Zhuravleva v. U.S. Outlet Stores, LLC, dba U.S. Polo Association

The Court Granted Final Approval on October 21, 2022.



You received a notice because a Settlement has been reached in this Action. According to U.S. Polo Assn.’s records you might be a member of the Settlement Class and may be eligible for relief.

The Notice explains the nature of the Action, the general terms of the proposed Settlement, and your legal rights and obligations. For more information, please visit the Long Form Notice here.

Plaintiff Irina Zhuravleva (the “Representative Plaintiff”) filed a lawsuit against U.S. Polo Assn. on behalf of herself and all others similarly situated. The lawsuit alleges that U.S. Polo Assn. engaged in deceptive advertising by advertising false reference prices on merchandise in U.S. Polo Assn. outlet stores in California.

U.S. Polo Assn. denies each and every one of the allegations of unlawful conduct, any wrongdoing, and any liability whatsoever, and no court or other entity has made any judgment or other determination of any liability. U.S. Polo Assn. further denies that any Class Member is entitled to any relief and, other than for settlement purposes, that this Action is appropriate for certification as a class action.

The issuance of this Notice is not an expression of the Court’s opinion on the merits or the lack of merits of the Representative Plaintiff’s claims in the Action.

For information about what has happened in the Lawsuit to date, and about the additional litigation referenced herein, you can access the Settlement Agreement and other case documents on the Court Documents page here.

In a class action lawsuit, one or more people called “Representative Plaintiff(s)” (in this Action, Irina Zhuravleva) sue on behalf of other people who allegedly have similar claims. For purposes of this proposed Settlement, one court will resolve the issues for all Class Members. The company sued in this case –U.S. Polo Assn. – is called the Defendant.

The Representative Plaintiff has made claims against U.S. Polo Assn. U.S. Polo Assn. denies it has done anything wrong or illegal and admits no liability. The Court has not decided that the Representative Plaintiff or U.S. Polo Assn. should win this Action. Instead, both sides agreed to the Settlement to avoid the cost, risks, and delay of continued litigation.

The Court has decided that everyone who fits this description is a Class Member for purposes of the proposed Settlement:

You are a Class Member if, during the period of time beginning July 12, 2015 through June 24, 2022, purchased merchandise at any U.S. Polo Assn. Outlet Store located in the State of California, and did not receive a refund or credit for their purchase(s).

If you are not sure if you are included in the Settlement Class, please review the detailed information contained in the Settlement Agreement, available for download here..


U.S. Polo Assn. has agreed to automatically provide each Class Member who received direct notice of this Settlement via email or postcard and does not timely request exclusion from the Settlement, or who timely and validly completes and submits a Claim Form with one (1) Merchandise Certificate which, at the Class Member’s election, may be applied for: (1) 10% off a merchandise purchase where no minimum purchase is required but with the discount applied only to the first $100 of merchandise; or (2) $5 off a merchandise purchase with no minimum purchase required. The Merchandise Certificate can be used on any purchase in a U.S. Polo Assn. outlet store in California or the U.S. Polo online store at www.uspoloassn.com

The Merchandise Certificate is not transferable and may not be combined with other Certificates though the Certificate may be used with any other discounts and promotions, and on items that are on sale or otherwise discounted. The Merchandise Certificates are not redeemable for cash. Each class member is entitled to receive one (1) Merchandise Certificate regardless of the number of alleged violations and is one-time use only. The Merchandise Certificates are valid for four (4) months following the date of issuance.

Additionally, the Settlement provides for injunctive relief. Specifically, U.S. Polo Assn. agrees that, as of the date the Court entered preliminary approval, and continuing forward, its pricing and labeling practices will not violate California state law or regulations.

If you received direct notice of this settlement, a Merchandise Certificate will be sent to you automatically. If you did not receive direct notice of this Settlement, you must submit a completed Claim Form. The Claim Form may be submitted electronically or by postal mail. Read the instructions carefully, fill out the form, and postmark it by September 22, 2022 or submit it online on or before 11:59 p.m. (Pacific) on September 22, 2022.

If you would like to submit a Claim Form online, please click here. A printable version of the Claim Form is also available here.

The Court will hold a hearing on October 21, 2022 at 1:30 p.m., to decide whether to approve the Settlement. The Merchandise Certificates will be distributed after the Court grants final approval of the Settlement and after any appeals are resolved.


The Court has ordered that the Law Offices of Zev B. Zysman, APC (“Class Counsel”) to represent the interests of the Class. You will not be separately charged for Class Counsel. If you want to be represented by your own lawyer, you may hire one at your own expense.

U.S. Polo Assn. has agreed to pay Class Counsel’s attorneys’ fees and costs up to $175,000, subject to approval by the Court. You will not be required to pay any attorneys’ fees or costs and the amount awarded will not reduce the benefits available to you under the Settlement. Please see Section 2.4 of the Agreement of Settlement here..

The Representative Plaintiff will request a service award of up to $2,500 for her services as class representative and her efforts in bringing the Action. The Court will make the final decision as to the amount to be paid to the class representative and the amount awarded will not reduce the benefits available to you under the Settlement.


If the Court approves the proposed Settlement, unless you exclude yourself from the Settlement, you will be releasing your claims against U.S. Polo Assn. This generally means that you will not be able to file a lawsuit, continue prosecuting a lawsuit, or be part of any other lawsuit against U.S. Polo Assn. regarding the claims in the Action.


You may exclude yourself from the Class and the Settlement. If you want to be excluded, you must send a signed letter or postcard stating: (a) the name and case number of the Action; (b) the full name, address, and telephone number of the person requesting exclusion; and (c) a statement that he/she does not wish to participate in the Settlement, postmarked no later than September 22, 2022 to the Claims Administrator at:


c/o CPT Group, Inc.

