Notice of Proposed Class, Collective & Representative Action Settlement

A court authorized this Notice. This is not a solicitation from a lawyer.

This Notice may affect your rights. Please read this Notice carefully.

A Settlement has been proposed in a class, collective, and representative action pending in the Supreme Court of the State of New York, County of Nassau, titled Topping, et al. v. Drata Inc., Index No. 606167/2026. The lawsuit alleges that Drata Inc. (“Drata” or the “Company”) misclassified its Sales Development Representatives as exempt from overtime and, as a result, failed to pay overtime and other wages in violation of the Fair Labor Standards Act (“FLSA”) and California law, including the California Private Attorneys General Act (“PAGA”).

Drata denies and disputes the allegations and maintains that it complies with applicable laws in good faith. The Court has not decided who is right. To avoid the risk and expense of continued litigation, the Parties have agreed to the Settlement. Plaintiffs and their counsel believe the proposed Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class and Collective.

You do not need to submit a claim form to receive a payment. Your legal rights are affected whether you act or do not act. Please read this Notice carefully to understand your rights and options.

1. Why did I get this Notice?

You received this Notice because Drata’s records show that you worked as a Sales Development Representative for Drata and are a member of the proposed Settlement Class or Collective. This Notice summarizes the terms of the Settlement and explains your rights and options before the Court decides whether to give final approval.

A Court authorized this Notice. The lawsuit is titled Topping, et al. v. Drata Inc. and is pending in the Supreme Court of the State of New York, County of Nassau, Index No. 606167/2026. The people who filed the lawsuit are the “Plaintiffs,” and Drata Inc. is the “Defendant” or the “Company.” The Plaintiffs and Drata have agreed to resolve the lawsuit through this Settlement.

2. What is this lawsuit about?

Several former Drata employees, called Plaintiffs, filed an action claiming that the Company misclassified Sales Development Representatives as “exempt” from overtime laws. Plaintiffs allege that the Company failed to pay overtime wages; failed to provide required meal and rest breaks or premium payments in lieu thereof; failed to pay wages timely during employment and at separation; failed to pay all wages owed; failed to provide legally compliant wage statements; failed to maintain accurate wage records; and failed to reimburse necessary business expenses in accordance with California state law. Two Plaintiffs also alleged claims for penalties under the California Private Attorneys General Act of 2004 (“PAGA”).

Drata denies and disputes these allegations and maintains that it complies with applicable laws in good faith. The Court has not decided this case in favor of either side. Both sides have agreed to resolve the claims to avoid the risk and expense of litigation.

3. Why is this a class and collective action?

In a class or collective action, one or more people called “Plaintiffs” (here, Madison De La Cruz, William Hubert, Parker Kendle, Christopher Lieu, DeAvin Rencher, Daniel Rovick, Ethan Rovick, Maclaine Scher, and Gabriel Topping) bring a lawsuit on behalf of themselves and other people with similar legal claims. The California employees are the “Settlement Class,” and the Sales Development Representatives employed outside California are the “Settlement Collective.”

4. Why is there a Settlement?

The Court has not decided in favor of the Plaintiffs or Drata. The Parties have agreed to the Settlement to avoid the costs and uncertainty of a trial. If the Court approves the Settlement, eligible Settlement Class and Collective Members will receive the payments described in this Notice. The proposed Settlement does not mean that Drata did anything wrong. Drata denies all allegations and maintains that it did not engage in any wrongdoing. Plaintiffs and their counsel believe the proposed Settlement is fair, reasonable, adequate, and in the best interests of the Settlement Class and Collective.

6. What does the Settlement provide?

Drata has agreed to pay $1,300,000 into a Settlement fund (the “Gross Settlement Amount”). This money will be divided among the Settlement Class and Collective Members and will also be used to pay any Court-approved attorneys’ fees and costs, any Court-approved service payments to the Plaintiffs who filed the lawsuit (up to $7,500 each, or $67,500 in total), the amount allocated under PAGA to the State of California ($22,600, of which $14,690 will be paid to the California Labor and Workforce Development Agency), and the costs of Settlement administration. In no event will unclaimed funds revert to Drata.

