Plaintiffs Chris Figueroa and Curtis Cruz (“Plaintiffs”), on behalf of themselves and all others similarly situated, have a pending lawsuit in the Supreme Court of the State of New York, County of Nassau, entitled Chris Figueroa and Curtis Cruz v. Pret a Manger (USA) Limited, Index No. 610839/2025 (the “Lawsuit”). In the Lawsuit, Plaintiffs assert claims under the New York Labor Law and the New York City Administrative Code for failure to pay all wages owed to their employees including: straight pay, overtime time, Spread of Hours Pay, uniform maintenance pay, and shift change premiums. Pret denies these allegations and contends that it properly paid its employees at all times.

The Court has certified the Lawsuit to be a class action for settlement purposes only, and you have been identified as a member of the Class that has been certified (a “Class Member”). That is why you received the Notice. Pret has reviewed and investigated this matter and denies any wrongdoing. Nevertheless, Pret has decided to resolve the Lawsuit in order to avoid the expense of further litigation and the ongoing disruption to their business operations. Plaintiff and Pret have entered into a Settlement Agreement and Release (“Settlement Agreement”), which is available here.

If you elect to participate in the Settlement, you will be deemed a “Claimant.” Claimants shall receive an allocated share of the Settlement Fund pursuant to a calculation based on the Claimant’s classification as a “NYLL Class Member” or an “NYCFW Class Member”. “NYLL Class Members” means all of Defendant's nonexempt employees who worked in Pret stores in the State of New York at any time between February 15, 2019 and February 1, 2024. “NYCFW Class Members” means all of Defendant's nonexempt employees who worked in Pret stores in the City of New York at any time between July 22, 2021, and February 1, 2024. You may be categorized as both a “NYLL Class Member” and an “NYCFW Class Member”. In fact, all “NYCFW Class Members” ae also “NYLL Class Members.”