Long v. Juniper Networks (US), Inc.

Superior Court of California County of Santa Clara
Case No. 22CV396462

On March 26, 2025, the Honorable Theodore C. Zayner of the Superior Court of Santa Clara County granted preliminary approval of a proposed settlement of a class and collective action lawsuit against Juniper. The Court has authorized the dissemination of the Notice previously mailed to you to inform Settlement Collective Members of their options under the Settlement.

You received the Collective Notice because Juniper’s records indicate that you were employed in one of the designated exempt commissioned sales roles in the United States outside of the state of California from September 7, 2019, through March 13, 2023

Juniper has denied and continues to deny the factual and legal allegations in the lawsuit and believes that it has valid defenses to the claims. By agreeing to settle, Juniper is not admitting either liability, the truth of any factual allegations, or that the lawsuit can or should proceed as a class action. The Parties entered into this settlement solely with the intention to avoid further disputes and the inconvenience and expense of litigation. The Court has not made any final ruling on the merits of the claims, and no party has prevailed in this action.

Settlement Collective Members must make a choice now, which will affect their legal rights.

Your Legal Rights and Options

Opt In

You can opt in to the FLSA claims and Settlement by returning the Opt-In Consent Form, previously mailed to you, via U.S. mail no later than June 21, 2025. Once you opt in, you are part of the FLSA Settlement Collective and the Settlement and will be bound by the release applicable to the FLSA claims in the Action, and your Opt-In will be filed with the Court.

You can also complete your Opt-In Consent Form online here using your Unique ID and PIN.

If you fail to return the Opt-In Consent Form by the deadline listed above, you will forfeit your estimated payment from the Net Settlement Amount listed below, and it will return to Juniper.

As an FLSA Collective Member, you will be represented by the attorneys for Plaintiffs and the FLSA Collective Members (“Class Counsel”) and will not be charged for their services.

Do Nothing

If you do nothing, meaning you do not take action to opt into the Settlement by June 21, 2025, you will be excluded from the FLSA claims and Settlement. If you do not opt in, you will not be bound by the release applicable to the FLSA claims in the Action, and you will not give up your right to sue the parties being released for any of the released FLSA claims.

If you have also received a separate Notice of Class Action Settlement, whether you opt in to the FLSA Settlement Collective and Settlement will not impact your rights to participate in the Settlement as a Class Member and/or a PAGA Member.

Object

You may object to the Settlement with respect to the FLSA claims in the Action by mailing a written objection to the Settlement Administrator at the address below by June 21, 2025. If you object and do not opt into the Settlement, you will be excluded from the FLSA claims and Settlement, will not be bound by the release applicable to the FLSA claims in the Action, and will not receive a check.

The procedures for opting in and objecting are set forth in the sections entitled “How do I opt in to the FLSA Action?” and “How do I object?

These rights and options—and the deadlines to exercise them—are set forth on the FAQs page.

The Court in charge of this case still has to decide whether to approve the Settlement. Payments will be made if the Court approves the Settlement and after any appeals are resolved.

Upcoming Important Dates

Objection Deadline

6/21/2025

Opt In Deadline

6/21/2025

Dispute Deadline

6/21/2025

Final Approval Hearing

10/22/2025 at 2:30 p.m.