1. Why did I get a notice?
2. What is this lawsuit about?
3. Why is this a class action?
4. Why is there a settlement?
5. How do I know if I am part of the Settlement?
6. I’m still not sure if I am included.
7. What relief does the Settlement provide to the Class Members?
8. How can I get a Class Member Payment(s)?
9. When will I get my Class Member Payment(s)?
10. Do I have a lawyer in this case?
11. How will the lawyers be paid?
12. Will the Named Plaintiffs receive any compensation for their efforts in bringing this Action?
13. What am I giving up to obtain relief under the Settlement?
14. How do I exclude myself from the Settlement?
15. How do I tell the Court that I disagree with the Settlement?
16. What is the difference between excluding myself and objecting to the Settlement?
17. What is the Fairness Hearing?
18. When and where is the Fairness Hearing?
19. May I speak at the hearing?
20. How do I get more information?
21. What if my address or other information has changed or changes after I submit a Claim Form?
You received notice because a settlement has been reached in this Action. You might be a member of the Settlement Class and may be eligible for the relief detailed in Question 7.
The Notice explains the nature of the Action, the general terms of the proposed Settlement, and your legal rights and obligations. To obtain more information about the Settlement, including information about how you can see a copy of the Settlement Agreement (which defines certain capitalized terms used in the Notice), see Question 20.
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Plaintiffs Logan Holsapple and Magne T. Wallacher (the “Named Plaintiffs”) filed a lawsuit (the “Action”) against Reactor Inc., individually and dba Vertical Hold Rock Climbing Gym, Benjamin Zintak, Alana Duyao, and Margaret Chiu (collectively “Defendants”), on behalf of themselves and all others similarly situated. The Action alleges that Defendants engaged in discriminatory conduct based on sex and/or gender identity by providing free or discounted admission and/or entry to females for Vertical Hold’s women’s and/or ladies’ clinics, classes, or events, while denying and/or excluding males and non-binary persons.
Defendants deny 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. Defendants further deny that any Class Member is entitled to any relief, other than for Settlement purposes.
The issuance of the Notice is not an expression of the Court’s opinion on the merits or the lack of merits of the Named Plaintiffs’ claims in the Action.
For information about how to learn about what has happened in the Action to date, please see Question 20.
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In a class action lawsuit, one or more people called “Named Plaintiff(s)” (in this Action, Logan Holsapple and Magne T. Wallacher) 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 and individuals sued in this Action, Reactor Inc., individually and dba Vertical Hold Rock Climbing Gym, Benjamin Zintak, Alana Duyao, and Margaret Chiu, are collectively called the Defendants.
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The Named Plaintiffs have made claims against Defendants. Defendants deny that they have done anything wrong or illegal and admit no liability. The Court has not decided that the Named Plaintiffs or Defendants should win this Action. Instead, both sides agreed to the Settlement. That way, they avoid the cost of a trial, and the Class Members will receive relief now rather than years from now, if at all.
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The Court has decided that everyone who fits this description is a Class Member for purposes of the proposed Settlement: All male and non-binary persons who paid for a membership and/or day pass to Vertical Hold and did not attend Vertical Hold’s women’s and/or ladies’ clinics, classes, or events, at any time between 2017 and 2020.
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If you are still not sure whether you are included, you can write or email the Claims Administrator for free help.
Holsapple, et al. v. Reactor Inc., et al.
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
info@VerticalHoldClassAction.com
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Defendants have agreed to provide each Class Member who timely submits a valid Claim Form by the Response Deadline and who does not exclude themselves from the Settlement, a Class Member Payment of four day passes to Vertical Hold.
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If you received notice of this Settlement and wish to receive a Class Member Payment of four day passes to Vertical Hold, you must complete a Claim Form.
The Claim Form may be submitted online here or by downloading a Claim Form here and submitting by postal mail. Read the instructions carefully, fill out the Claim Form, and postmark it by September 3, 2026, or submit it online on or before 11:59 p.m. (Pacific) on September 3, 2026.
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As described in Question 17 and Question 18, the Court will hold a hearing on July 31, 2026, at 9:00 a.m., to decide whether to approve the Settlement. If the Court approves the Settlement, there may be appeals. It’s always uncertain when the appeals will be resolved, and resolving them can take time, perhaps more than a year. You can check on the progress of the case on this website. Please be patient.
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The Court has ordered that the law firm of Law Offices of Daniel J. Williams (“Class Counsel”) will represent the interests of all Class Members. You will not be separately charged for this lawyer’s services. If you want to be represented by your own lawyer, you may hire one at your own expense.
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Defendants have agreed to pay Class Counsel’s attorneys’ fees of $187,000.00, and all costs incurred by Plaintiffs in the present legal action, subject to approval by the Court. You will not be required to pay any attorneys’ fees or costs. Please see paragraphs 2.5 and 2.7 of the Settlement Agreement, available here, for additional details.
