1. What is the Notice and why should I read it?
2. What is a class action lawsuit?
3. What is this lawsuit about?
4. Why is there a Settlement?
5. How do I know if I am in the Settlement Class?
6. What does the Settlement provide?
7. How do I request to receive a payment?
8. When will I get my payment?
9. Will Defendants retaliate against me if I participate in the Settlement?
10. Do I have an attorney in this case?
11. How will Class Counsel and the Class Representative be paid?
12. What claims do I give up by participating in this Settlement?
13. What happens if I do nothing?
14. What happens if I request to be excluded?
15. How do I request to be excluded?
16. If I don't exclude myself, can I sue Defendants for the same thing later?
17. If I exclude myself, can I get anything from this Settlement?
18. How do I object to the Settlement?
19. What's the difference between objecting and excluding myself from the Settlement?
20. When and where will the Court hold a hearing on the fairness of the Settlement?
21. Do I have to come to the hearing?
22. May I speak at the hearing?
23. Where can I get additional information?
The Court authorized the Notice to inform you about a proposed Settlement with Defendants. You have legal rights and options you may act on before the Court decides whether to approve the proposed Settlement. You may be eligible to receive a cash payment as part of the Settlement. The Notice explains the Lawsuit, the Class Action Settlement Agreement ("Settlement Agreement"), and your legal rights. Judge Taki Flevaris of King County Superior Court is overseeing the Settlement of this Lawsuit. Shannon Spencer is the Plaintiff or Class Representative. Defendants are Siemens Corporation; Siemens Industry, Inc.; Siemens Industry Software Inc.; Siemens Medical Solutions USA, Inc.; Siemens Financial Services, Inc.; and Siemens Mobility, Inc.
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A class action is a lawsuit in which one or more plaintiffs sue on behalf of a group of people who have allegedly similar claims. Together, this group is called a "Settlement Class" and consists of "Settlement Class Members." In a class action, the court resolves the issues for all class members, except those who specifically comply with the instructions for excluding themselves from (or opting out of) the class.
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Plaintiff claims that Defendants violated Washington law, RCW 49.58.110, when they allegedly did not disclose required information (including but not limited to the wage scale or salary range being offered) on authorized job postings for open positions. Defendants deny that they (a) violated any federal, state, or local law in any manner; (b) are, or can be, held liable for the claims made in the Lawsuit; and (c) are joint employers with any other entity. Further, the Court has not made any determination that any Plaintiff or Class Member is entitled to any payment or that Defendants violated any federal, state, or local law in any manner.
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The Court has not decided whether Plaintiff or Defendants should win this lawsuit. Instead, the Parties agreed to this Settlement to avoid the uncertainty, risks, time, and expense of ongoing litigation, and to allow Settlement Class Members the opportunity to get compensation now rather than years later---if ever. Plaintiff and Class Counsel (the attorneys for the Settlement Class Members) agree the Settlement is in the best interests of the Settlement Class.
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Defendants' records show you are part of the Settlement Class because you are lawfully available, reside in the United States currently and at the time the alleged application was submitted, were and currently are legally eligible to work in the United States, you applied for an open job in the State of Washington with one or more of Defendants between January 1, 2023 and June 24, 2025 (the "Settlement Class Period"), you did not voluntarily withdraw from the hiring process, and the authorized job posting through which you applied did not disclose the wage scale or salary range for the position when you applied.
If you are still not sure whether you are included, you can contact the Settlement Administrator by calling toll-free at 1-833-360-6892 or emailing info@SEPOASettlement.com.
Anyone who believes he or she should have been included in the Settlement Class, but who did not receive a copy of the Notice, must contact the Settlement Administrator immediately.
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All Settlement Class Members who submit a timely, valid Claim Form are eligible to receive an equal share of the Class Fund, up to a maximum of $5,000.00. Your estimated payment amount is included on the Claim Form you received with this Notice.
Settlement payments will be characterized as non-wage damages (reported on an IRS Form 1099).
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To qualify for a settlement payment, you must complete the Claim Form and submit it by email or mail, postmarked on or before September 29, 2025, to:
Spencer v. Siemens Corporation et al.
c/o Simpluris, Inc.
P.O. Box 26170
Santa Ana, CA 92799
info@SEPOASettlement.com
You can also complete your claim form online on the website using your Unique ID and PIN.
Claims will be subject to a verification process. All Claim Forms must be submitted or postmarked on or before September 29, 2025.
To ensure you receive your payment, you must contact the Settlement Administrator if your address or phone number changes at any time.
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The Final Approval Hearing (the hearing to consider the fairness of the Settlement) is scheduled for November 21, 2025, at 9:00 a.m. If the Court approves the Settlement, eligible Settlement Class Members who submitted timely, valid Claim Forms will be mailed Settlement Checks after all appeals and other reviews, if any, are completed. Please be patient. Please also note that all checks will expire and become void 180 days after the date of issuance.
