1. Why did I get a notice?
2. What do I do next?
3. What is the deadline to opt out?
4. Who is in the class?
5. Do I have a lawyer in this lawsuit?
6. What is this lawsuit about?
7. What are my options?
8. What are the consequences of doing nothing?
9. What If I don't want to be part of this case?
10. How do I opt out?
11. How can I get more information?
The Notice is to tell you about a class action lawsuit, Adam Ward v. Liberty Mutual Insurance Company, which was brought on behalf of people who received prerecorded calls on their cellular telephones, and/or people who received two or more calls or texts while their number was on the Do-Not-Call Registry, from or on behalf of Liberty Mutual between March 1, 2020, to June 30, 2020.
Notice has been sent to the best known physical and email address for the approximately 21,000 persons who belong to either or both classes. The Notice gives you information about the case and tells you how to opt out if you don’t want to be part of it.
This is an important legal document, and we recommend that you read all of it. If you have questions or need assistance, please go to the Important Documents section of this website or call (833) 421-7362.
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Read the Notice to understand the case and to determine if you are a class member. Then, decide if you want to stay in the case or opt out.
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The deadline to ask to be excluded from the case is September 14, 2026.
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The definition of the two classes that the Court approved are:
Pre-Recorded Voice Class: All persons in the United States or its territories (1) to whom Liberty Mutual placed, or caused to be placed, one or more call; (2) between March 1, 2020, to June 30, 2020; (3) to a number assigned to a cellular telephone service; (4) where Drips’ records indicate a prerecorded message played; and (5) the person’s phone number appears on the AWLI Spreadsheet; and:
National Do Not Call Registry Class: All persons in the United States or its territories who (1) received more than one call in a 12-month period; (2) by or on behalf of Liberty Mutual; (3) on a telephone number that appeared on the National Do Not Call Registry for at least 31 days at the time of the calls, (4) between March 1, 2020, and June 30, 2020; and (5) the person’s phone number appears on the AWLI Spreadsheet.
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In a class action, the Court appoints class representatives and lawyers to work on the case and represent the interests of all the class members. For purposes of the case, the Court has appointed the following lawyers as Class Counsel:
Your lawyers: The Court has appointed Max Morgan of The Weitz Firm, LLC; Jacob Ginsburg of Kimmel & Silverman, P.C. and Alex Burke of Burke Law Offices, LLC as counsel for the class. These are the lawyers who are bringing the case on your behalf. You will not be charged for their services, although their fees may be paid with the Court's approval from any judgment or settlement obtained on behalf of the class(es).
If you want to be represented by your own lawyer, you may hire one at your own expense.
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In 2024, Plaintiff Adam Ward filed this class action lawsuit, claiming that Liberty Mutual's telemarketing calls and text messages violated the Telephone Consumer Protection Act. Specifically, Ward alleged the calls which played pre-recorded messages to his cell phone violated 47 U.S.C. § 227(b)(1)(A)(iii) and alleges the calls and texts to his number despite registration on the National Do-Not-Call Registry violated 47 U.S.C. § 227(c)(5).
All persons in the classes were called by Liberty Mutual after Liberty acquired "leads" from its vendor All Web Leads, Inc.
The Court has not ruled in favor of either party on the issue of consent or any other substantive issue. However, if the Plaintiff prevails for the class, class members may recover between $500.00 and $1,500.00 per call or text message, as well as up to $500.00 and $1,500.00 per call for class members whose residential telephone numbers called were on the National Do Not Call Registry at the time of the calls.
Liberty Mutual contends that it had consent to make the calls and send the text messages at issue in this case. If Liberty can prove it had consent, this may constitute a complete bar to recovery for the class. The parties dispute whether Liberty Mutual can demonstrate that it had consent for its calls and text messages to the class members.
If you stay in the case, you will be bound by all of the Court's rulings going forward, regardless of whether the Plaintiff prevails or not.
Liberty Mutual denies that it did anything wrong.
The parties will continue to pursue legal action and prepare the case for trial, unless the two sides decide to settle the case.
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You have two options. You can do nothing and stay in the case, or you can opt out of the case.
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If you do nothing, you will be part of the case and your rights will be affected by the outcome. You won’t be able to start, continue, or be part of any other lawsuit against Liberty Mutual about the calls or text messages in this case.
If the consumers win, class members may be entitled to money. If Liberty Mutual wins, class members will receive nothing.
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You can opt out.
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If you do not want to be part of this case, you should complete the Opt Out Form online here by September 14, 2026. This is the easiest and best way to opt out.
You may also opt out by United States mail. To do so, download the Opt Out Form here, and put it in the mail so that it's postmarked by September 14, 2026, to:
Simpluris, Inc.
Re: Liberty TCPA Class Action
P.O. Box 26170
Santa Ana, CA 92799
If you opt out, Simpluris needs to know who you are and verify that you are actually a Class Member. Therefore, please be sure to include your name, address and current telephone number, as well as the telephone number you received calls or text messages from Liberty Mutual on, if different from your current telephone number, when submitting your opt-out.
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This website and the Notice summarize the certification decision. There are more details in the case documents. To get a copy of the case documents or get answers to your questions:
visit the Important Documents page of this website
access the Court Electronic Records (PACER) system online or by visiting the Clerk’s office of the Court (address below)
contact the lawyers who represent the class (information below)
Notice Administrator | Clerk’s office of the Court |
Simpluris, Inc. | United States District Court for the |
Class Counsel | ||
Max S. Morgan | Jacob U. Ginsburg | Alexander H. Burke |
Do not contact the Court or Clerk of Court regarding this Lawsuit
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