Frequently Asked Questions

You received a notice to inform you of a proposed class action settlement in Khanal v. San Francisco Hilton, Inc., Case No. 4:14-cv-01523-JSW (U.S. District Court for the Northern District of California) (the “Action”). Plaintiff Baikuntha Khanal (“Plaintiff”) on behalf of himself and members of the certified class in the Action and Defendant Hilton Management LLC (“Defendant” or “Hilton”), have entered into a settlement agreement to effect a full and final settlement and preclusive judgment resolving all claims brought against Hilton in the Action. This notice describes the terms of the parties’ agreement. You do not need to take any action to receive payment under this settlement.

This case was filed in 2014 as a class action on behalf of non-managerial banquet service employees who worked at the San Francisco Union Square Hilton hotel, contending that Hilton should have paid such banquet service employees the full amount of the banquet food and beverage service charges added to banquet bills. Plaintiff contended that reasonable banquet customers would have understood these service charges to be gratuities that must be paid to service employees under California law. Hilton strongly denies violating any laws or failing to pay any wages and contends it complied with all applicable laws. The Court has made no determination whether Hilton or Plaintiff are correct on the merits. The Court certified this case as a class action on January 3, 2022, and notice of the class action was sent to class members shortly thereafter. Following lengthy litigation, and on the verge of a trial, the parties mediated and reached a proposed settlement of this case. The settlement is conditioned upon court approval.

Under the settlement, Hilton will pay $12,000,000 (the “Gross Settlement Amount”). Plaintiff will request that the court award 25% of the Gross Settlement Amount to pay attorneys’ fees incurred by counsel for bringing and prosecuting the lawsuit. In addition, Plaintiff will request that the court reimburse counsel for costs incurred in the case (not to exceed $150,000) and approve a service award for the named plaintiff, Baikuntha Khanal, in the amount of $20,000. Plaintiff will also request that the costs of the Settlement Administrator, which are estimated to be $19,380, be paid from the Gross Settlement Amount. Any amounts allocated to individuals who opt out of settlement shall be retained in a separate fund to facilitate the resolution of the claims of opt outs.

For the precise terms of the settlement, please see the settlement agreement, contact class counsel, or access the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov, or by visiting the office of the Clerk of the Court for the United States District Court for the Northern District of California, 1301 Clay Street, Oakland, CA 94612, between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.

To receive a settlement payment, you do not need to do anything.

If you disagree with the settlement, you have two options.

First, you may choose to opt out of the settlement class. If you opt out, you will not be bound by the settlement and will be free to bring your own claims against Hilton, but you will not receive any of the payments under the settlement or its other benefits. To opt out, you must send a letter to the Settlement Administrator at the address listed here. That letter must include your name, your address, and your telephone number and must state that you choose to opt out of the settlement. This letter must be postmarked no later than June 23, 2026 for it to be effective.

Second, you may remain in the settlement class but ask the Court to deny approval by filing an objection. You can’t ask the Court to order a different settlement; the Court can only approve or reject the settlement. If the Court denies approval, no settlement payments will be sent out, and the lawsuit will continue. If that is what you want to happen, you should object.

Any objection to the proposed settlement must be in writing. If you file a timely written objection, you may, but are not required to, appear at the Final Approval Hearing, either in person or through your own attorney. If you appear through your own attorney, you are responsible for hiring and paying that attorney. All written objections and supporting papers must (a) clearly identify the case name and number (Khanal v. San Francisco Hilton, Inc., Case No. 4:14-cv-01523-JSW), (b) be mailed to the Settlement Administrator at Khanal v. San Francisco Hilton, Inc., c/o Analytics Consulting LLC, PO Box 2002, Chanhassen MN 55317-2002, or submitted to the Court either by filing them electronically or in person at any location of the United States District Court for the Northern District of California or by mailing them to the Class Action Clerk, United States District Court for the Northern District of California, 1301 Clay Street, Oakland, CA 94612, and (c) be filed or postmarked on or before June 23, 2026.

You may not opt out of the settlement and also object to it. If you attempt to do both, your objection will be effective, and you will be included in the settlement class.

There will be a court hearing on August 14, 2026 at 9:00 a.m. at the United States District Court for the Northern District of California, in Courtroom 5 of this Court, located at 1301 Clay Street, Oakland, CA 94612, to determine whether the settlement should be approved. You are free to attend the final approval hearing, but you are not required to attend. The date for the hearing may change without further notice to the class, so class members should check the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov to confirm the date has not changed. Under California law, if the settlement is approved by the Court, you will be bound by the settlement and will not be permitted to pursue separate claims that were pursued in the lawsuit unless you choose to opt out of the settlement.

All settlement-related documents, as well as the complaint and certain other papers related to the case, are available here. If you have any remaining questions about the settlement, you may contact the settlement administrator or the attorneys representing the class:

Settlement Administrator:
Khanal v. San Francisco Hilton, Inc.
c/o Analytics Consulting LLC
PO Box 2002
Chanhassen, MN 55317-2002
Email: SFHiltonUnionSquareSettlement@noticeadministrator.com
Phone: 888-354-9671

Class Counsel:
Shannon Liss-Riordan
Lichten & Liss-Riordan, P.C.
729 Boylston Street, Suite 2000
Boston, MA 02116
Website: www.llrlaw.com
Email: claims@llrlaw.com
Phone: 855-590-2600