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No. Defendants support the Settlement and will not retaliate in any way against any Settlement Class Member for participating in, objecting to, or opting out of the Settlement. Your decision to participate, not participate, or object to the Settlement will not affect any current or future application for employment or employment with Defendants.
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Yes, the Court appointed Timothy Emery, Patrick B. Reddy, and Paul Cipriani of Emery Reddy, PLLC as Class Counsel to represent the Settlement Class. Their contact information is:
Emery Reddy, PLLC
600 Stewart Street
Suite 1100
Seattle, WA 98101
Phone: (206) 442-9106
Should I get my own attorney? You don't need to hire your own attorney because Class Counsel are working on your behalf. These attorneys and their firm are experienced in handling similar cases. You will not be charged for these attorneys. You can ask your own attorney to appear in Court for you, at your own cost, if you want someone other than Class Counsel to represent you.
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Class Counsel will ask the Court to approve, and Defendants agree not to oppose, an award of attorneys' fees in the amount of $1,032,500.00, plus costs and expenses of $5,000.00, to be paid from the Settlement Fund. Class Counsel also will request a service award payment for Plaintiff in an amount of $25,000.00, to be paid from the Settlement Fund. The Court will determine the proper amount of any attorneys' fees, costs, and expenses to award Class Counsel and the proper amount of any service award for Plaintiff. The Court may award less than the amounts requested. Whether the Settlement will be finally approved, and payments to any Class Members will be made, does not depend on whether or how much the Court awards in attorneys' fees, costs, and expenses, or the service award.
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If the Court approves the Settlement, the Court will enter a final judgment dismissing the Lawsuit "with prejudice." This means that all of the claims in the Lawsuit will be permanently dismissed. Specifically, Defendants will be "released" from claims as described in Paragraph 20 of the Settlement Agreement, which states that:
Upon final approval of this Settlement Agreement by the Court and provided the Settlement Class Member does not submit a timely, valid request for exclusion in accordance with the procedures set forth in Paragraph 15(b), each Settlement Class Member (including but not limited to their respective heirs, descendants, dependents, executors, administrators, successors, and assigns ("Releasors")) will be deemed for all purposes to have fully and finally released, waived, and forever discharged (a) Defendants; (b) Defendants' present and former parents, subsidiaries, siblings, and affiliates (including, without limitation, Siemens Advanta Solutions Corp., Siemens Energy Demag Delaval Turbomachinery, Inc., Siemens Energy Generation Services Company, Siemens Energy Staffing, Inc., Siemens Energy, Inc., Siemens Gamesa Renewable Energy, Inc., Siemens Government Technologies, Inc., Siemens Healthcare Diagnostics Inc., and Siemens Logistics, LLC); (c) Defendants' and all preceding entities' divisions, members, joint venture partners, predecessors, successors, and merged entity or entities; (d) Defendants' and all preceding entities' present and former officers, partners, directors, employees, agents, attorneys, shareholders, insurers or reinsurers, employee benefit plans (and the trustees, administrators, fiduciaries, agents, representatives, insurers and reinsurers of such plans), assigns, trustees, heirs, administrators, executors, representatives and/or principals thereof, (e) Defendants and all persons or entities acting by, through, under, or in concert with any of the Defendants, all preceding entities, or all preceding individuals, and (f) any Defendants, individual, or entity that could ever arguably, allegedly, or potentially be deemed jointly liable with any of Defendants, all preceding entities, or all preceding individuals (collectively, the "Releasees"), of and from any and all claims including, but not limited to those arising out of or relating to a violation of RCW 49.58.110 (or similar federal, state, or local law), and any attendant claims for relief under RCW 49.58.070 (or similar federal, state, or local law), such as interest, liquidated damages, exemplary damages, statutory damages, and attorneys' fees and costs, that arose during the Settlement Class Period, including but not limited to the claims that were or could have been asserted against Defendants or Releasees by Plaintiff and members of the Settlement Class in the Complaint (the "Released Class Claims"). This Settlement is intended to include in its effect all claims identified in this Paragraph, even if Plaintiff, the Settlement Class Members, or the Releasors (individually or collectively) do not know or suspect they exist. Plaintiff, the Settlement Class Members, and the Releasors further covenant that they will not participate in any other lawsuit or legal action against Defendants or the Releasees for the Released Class Claims released by this Settlement Agreement, and will dismiss, or exclude or withdraw themselves from, any matter or class action of which they become aware that is asserting Released Class Claims released by this Settlement Agreement.
