ZK Technology BIPA Class Action Settlement

Only AGI workers in Illinois. Alliance Ground International (AGI) workers who scanned a finger or face on an AGI timeclock in Illinois are the entire class — and union members are cut out. This $635,160 fund resolves Roman v. ZK Technology LLC, No. 2022-CH-06727 in the Circuit Court of Cook County, along with a companion federal case of the same name, No. 23-cv-15058 (N.D. Ill.). ZK Technology is the timeclock vendor and the named Defendant; AGI is the employer. The Class is effectively a closed list of 1,608 people who were mailed a notice — the online claim form is a login page that will not open without the Login ID and PIN printed on that notice. The single biggest catch is not in the official notice at all: paragraph 50 of the Settlement Agreement excludes anyone who was a member of a collective bargaining agreement, along with anyone who already signed a BIPA release. AGI is an aviation ground-handling company, so that union exclusion is likely to remove a real share of the workforce — yet the notice's own class definition and FAQ never mention it. The notice estimates $800 to $2,000 per claimant, but $2,000 is a hard cap and $800 is not a floor: strip the 38% attorneys' fee and the $5,000 service award out of the fund and about $388,799 remains for 1,608 people, or roughly $242 apiece if they all file. Administration expenses come out too, with no cap written anywhere. Claims close November 10, 2026; opting out or objecting closes earlier, on October 23, 2026.

Do I Qualify?

You may be eligible if:

• You worked for Alliance Ground International, LLC (AGI) — not for ZK Technology, which is the timeclock vendor and the named Defendant
• You scanned your finger or your face on AGI's finger-scan or face-scan timekeeping system
• You did that scanning while working for AGI in the State of Illinois — an AGI station in another state does not count
• The scan happened at some point between September 2020 and August 12, 2026, the date the notice fixes as the close of the class period
• Consent was never obtained from you to share your biometric information with ZK Technology
• You are NOT eligible if you were a member of a collective bargaining agreement — this union exclusion is in paragraph 50 of the Settlement Agreement and on the claim-form login page, but it is missing from the mailed notice's class definition and from FAQ 4
• You are NOT eligible if you executed a release pursuant to BIPA, or if you already released these claims in a Related Action that was dismissed before this Agreement's Effective Date
• You are NOT eligible if you opt out by October 23, 2026, or if you are the judge, court staff assigned to the case, or their immediate family
• Practical gate: the Settlement Agreement says the Class is 1,608 individuals, all of whom were mailed a notice. Filing online requires the Login ID and PIN from that notice, so you cannot simply add yourself
• Using a ZK Technology or ZKTeco timeclock at some other employer does not put you in this Class

No receipts, pay stubs or employment records are required — but you do need the Login ID and PIN from the notice that was mailed to you. The online claim form at ZKBIPASettlement.com is a login page, and it will not open without both credentials. That is the real gate on this settlement: the administrator mailed notices to the 1,608 people on the Class List, and the credentials come from that mailing. If you never received a notice or cannot find it, email info@ZKBIPASettlement.com with your full name and mailing address to have your Login ID and PIN resent, or call (888) 406-0864 toll free, 24/7. A paper Claim Form can be downloaded from the settlement website's Important Documents page and mailed instead, postmarked by November 10, 2026 — its instructions also ask for the Login ID. You do have to sign a certification on the form, and you may submit only one claim, online or on paper, however many times you scanned in. If you requested exclusion, do not file a claim.

What Happened?

The Illinois Biometric Information Privacy Act (BIPA), 740 ILCS 14/1 et seq., bars a private company from capturing, obtaining, storing, transferring or using someone's fingerprint or facial geometry — for any purpose, timekeeping included — without first giving written disclosures and obtaining written consent.

Hugo Roman sued ZK Technology LLC, which supplied the finger-scan and face-scan timeclocks that Alliance Ground International, LLC used to track its workers' hours. The lawsuit alleges ZK Technology took in AGI workers' fingerprint and face-geometry data without the written disclosures and consent BIPA requires. ZK Technology contests the claims and denies violating BIPA, and the Court has not decided who is right — the settlement is not an admission of wrongdoing.

One settlement resolves two parallel cases: Hugo Roman v. ZK Technology LLC, No. 2022-CH-06727, before Judge Joel Chupack in the Circuit Court of Cook County, and a federal case with the same caption, No. 23-cv-15058, before Judge Joan H. Lefkow in the Northern District of Illinois. It resolves claims against ZK Technology, against AGI, and against their affiliated entities.

ZK Technology agreed to fund $635,160 — which is exactly 1,608 Class Members times $395 a head. The Agreement adjusts that figure by $395 per person if the final Class List comes in above 1,700 or below 1,500. Each valid claimant takes an equal, pro rata share of what is left after attorneys' fees of up to 38%, counsel's costs and expenses, a Service Award of up to $5,000, and uncapped administration expenses, subject to a hard $2,000 ceiling per approved claim.