Members of the Settlement Class and Collective will “release” their claims as part of the Settlement, which means they cannot sue Drata for the same issues or claims raised by the lawsuit. The full terms of the release are in the Settlement Agreement, available on the Case Documents page.

7. How was my estimated payment calculated?

The calculation of your payment depends on your total compensation as a Sales Development Representative and the number of weeks you worked in an eligible role during the relevant period. The Settlement Administrator used information from Drata’s records to calculate your individual payment based on your eligible weeks worked. Eligible employees who worked in California received a higher amount for each week worked than employees who worked in other states, because there are more claims alleged under California law than under federal law alone.

8. How will my payment be taxed?

For California Settlement Class Members, one half (1/2) of your individual Settlement payment is treated as wages (subject to tax withholdings and reported on IRS Form W-2) and one half (1/2) is treated as non-wage compensation (no taxes withheld, reported on IRS Form 1099). For Settlement Collective Members, one third (1/3) is treated as wages (Form W-2) and two thirds (2/3) is treated as non-wage compensation (Form 1099). The Settlement Administrator and the lawyers in the case cannot advise you on taxes. Please seek your own personal tax advice.

12. Do I have a lawyer in this case?

The Court has preliminarily approved lawyers from the following firms as Class Counsel to represent you and the other Settlement Class and Collective Members: Outten & Golden LLP and Werman Salas P.C. These are the lawyers who negotiated the Settlement on behalf of the Class and Collective. You will not be charged for their services. If you prefer, you may hire your own lawyer at your own expense.

You may contact Class Counsel if you have any questions about this Notice or the Settlement. Please do not contact the Court with questions about the Settlement.

Class Counsel:

Melissa L. Stewart · Amy L. Maurer
Outten & Golden LLP
685 Third Avenue, 25th Floor
New York, NY 10017

Maureen Salas · Anne Kramer
Werman Salas P.C.
77 W. Washington St., Ste. 1402
Chicago, IL 60602

13. How will Class Counsel be paid?

To date, Class Counsel has not been paid any money for their work or the expenses they have advanced. As part of the final approval of this Settlement, Class Counsel will ask the Court to approve a payment of up to one-third of the Settlement fund, or $433,333.33 in attorneys’ fees, plus reimbursement of out-of-pocket costs. Class Counsel will also request service awards of up to $7,500 for each of the nine Plaintiffs ($67,500 in total). These amounts will be paid from the Settlement fund and will only be awarded if approved by the Court. The Court may award less than the amounts requested.

You may tell the Court that you object to the Settlement or any part of it. You may object only if you remain in the Settlement Class.

15. How do I tell the Court that I disagree with the Settlement?

If you disagree with any part of the Settlement, you may object. You must give the reasons why you think the Court should not approve it and say whether your objection applies to just you, a part of the class, or the entire class. The Court will consider your views. The Court can only approve or deny the Settlement — it cannot change its terms. You may, but are not required to, hire your own lawyer at your own expense.

To object, you must mail a letter to the Settlement Administrator (at the address on the Contact page) that:

• Is postmarked by the Bar Date (TBD);
• Includes your full name, address, and telephone number;
• States all the reasons for your objection and any supporting documentation; and
• Includes your signature.

Submitting an objection does not exclude you from the Settlement, and you may still receive a payment.

16. What is the difference between opting out and objecting?

Opting out is telling the Court that you do not want to be part of the Settlement Class. If you opt out, you cannot object, because the Settlement no longer affects you. Objecting is telling the Court that you do not like something about the Settlement. You can object only if you stay in the Settlement Class.

18. How do I get more information?

This Notice summarizes the proposed Settlement. More details are in the Settlement Agreement, which is available on the Case Documents page. You may also contact the Settlement Administrator or Class Counsel using the information on the Contact page.

PLEASE DO NOT CONTACT THE COURT OR THE COURT CLERK’S OFFICE REGARDING THIS NOTICE OR THE SETTLEMENT.