McKinney, et al. v. Scale AI, Inc., et al.

Superior Court of the State of California, County of San Francisco
Case No. CGC24620481

Welcome to the Settlement Website for the McKinney v. Scale AI Class Action Lawsuit

If you received notice, you may be eligible to receive money from the Settlement of class action lawsuits ("Actions") against Scale AI, Inc. ("Scale AI"), Smart Ecosystem, Inc. ("Smart Ecosystem"), Alexandr Wang, Dennis Cinelli, Daniel Berrios, Xiaote Zhu, and HireArt, Inc. ("Defendants") for alleged wage and hour violations. Defendants strongly deny violating any laws, deny the claim that Contributors are not independent contractors, and contend that they complied with all applicable laws.

The Actions are brought by former independent contractors who performed services with Scale AI or Smart Ecosystem, and/or HireArt employees, on behalf of a Class and a group of PAGA Workers, seeking payment of unpaid wages, unreimbursed business expenses, and penalties.

The Court has preliminarily approved the proposed Class Settlement and authorized the Notice. The Court has not yet decided whether to grant final approval. Your legal rights are affected whether you act or not.

Summary of Your Legal Rights and Options in this Settlement

You Don’t Have to Do Anything to Participate in the Settlement

If you do nothing, you will be a Participating Class Member, eligible for an Individual Class Payment and an Individual PAGA Payment (if any). In exchange, you will give up your right to assert the wage claims against Defendants and bound by the release of the Released Class Claims. You will also be bound by the Released PAGA Claims if you are a PAGA Worker.

You Can Opt Out of the Class Settlement but not the PAGA Settlement

The Opt Out Deadline is September 3, 2026

If you don’t want to fully participate in the proposed Class Settlement, you can opt out of the Class Settlement by sending the Administrator a written Request for Exclusion. Once excluded, you will be a Non-Participating Class Member and no longer eligible for an Individual Class Payment. Non-Participating Class Members cannot object to any portion of the proposed Class Settlement. See Question 6 for more information.

If you are a PAGA Worker, you cannot opt out of the PAGA Settlement and if the Court approves the PAGA Settlement, Defendants must pay you an Individual PAGA Payment and you will be deemed to release the Released PAGA Claims.

Participating Class Members Can Object to the Class Settlement but not the PAGA Settlement

Written Objections Must be Submitted by September 3, 2026

All Class Members who do not timely and validly opt out of the Class (“Participating Class Members”) can object to any aspect of the proposed Class Settlement. The Court’s decision whether to finally approve the Settlement will include a determination of how much will be paid to Class Counsel and Plaintiffs who pursued the Actions on behalf of the Class and the PAGA Workers. You are not personally responsible for any payments to Class Counsel or Plaintiffs, but every dollar paid to Class Counsel and Plaintiffs reduces the overall amount paid to Participating Class Members. You can object to the amounts requested by Class Counsel or Plaintiffs if you think they are unreasonable. See Question 7 for more information.

Participate in the Hearing You Can Participate in the October 30, 2026 Final Approval Hearing

The Court’s Final Approval Hearing is scheduled to take place on October 30, 2026. You don’t have to attend but you do have the right to appear (or hire an attorney to appear on your behalf at your own cost), in person, by telephone or by using the Court’s virtual appearance platform. Participating Class Members can verbally object to the Class Settlement at the Final Approval Hearing. See Question 8 for more information. The Court may change the Final Approval Hearing date so check the Court’s website for further information if you plan to attend.

You Can Challenge the Calculation of Your Class Workweeks / PAGA Pay Periods

Written Challenges Must be Submitted by September 3, 2026

The amount of your Individual Class Payment and Individual PAGA Payment (if any) depend on your Class Workweeks and PAGA Pay Periods, respectively. The number of Class Workweeks and number of PAGA Pay Periods you received payment for work performed with Scale AI according to Defendants’ records is stated on the first two pages of the Notice. If you disagree with either of these numbers, you must challenge it by September 3, 2026. See Question 4 for more information.

Upcoming Important Dates

Opt Out Deadline

9/3/2026

Dispute Deadline

9/3/2026

Final Approval Hearing

10/30/2026