By being part of the settlement, Settlement Class Members agree that they cannot sue or seek recovery against Defendants or other Released Parties as described in the Settlement Agreement for any released claims.
Participating in the Settlement does not waive claims outside the release. Any potential Settlement Class member who does not request exclusion from (or to opt out of) the Settlement by the applicable deadline will be a Settlement Class Member and will be considered to have accepted this release and to have waived any and all of the released claims against Defendants and the Releasees on behalf of themselves and the Releasors. Any potential Settlement Class Member who requests exclusion from (or who opts out of) the Settlement by the applicable deadline will not be a Settlement Class Member, will not be subject to the release, and will not receive any payment.
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If you do nothing, you will receive no payment under the Settlement. You will still be in the Settlement Class, and, if the Court approves the Settlement, you will be bound by all orders and judgments of the Court, and the Settlement Agreement, including its release of claims against Defendants and the Releasees. You will be deemed to have participated in the settlement and will be subject to the provisions of Section 12 above (and Paragraph 20 of the Settlement Agreement). Unless you exclude yourself (or opt out), neither you nor the Releasors will be able to file a lawsuit or be part of any other lawsuit against Defendants or the Releasees for the claims or legal issues resolved in this Settlement.
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If you submit a timely, valid request for exclusion from the Settlement, you will receive no benefits or payment under the Settlement, you will not be in the Settlement Class, you will not release any claims against Defendants, and you will not be legally bound by the Court's judgments in this Lawsuit.
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To request to be excluded (or to opt out of) the settlement, you must send a letter, postmarked no later than September 29, 2025, to the Settlement Administrator at the following address:
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No. Unless you exclude yourself, you and your Releasors give up any and all rights to sue Defendants or the Releasees for the claims resolved by this Settlement even if you do not submit a Claim Form.
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No. If you exclude yourself (opt out), you will not be entitled to any payment under this Settlement. You must not submit a Claim Form to ask for a payment if you exclude yourself or opt out of the Settlement.
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If you do not exclude yourself from the Settlement Class, you can object to the Settlement if you disagree with any part of it. You can give reasons why you think the Court should deny approval of the Settlement, in whole or in part, by filing an objection. To object, you must file written notice with the Court stating that you object to the Settlement in Spencer v. Siemens Corporation, et al., no later than September 29, 2025. Your objection must be filed with the Court, which you can do by mailing your objection and any supporting documents to King County Superior Court at the following address:
| Class Counsel | Defendant's Counsel |
| Timothy W. Emery Patrick B. Reddy Paul Cipriani Emery Reddy, PLLC 600 Stewart Street, Suite 1100 Seattle, WA 98101 | Jack Blum Denise K. Drake Clayton Nedza Polsinelli PC 900 W 48th Place, Suite 900 Kansas City, MO 64112 Jane Pearson Jessica Andrade Polsinelli PC 1000 Second Avenue, Suite 3500 Seattle WA 98104 |
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Objecting is simply telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class.
Excluding yourself from the Settlement Class tells the Court that you do not want to be part of the Settlement Class and you do not want to receive any payment from this Settlement. If you exclude yourself, you have no basis to object because this case and Settlement no longer affect you.
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The Court scheduled the Final Approval Hearing for November 21, 2025, at 9:00 a.m. in King County Superior Court, Maleng Regional Justice Center, 401 4th Avenue N, Room 4F, Kent, Washington 98032.
The purpose of the hearing is for the Court to determine whether the Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class. At the hearing, the Court will hear any objections and arguments concerning the fairness of the proposed Settlement, including those related to the amount requested by Class Counsel for attorneys' fees, costs, and expenses and the Plaintiff's service award.
Note: The date and time of the Final Approval Hearing are subject to change by Court order. Any changes will be posted on this Settlement Website, or through the Court's publicly available docket. You should check this Settlement Website or the Court's docket to confirm the date and time have not been changed.
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No. Class Counsel will answer any questions the Court may have, but you are welcome to attend the hearing at your own expense. If you file an objection, you do not have to come to the hearing to talk about it. As long as your written objection was filed or mailed on time and meets the other criteria described in the Settlement, the Court will consider it. You may hire an attorney to assist you, or to attend the hearing on your behalf, at your own expense, but this is not required.
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Yes. If you do not exclude yourself (opt out) from the Settlement Class, you may ask the Court for permission to speak at the Final Approval Hearing, concerning any part of the proposed Settlement.
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This website and the Notice summarize the proposed settlement. More details are in the Settlement Agreement, which is available here.
You may contact the Settlement Administrator by phone, email, or in writing at:
Spencer v. Siemens Corporation et al.
c/o Simpluris, Inc.
P.O. Box 26170
Santa Ana, CA 92799
(833) 360-6892
info@SEPOASettlement.com
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