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YOU MAY BE ENTITLED TO RECEIVE A
VOUCHER OR ALTERNATIVE MONETARY PAYMENT
TO: Any and all California residents who purchased products at any of the four Domino’s locations in San Francisco: (a) 3116 Noriega Street, San Francisco, California 94116; (b) 320 Bayshore Blvd., San Francisco, California 94142; (c) 5200 Geary Blvd., San Francisco, California 94118; and (d) 728 Geary Street, San Francisco, California 94109. If you paid a six percent charge collected by these locations for San Francisco’s Health Care Security Ordinance (“HSCO”) between December 4, 2023 and August 12, 2026,
YOU SHOULD READ THE NOTICE CAREFULLY BECAUSE IT WILL AFFECT YOUR RIGHTS.
A settlement has been proposed in a class action lawsuit pending in the San Francisco County Superior Court for the State of California entitled Hayden Miller, et al., individually and on behalf of all others similarly situated, v. Asi Foods Inc., et al., San Francisco Superior Court Case No. CGC-25-630503 (the “Class Action”). The notice explains the nature of the lawsuit, the general terms of the proposed settlement, and your legal rights and obligations.
WHAT THE CLASS ACTION IS ABOUT
Plaintiffs in the Class Action filed a class action lawsuit against Asi Foods Inc., Aai Foods Inc. Ahi Foods Inc., Ari Foods Inc. (“Defendants”) which operate the Domino’s Pizza franchises at the above four locations. The Class Action alleges that Defendants charged a fee of six percent of an order paid by consumers associated with the San Francisco Health Care Security Ordinance but improperly identified the fee as a tax to consumers, and that this practice violated California law.
Defendants deny any wrongdoing and any liability whatsoever.
The Parties have concluded that it is in their best interests to settle the Class Action on the terms generally set forth herein in order to avoid expense, inconvenience, and interference with ongoing business operations.
A Judge of the San Francisco Superior Court has determined that the Class Action should proceed, for purposes of settlement only, with Plaintiffs as the representatives of the Class, and has granted preliminary approval of the settlement, subject to a final fairness hearing discussed below.
THE PROPOSED SETTLEMENT
Defendants no longer pass on the HSCO fee to consumers and have not done so since January 2026. Defendants have agreed that if the HSCO fee is passed on to consumers in the future, it will be clearly and conspicuously disclosed, though they deny that such modifications were necessary to comply with California law. Defendants have agreed to provide one of two alternatives to Class Members: (1) a Voucher in the amount of seventy-five percent (75%) of the HSCO fee paid during the class period; or (2) a Monetary Alternative in the form of a payment in the amount of fifty percent (50%) of the fee paid during the class period. The fee paid will be calculated based on records of your purchase history maintained by Defendants. The Voucher will only be valid at Defendant’s four Domino’s locations. For those Class Members for whom Defendants have a valid e-mail address, the Voucher will be sent as a default and automatically with no further action required by you. For those Class Members for whom Defendants have a valid e-mail address, but prefer the Monetary Alternative instead of a Voucher, you must timely file a valid Claim selecting the Monetary Alternative instead of the Voucher or else you will receive a Voucher. For those Class Members who did not provide a valid-email address when ordering, you must timely submit your proof of purchase(s) to the Claims Administrator at [email protected] or by mail to Miller v Asi Foods c/o Settlement Administrator, PO Box 23698, Jacksonville, FL 32241 and you will be provided a login to submit a Claim. Class members who lack internet access may contact Plaintiff’s counsel using the information set forth below for assistance in processing a claim.
Subject to Court approval, Class Representatives and named plaintiffs Hayden Miller, Abraham Barkhordar, and Daniel Baxter (“Class Representatives”) will seek an enhancement of up to $1,500 for their services as Class Representatives and their efforts in bringing the Class Action, and the attorneys for the Class (“Class Counsel”) will seek up to $200,000 for their attorneys’ fees and reimbursement of costs. The final decision regarding the amount of attorneys’ fees, costs, and enhancements that will be paid to Class Counsel and the Class Representative are subject to the discretion of the Court and the Court’s approval. Payment of attorneys’ fees, costs, or enhancement will not affect the benefits provided to the Class.