The Animal Doctor, Ltd. Profit Sharing Plan (the “Plan”) is a defined contribution plan in which the investment decisions are made by the Trustee of the Plan. Plan participants do not have the power to decide how Plan assets are invested and were not provided proper disclosures regarding the Plan’s investments.

Defendant Lori W. Wyatt, the owner of The Animal Doctor, Ltd is also the Trustee and Investment Fiduciary of the Plan. As Trustee and Investment Fiduciary, Dr. Wyatt decided to invest almost 98% of the Plan assets in only three pharmaceutical or biotech companies: Inovio Pharmaceuticals, Inc., Moderna, Inc., and Novavax, Inc. As of December 31, 2021, approximately 50% of the Plan’s assets were invested in Inovio Pharmaceuticals alone. This decision resulted in significant losses to the Plan and the participant accounts in the Plan.

By investing almost all of the Plan’s assets in only three pharmaceutical/biotech companies and almost 50% in a single company, and by maintaining such investments, Dr. Wyatt breached her fiduciary duties in failing to invest Plan assets prudently and in the best interests for participants and in failing to diversify Plan assets. As a result, these breaches of fiduciary duty have caused the Plan more than half of its value.

The Court has certified the following Class:

All participants in The Animal Doctor, Ltd. Profit Sharing Plan at any time between March 8, 2021 to December 31, 2025 (except those participants who terminated without even partial vesting) and the beneficiaries of any such participants, excluding the Excluded Persons.

“Excluded Persons” means the following persons who are excluded from the Class: Excluded from the Class are (1) Defendants, (2) any fiduciaries of the Plan, (3) other persons who had decision-making or administrative authority relating to the administration, investment allocation, modification, funding, or interpretation of the Plan, (4) the beneficiaries of such persons, the immediate relatives of such persons, and (5) the legal representatives, assigns or successors in interest of any excluded person.

The Complaint was filed on September 13, 2024 in the Northern District of Illinois.

Order Certifying the Class & Granting Preliminary Approval – August 27, 2026.

Settlement Agreement

Plan of Allocation

Class Notice

Motion for Preliminary Approval – August 20, 2026

Motion for Class Certification – August 20, 2026

Complaint – September 13, 2024 

Plaintiffs and Defendants executed a settlement term sheet on April 1, 2026. A formal settlement agreement was executed on August 20, 2026. Under the terms of the Settlement, Animal Doctor has agreed to pay $500,000 into a Settlement Fund. After subtracting court-approved attorneys’ fees, litigation expenses such as costs for Class Notice, settlement administration and any court-approved service award to Plaintiff, the Net Settlement Fund will be distributed to Class Members.

Plaintiff filed a Motion for Class Certification and Motion for Preliminary Approval on August 27, 2026. The Court granted Plaintiff’s motions on August 27, 2026 and set a final fairness hearing to be held on December 17, 2026 at 9:00 a.m. at Everett McKinley Dirksen U.S. Courthouse, 219 South Dearborn Street, Chicago, IL 60604.