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The Named Plaintiffs will request a Service Fee award of up to $10,000.00 each for their service as Class representatives and their efforts in bringing the Action. The Court will make the final decision as to the amount to be paid to the Named Plaintiffs.
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If the Court approves the proposed Settlement, unless you exclude yourself from the Settlement, you will be releasing your claims against Defendants. 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 Defendants regarding the claims in the Action. The Settlement Agreement contains the full terms of the release.
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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) your full name, address, telephone number, and email address; and (c) a statement that you do not wish to participate in the Settlement, postmarked no later than September 3, 2026 to the Claims Administrator at:
Holsapple, et al. v. Reactor Inc., et al.
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
If you timely request exclusion from the Class, you will be excluded from the Class, you will not receive a Class Member Payment 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 Defendants based on the conduct complained of in the Action.
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At the date, time, and location stated in Question 18, the Court will hold a Fairness Hearing to determine if the Settlement is fair, reasonable, and adequate, and to consider Class Counsel’s request for an award of attorneys’ fees and costs and Service Fees to the Named Plaintiffs.
If you wish to object to the fairness, reasonableness, or adequacy of the Settlement Agreement or the proposed Settlement, you must file a written objection with the Court and deliver copies of the written objection to the Claims Administrator, Class Counsel, and Defendants’ Counsel at the address set forth below no later than (i.e., postmarked by) September 3, 2026.
Holsapple, et al. v. Reactor Inc., et al.
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
Any written objections must contain: (a) the name and case number of the Action; (b) the Class Member’s full name, address, telephone number, and email address; (c) the words “Notice of Objection” or “Formal Objection”; (d) in clear and concise terms, the legal and factual arguments supporting the objection; (e) facts supporting the person’s status as a Class Member; (f) the Class Member’s signature and the date; and (g) the following language immediately above the Class Member’s 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 attorneys’ fees and costs.
If you do not timely make your objection, you will be deemed to have waived all objections and will not be entitled to speak at the Fairness Hearing.
If you submit a written objection, you may appear at the Fairness Hearing, either in person or through personal counsel hired at your expense, to object to the fairness, reasonableness, or adequacy of the Settlement Agreement or the proposed Settlement, or to the award of attorneys’ fees. You are not required, however, to appear. If you, or your attorney, intend to make an appearance at the Fairness Hearing, you must include on your timely and valid objection a statement substantially similar to “Notice of Intention to Appear.”
If you intend to appear at the Fairness Hearing through counsel, you must also identify the attorney(s) representing you who will appear at the Fairness Hearing and include the attorney(s) name, address, phone number, email address, and the state bar(s) to which your counsel is admitted. Also, if you intend to request the Court to allow you to call witnesses at the Fairness Hearing, such request must be made in your written objection, which must also contain a list of any such witnesses and a summary of each witness’s expected testimony.
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Objecting is simply telling the Court that you disagree with something about the Settlement. You can object only if you do not exclude yourself from the Settlement.
Excluding yourself is telling the Court that you don’t want to be part of the Settlement. If you exclude yourself, you have no basis to object because the Settlement no longer affects you.
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The Court has preliminarily approved the Settlement and will hold a hearing to decide whether to give final approval to the Settlement. 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 costs to Class Counsel; and to consider the request for a service fee award to the Named Plaintiffs. You may attend, but you do not have to.
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On July 31, 2026, at 9:00 a.m. Pacific Standard Time, 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 Hon. Michael T. Smyth in Department C-67 of the Superior Court of California, County of San Diego, located at the Hall of Justice, 330 West Broadway, San Diego, CA 92101. The hearing may be postponed to a different date or time or location without notice. Please check this website for any updates about the Settlement generally, or the Fairness Hearing specifically. 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.
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At that hearing, the Court will be available to hear any objections and arguments concerning the fairness of the Settlement. As described in Question 15, you may speak at the Fairness Hearing only if (a) you have timely submitted an objection, and (b) you have timely and validly provided a Notice of Intent to Appear.
If you have requested exclusion from the Settlement, you may not speak at the hearing.
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This website and the Notice summarize the proposed Settlement. To see a copy of the Settlement Agreement, the Court’s Preliminary Approval Order, Class Counsel’s application for attorneys’ fees and costs, and the operative Complaint filed in the Action, please visit the Important Documents page. Alternatively, you may contact the Claims Administrator by U.S. mail or email at:
Holsapple, et al. v. Reactor Inc., et al.
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
info@VerticalHoldClassAction.com
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 https://odyroa.sdcourt.ca.gov or the Clerk’s office at the Hall of Justice, 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.
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It is your responsibility to inform the Claims Administrator of your updated information. You may do so at the address below:
Holsapple, et al. v. Reactor Inc., et al.
c/o Claims Administrator
P.O. Box 25226
Santa Ana, CA 92799
Do not address any questions about the Settlement or the Litigation to the Clerk of the Court or the Judge.
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