing the lawsuit are successful.
You keep any rights to sue LinkSquares separately about the same legal claims in this lawsuit, but the limitations period on your federal claim will continue to run.
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This notice contains information that affects your rights. Please read it carefully.
1. Why did I get this notice?
You are getting this notice because LinkSquares’s records show that you worked as an Account Executive or Sales Development Representative between October 17, 2021, and the present.
2. What is this lawsuit about?
The lawsuit alleges that LinkSquares failed to pay Account Executives and Sales Development Representatives overtime under the Fair Labor Standards Act (“FLSA”) for the hours they worked over 40 in a workweek. The plaintiff alleges that he and other salespeople performed as their primary duties non-exempt inside sales work and routinely worked over 40 hours in a workweek to meet the quotas, job requirements, and performance metrics set by LinkSquares. Plaintiff alleges he and other salespeople were paid a base salary plus a commission and improperly treated as ineligible for overtime. LinkSquares denies these allegations. The Court has not yet decided who is correct.
The lawsuit is known as Caicedo v. LinkSquares Inc., Case No. 1:24-cv-12642, and is pending before he Honorable William G. Young, United States District Judge in the District of Massachusetts.
3. What is a collective action and who is involved?
In a collective action lawsuit, one or more people may bring a lawsuit on behalf of themselves and others who are similarly situated to them. All salespeople who decide to participate in the FLSA claims in this case are part of the “Collective” and are “Collective Members.” One court resolves the issues for all Collective Members.
4. How do I ask the Court to include me in the case?
Enclosed is a form called “Consent to Join.” If you want to join this lawsuit, you must read, sign, and promptly return the Consent to Join Form by (if by mail, postmarked by) September 8, 2025. An addressed and postage-paid envelope is enclosed for your convenience. The Consent to Join Form must be mailed, faxed, or submitted online to:
LinkSquares Overtime Case
ILYM Group, Inc.
P.O. Box 2031
Tustin, CA 92781
Fax: (888) 845-6185
“Join the Case” button/link to the online consent form
The signed Consent to Join Form must be submitted or postmarked by September 8, 2025.
5. Can LinkSquares and/or my current employer retaliate against me if I join the lawsuit?
No. It is a violation of federal law for LinkSquares or any other employer to fire, discipline, or in any manner discriminate or retaliate against you for taking part in this case. If you believe that you have been penalized, discriminated against, or disciplined in any way as a result of you receiving this notification, considering whether to join this lawsuit, or actually joining this lawsuit, please contact Plaintiff’s lawyers listed below.
6. Do I have a lawyer in this case?
If you choose to join the lawsuit, you will be represented by Plaintiff’s counsel, Outten & Golden LLP and Fair Work P.C. Information about Plaintiff’s counsel is available at: https://www.outtengolden.com/ and https://www.fairworklaw.com/, and their contact information is listed in Section 7, below.
Plaintiff has entered into a contingency fee agreement with Plaintiff’s counsel, which means that if Plaintiff does not win, there will be no attorneys’ fees or costs chargeable. Under the fee agreement, in the event there is a recovery, Plaintiff’s counsel will apply to the Court for reimbursement of costs and expenses, and fees as a portion of any settlement obtained or money judgment entered in favor of the Plaintiff and the Collective in an amount the greater of: (1) the “lodestar” amount, calculated by multiplying reasonable hourly rates by the amount of time expended on the lawsuit; or (2) one-third of the gross settlement or judgment amount. Fees may be part of a settlement obtained or money judgment entered in favor of the Plaintiff or may be ordered by the Court to be separately paid by LinkSquares or may be a combination of the two.
7. Do I have a lawyer in this case?
If you have any questions, you may write, e-mail, or call Plaintiff’s counsel:
Melissa L. Stewart
Emma R. Janger
OUTTEN & GOLDEN LLP
695 Third Avenue, 25th Floor
New York, New York 10017
Telephone: : (347) 390-2104
linksquaresovertime@outtengolden.com
Hillary Schwab
FAIR WORK P.C.
192 South Street, Suite 450
Boston, MA 02111
Mikael Rojas
OUTTEN & GOLDEN LLP
1225 New York Ave NW, Suite 1200B
Washington, DC 20005
Telephone: : (347) 390-2104
linksquaresovertime@outtengolden.com
DATED: June 9, 2025