50 Corporate Park

Irvine, CA 92606



If you timely request exclusion from the Class, you will be excluded from the Class, you will not receive a Merchandise Certificate under the Settlement, you will not be bound by the judgment entered in the Action, and you will not be precluded from prosecuting any timely, individual claim against U.S. Polo Assn. based on the conduct complained of in the Action.


The Court will hold a Fairness Hearing to determine if the Settlement is fair, reasonable, and adequate, and to also consider Class Counsel’s request for an award of attorneys’ fees and costs, and service award to the Representative Plaintiff.

If you wish to object to the fairness, reasonableness, or adequacy of the Agreement of Settlement or the proposed Settlement, you may submit a written objection to the Court, Class Counsel and Defense Counsel at the addresses set forth below no later than (i.e., postmarked by) September 22, 2022.

Clerk of the Court
Superior Court of the State of California, County of San Diego
330 West Broadway Department C-69
San Diego, California 92101
Zev B. Zysman
Law Offices of Zev B. Zysman
15760 Ventura Boulevard 7th Floor
Encino, CA 91436

(818) 783-8836

Talia L. Delanoy
Gordon Rees Scully Mansukhani, LLP
3 Parkcenter Drive Suite 200
Sacramento, CA 95825

(916) 565-2900

Any written objections should contain: (1) the name and case number of the Action; (2) your full name, address, and telephone number; (3) the words “Notice of Objection” or “Formal Objection”; (4) in clear and concise terms, the legal and factual arguments supporting the objection; (5) facts supporting your status as a Class Member (e.g., either any unique identifier included by the Claims Administrator in your notice, or the date and location of your relevant purchases); (6) your signature and the date; and (7) the following language immediately above the your signature and date: “I declare under penalty of perjury under the laws of the State of California that the foregoing statements regarding class membership are true and correct to the best of my knowledge.” You may, but need not, submit your objection through counsel of your choice. If you do make your objection through an attorney, you will be responsible for your personal attorney’s fees and costs.

Class Members have the option to appear at the Fairness Hearing, either in person or through personal counsel hired at the Class Member’s expense, to object to the fairness, reasonableness, or adequacy of the Settlement, the award of attorneys’ fees and costs, or the proposed incentive award to the Class Representative. However, Class Members (with or without their attorneys) intending to make an appearance at the Fairness Hearing must so inform the Parties and the Court on or before September 22, 2022 by providing a “Notice of Intention to Appear” to the Claims Administrator.

Objecting is simply telling the Court that you disagree with something about the Settlement. You can object only if you stay in the Settlement Class. Excluding yourself is telling the Court that you don’t want to be part of the Settlement Class. If you exclude yourself, you have no basis to object because the Settlement no longer affects you.


The Court has preliminarily approved the Settlement and will hold a hearing to decide whether to give final approval to the Settlement. You may attend, but you do not have to. The purpose of the Fairness Hearing will be for the Court to determine whether the Settlement should be approved as fair, reasonable, adequate, and in the best interests of the Settlement Class; to consider the award of attorneys’ fees and expenses to Class Counsel; and to consider the request for service award to the Representative Plaintiff. Class Counsel will file with the Court their motion for award of attorneys’ fees and costs and Class Representative’s service payments no later than September 29, 2022.

On October 21, 2022, at 1:30 p.m. (Pacific), a hearing will be held on the fairness of the proposed Settlement. At the hearing, the Court will be available to hear any objections and arguments concerning the proposed Settlement’s fairness. The hearing will take place before the Honorable Katherine A. Bacal in Department C-69 of the Courthouse of the San Diego County Superior Court, located at 330 West Broadway, San Diego, CA 92101. You should also check the Court’s main website (www.sdcourt.ca.gov) for any information about COVID-19 related issues that may impact the manner in which the Fairness Hearing is held (e.g., via videoconference or teleconference). The hearing may be postponed to a different date or time or location without notice. If the date or time of the Fairness Hearing changes, an update to this website will be the only way you will be informed of the change.

At the Fairness Hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement. You may speak at the Fairness Hearing only if you have timely and validly provided a Notice of Intention to Appear. Please note that due to the COVID-19 pandemic, the Court may determine to hold the Fairness Hearing by videoconference, teleconference or some other means (e.g., Zoom, Court Call, etc.) and you should check the Register of Actions for this Action (https://roa.sdcourt.ca.gov) and/or this website for any information on Court orders or procedures permitting remote appearance at the Fairness Hearing.

If you have requested exclusion from the Settlement, you may not speak at the hearing.


To see a copy of the Settlement and Amendment thereto, the Court’s Preliminary Approval Order, Class Counsel’s application for attorneys’ fees, costs, and incentive award, and the operative complaint filed in the Action, please visit the Court Documents page here or by writing the Claims Administrator at the U.S. postal (mailing) address or email address below:


c/o CPT Group, Inc.

50 Corporate Park

Irvine, CA 92606



This description of this Action is general and does not cover all of the issues and proceedings that have occurred. In order to see the complete file, you should visit the Register of Actions for this Action (https://roa.sdcourt.ca.gov/roa/) or the Clerk’s office at 330 West Broadway, San Diego, CA 92101. The Clerk will tell you how to obtain the file for inspection and copying at your own expense. Please be certain, however, to check updates on the Court’s website about accessibility to the Court and the ability to view documents during the COVID-19 pandemic before you expend time to travel to the Court.

It is your responsibility to inform the Claims Administrator of your updated information. You may do so at the address or email below:


c/o CPT Group, Inc.

50 Corporate Park

Irvine, CA 92606