The exclusions matter more here than the headline number. Paragraph 50 of the Settlement Agreement writes four groups out of the Class, and the broadest of them — anyone who was a member of a collective bargaining agreement — never appears in the Long Form Notice's class definition (Question 5) or in FAQ 4 on the settlement website. It surfaces only in the Agreement itself and on the claim-form login page. Aviation ground handling is heavily union-represented work, so an AGI worker reading the mailed notice could reasonably file a claim without ever learning they may be excluded.

The Court granted preliminary approval and conditionally certified the Class for settlement purposes only. The final approval hearing is set for November 23, 2026 at 9:30 a.m. in Courtroom 2601 of the Circuit Court of Cook County in Chicago, with Zoom access. Nothing is paid unless the Court grants final approval, and an appeal would push payment out further.

The court-appointed administrator is Simpluris. Class Counsel are Evan M. Meyers, Jordan R. Frysinger, Joseph M. Dunklin and Donald S. Cuba II of McGuire Law, P.C. in Chicago; ZK Technology is represented by Jacob Radecki of McDonald Hopkins LLC.

How to File Your Claim

1. You must submit a Claim Form by November 10, 2026 — that is the only way to be paid, and it is the only thing you need to do
2. Online: go to the official settlement website at ZKBIPASettlement.com and open the claim form, which is a login page — it will not open without the Login ID and PIN printed on the notice mailed to you
3. Lost or never received your notice? Email info@ZKBIPASettlement.com with your full name and mailing address and ask the administrator to resend your Login ID and PIN, or call (888) 406-0864 toll free, 24/7
4. By mail: download the paper Claim Form from the Important Documents page of the settlement website, or use the one attached to the postcard notice, and mail it to Roman v. ZK Technology LLC, c/o Settlement Administrator, P.O. Box 25226, Santa Ana, CA 92799 — it must be postmarked no later than November 10, 2026
5. One claim per person, online or on paper, no matter how many times you scanned in
6. On the form you state a preferred payment method: a paper check, or an electronic payment such as PayPal, Venmo or Zelle. This sets how you are paid, not how much
7. HEADS UP, AN EARLIER DEADLINE: requests to opt out and written objections are due October 23, 2026, more than two weeks before the claim deadline. Objections go to the Clerk of the Circuit Court of Cook County, 50 West Washington Street, Suite 1001, Chicago, IL 60602, with copies to Class Counsel and Defendant's counsel
8. Final approval hearing: November 23, 2026 at 9:30 a.m. in Courtroom 2601, Circuit Court of Cook County, Chicago, and by Zoom (Meeting ID 940 2104 4687, passcode 296476). The date can change — check the settlement website
9. Visit the official claim form: https://zkbipasettlement.com/

How Much Will I Actually Get?

THE $800 FIGURE IS AN ESTIMATE, NOT A FLOOR. Every valid claimant receives an equal, pro rata share of the $635,160 Settlement Fund, and the official notice estimates that share at $800 to $2,000 per person. But the $2,000 is a hard ceiling written into the Settlement Agreement and the $800 is not a guaranteed minimum — the Agreement caps the net payment at $2,000 per approved claim and says nothing about a floor. The actual number depends on how many valid claims come in, and the notice says so. THE FUND IS GROSS. Deducted before anything is divided: Class Counsel's attorneys' fees of up to 38% of the fund (up to $241,360.80) plus their costs and expenses, a Service Award of up to $5,000 for the Class Representative, and settlement administration expenses. Note what the 38% actually covers — it caps the attorneys' fee alone. Counsel's costs and expenses are on top of it, and the administration expenses carry NO stated cap anywhere in the Settlement Agreement. DO THE ARITHMETIC ON THE PUBLISHED NUMBERS. Take the $635,160 fund, subtract the full 38% fee ($241,360.80) and the $5,000 service award, and $388,799.20 is left before any administration expenses. The Settlement Agreement puts the Class at 1,608 people. If every one of them filed, that works out to roughly $242 each — well under the $800 the notice estimates. For the estimate to hold, only about 486 of the 1,608 (under a third of the class) can file; to reach the $2,000 cap, only about 194 can. Those are our calculations from the figures the notice and Agreement publish, not numbers the administrator has endorsed, and administration expenses would push all of them lower. The fund itself can move: it rises by $395 for each Class Member above 1,700 on the final Class List and falls by $395 for each one below 1,500. At the stated 1,608 it stays at $635,160. Payment goes out about 28 days after the settlement becomes effective under the Settlement Agreement, though the mailed notice says approximately 45 days after final approval — the official documents differ on this. An appeal would delay it further. Paper checks expire and go void 120 days after they are issued. Money from uncashed checks is redistributed to claimants who did cash if that is administratively practical, and anything still unclaimed after that goes as cy pres to Illinois Legal Aid Online, not back to claimants.

Last reviewed: September 28, 2026 | Information verified from court records and official settlement documents.

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