How much plaintiff intake verification is enough? A tiered checklist for class action and mass arbitration sign-ups

Plaintiff intake verification works best in tiers: quiet, automatic checks on every sign-up, documented proof before you retain someone or put them forward as a class representative, and a file that ties each claimant to the facts before anything is filed in their name. Settlement records now show fraudulent claims arriving by the million. And in Wallrich v. Samsung Electronics America, Inc. (7th Cir. July 1, 2024), counsel-signed demands and a spreadsheet of names and addresses did not show that any of 35,651 consumers were Samsung customers who had agreed to arbitrate.

Why does intake verification matter more than it used to?

An open web form lets a real person sign up in two minutes and a script sign up thousands of times. Settlement administrators now put numbers on that in sworn declarations.

In the JUUL economic loss settlements, administrator Epiq told the court it received 14,488,748 claims and scored 77.45% of them high for fraud indicia (declaration, April 24, 2024, ¶¶ 7 to 8). Judge William Orrick approved a plan for "rejecting claims that are clearly fraudulent without expending class resources unnecessarily" (order, May 7, 2024).

JUUL is not an outlier:

Sources: JUUL declaration and distribution order; Artsana declaration, hearing transcript and final approval brief; Grande filing and final approval order; Godiva declaration and letter; Novartis declaration. Units differ by case (claims, claimants, products). Compiled by ClassAct, October 25, 2026.

These are settlement claims, not firm intake, but an intake form is an open web form too. The Novartis administrator said that in her experience, settlements with an open class, no documentation requirement and no cap on the amount claimed tend to draw a "high proportion of potentially fraudulent claim submissions" (declaration, December 20, 2023, n.3).

Mass arbitration raises the stakes per name, because each demand is its own case. The AAA's 2025 data release (June 3, 2026) gives "whether the claimants met any contractual pre-conditions to filing, which arbitration agreement applies, and whether the claimants met the relevant filing requirements" as typical issues for the Process Arbitrator.

What do arbitration rules and courts expect you to show about each claimant?

Less at filing than at the first real challenge.

The AAA's Mass Arbitration Supplementary Rules (amended and effective April 1, 2024) say "A separate Demand for Arbitration must be filed in each individual case." The filing party also submits an intake spreadsheet that goes to the other side, plus "an affirmation that the information provided for each individual case is true and correct to the best of the representative's knowledge" (MA-2). If the AAA appoints a Process Arbitrator, disputes over filing requirements and how to cure deficiencies can go there (MA-6(a), (c)(i)).

The JAMS Mass Arbitration Procedures (effective May 1, 2024), where the parties agreed to them, say "A Demand for Arbitration Form and applicable arbitration agreement must be submitted for each Claimant" (Proc. 2(a)). They also call for "a sworn declaration from counsel" to the same best-of-knowledge standard (Proc. 2(c)).

Wallrich shows what comes after intake. The consumers had asked a court to compel arbitration, so they carried the burden, and Samsung conceded its customers were bound. The question became whether each claimant was "in fact" a Samsung customer.

The court noted that "The AAA's filing requirements involve no substantive determinations" and that the demands were "nothing more than allegations." It said the consumers "could have submitted almost anything to meet their burden," such as "receipts, order numbers, or confirmation numbers," or declarations. Its summary-judgment-like posture "does not allow second chances" (slip op. 12 to 15).

Some limits: Wallrich binds federal courts in Illinois, Indiana and Wisconsin, it applied the AAA's earlier multiple-case filing rules rather than the 2024 version, and a separate holding addressed fees. Your clause, forum and circuit may differ.

How much proof can you ask for before real members drop out?

Some, but each added step can cost real people. In its 2015 arbitration study, the CFPB reported that five administrators of consumer financial settlements said procedural complexity affected claims rates: "Claims rates fell nearly 90% if documentary proof was required" (Section 8, p. 31).

The FTC's 2019 staff report was more cautious. It did not find documentation requirements related to claims rates overall (p. 3). A footnote reports that forms asking for the most difficult documentation, such as original receipts or notarizations, had claims rates "an average of 27.3 percentage points lower," a marginally significant result, and only 5% of cases asked for that kind of proof (p. 39; p. 45 n.61). The two studies measure differently, so their figures don't compare directly.

Courts look at the other side of the ledger too. In Novartis, the court referred an inquiry "to assess the reasons for the disproportionately low number of claims allowed compared to claims filed," then adopted a finding that the process "has integrity" (order, May 4, 2026). A written screening rule, applied the same way to everyone, is easier to explain than case-by-case calls.

The workable answer is to ask for proof when it changes a decision, and not before.

What should a plaintiff intake verification checklist cover at each stage?

A sign-up costs the firm little; a filed demand carries a fee and an affirmation.

Sources: AAA rules, MA-2 (Apr. 1, 2024); JAMS procedures, Proc. 2(c) (May 1, 2024); Wallrich, slip op. 12 to 15; FTC data guidance ("Keep only what you need"). Compiled by ClassAct, October 25, 2026.

A worked example

Take a hypothetical California-only claim against a subscription app, with a week of ads behind it.

1. Sign-up. Three knockouts: lived in California during the class period, paid for the subscription, paid within the date range. Duplicate and traffic checks send flagged entries to a review queue rather than rejecting them.
2. Shortlist. The firm asks for one thing: a screenshot of the receipt email or billing page showing name, plan and date.
3. Filing. If the terms carry an arbitration clause, each file gets the account email, sign-up date, where the person subscribed (app or web can mean different terms), any required notice of dispute and a signed declaration.

How do you keep real sign-ups engaged while you check them?

Verification adds waiting, and waiting loses people.

• Use a second channel. The court-approved JUUL plan called for verification notices by email and, where one bounced, a second attempt by alternate email or text message (order, May 7, 2024). For intake, the equivalent is a channel the person agreed to at sign-up.
• Repeat the ask. In the FTC's settlement sample, cases that tried to reach class members more than once had "average and median claims rates that are more than twice as high" as single-attempt cases (p. 27). Our claims rate breakdown covers notice methods.
• Ask for one thing at a time, with an example of acceptable proof.

What this means for your firm

1. Write down each case's knockouts and fraud flags before the ads run, and keep the version you used.
2. Ask for proof where it changes a decision: engagement, naming a representative, filing.
3. For mass arbitration, compare each file with the evidence Wallrich found missing, and read it alongside the clause and current forum rules.
4. Send borderline flags to review. In JUUL, the court approved rejecting clearly fraudulent claims outright and sending the middle tier to verification.
5. Collect only what each stage needs.

Rules vary by jurisdiction. Check the rules that apply to you.