How much will I get from the Neutrogena Skin360 settlement?

Each valid claimant's share is estimated at roughly $427 before fees. After attorneys' fees of up to 33.33% and administration costs, the net payout per person could be approximately $280. The exact amount depends on how many of the estimated 11,000 class members file valid claims — fewer claimants means a higher individual payout.

Who qualifies for the Neutrogena Skin360 BIPA settlement?

Illinois residents who used any version of the Skin360 skin assessment tool — including Neutrogena Skin360, Neostrata Skin360, and any Skin360 collaborations — via mobile app or web browser between December 9, 2019 and May 5, 2023. You do not need to show any proof of financial loss.

Do I need proof of financial loss to file a Neutrogena Skin360 claim?

No. This is a statutory damages claim under BIPA, which does not require proof of actual harm or financial loss. You only need to submit a sworn attestation under penalty of perjury that you used the Skin360 tool while in Illinois during the class period.

Will Neutrogena delete my facial scan data?

Yes. Under the settlement terms, Kenvue must delete all facial images collected through Skin360 assessments during the class period and confirm deletion within 14 days of final court approval. Going forward, the company must implement a written consent form and a formal data retention and destruction policy.

What happens to unclaimed money in the Neutrogena Skin360 settlement?

The settlement fund is non-reversionary, meaning no money goes back to Kenvue. Any unclaimed or uncashed funds will be donated to the Electronic Privacy Information Center (EPIC), a digital privacy nonprofit organization, as a cy pres recipient approved by the court.

How long do I have to file a Neutrogena Skin360 settlement claim?

Class members will have 90 days from the date notice is first sent to submit a claim form. The settlement is currently awaiting preliminary court approval, and notice has not yet been sent. Claim forms can be submitted online or by mail once the settlement website launches.

Neutrogena Skin360 $4.7 Million Settlement — Illinois Users Who Scanned Their Face Could Get Hundreds of Dollars Each

Q: What did Neutrogena Skin360 do with my face scan data?

The lawsuit alleged that Skin360 used 180-degree facial scanning to capture users' unique facial geometry and stored those scans in an electronic database. This data was linked to users' names, birth dates, email addresses, sleep and exercise habits, stress levels, and geolocation. The company also allegedly used the facial data to enhance its AI assistant (NAIA) and recommend Neutrogena products — all without disclosing the collection or obtaining written consent.

By Steve Levine

Neutrogena Skin360 $4.7 Million BIPA Class Action Settlement 2026 Illinois Facial Scan No Proof Needed

Published: March 12, 2026

Settlement Fund: $4,700,000 (non-reversionary)

Estimated Payout: ~$427 per person before fees, ~$280 after fees

No Proof of Financial Loss Required

Status: Awaiting Preliminary Approval — Claim Form Not Yet Available

What Is This Settlement About?

If you live in Illinois and ever used the Neutrogena Skin360 app or website to scan your face for a skin assessment, you may be owed hundreds of dollars from a new $4.7 million class action settlement — and you do not need to prove you were financially harmed to get paid.

Neutrogena Skin360 was a digital skin analysis tool that asked users to complete a 180-degree facial scan using their smartphone camera. The software analyzed their skin — evaluating wrinkles, fine lines, dark spots, dark circles, and texture — then generated a personalized "Skin360 score" and recommended Neutrogena products. The technology was developed using more than 10,000 facial databases across ethnicities, skin types, and ages (7 to 70 years old), with more than 10 types of lighting conditions.

The problem, according to a class action lawsuit originally filed in May 2022, is that Neutrogena's facial scanning technology captured detailed scans of each user's unique facial geometry — a biometric identifier — and stored those scans in an electronic database linked to users' names, birth dates, email addresses, sleep and exercise habits, stress levels, and even real-time geolocation data. The company also allegedly used this facial data to train and enhance its AI assistant called NAIA, which recommended Neutrogena products to users.

The lawsuit alleged that Neutrogena never told users their facial biometric data was being captured, never explained how the data would be used or how long it would be stored, and never obtained their informed written consent — all of which are required under the Illinois Biometric Information Privacy Act (BIPA). Neither the Neutrogena Skin360 Privacy Policy nor its Terms of Use contained any written policy regarding the treatment of biometric information or biometric identifiers. The company did not even disclose that it was collecting this type of data at all.

How Did This Lawsuit Play Out in Court?

The case has a significant legal history that strengthened the plaintiffs' position before the settlement was reached.

The lawsuit was originally filed on May 26, 2022 in the U.S. District Court for the District of New Jersey. Johnson & Johnson moved to dismiss the case, arguing that Skin360 was a healthcare or wellness service exempt from BIPA's requirements. In April 2023, Judge Michael Shipp denied that motion, ruling that it was "a reach to consider" the app's AI-driven skin assessments "medical care" under BIPA's healthcare exemption. The judge noted that Skin360 uses AI and a database of images with no medical professionals involved, and that it primarily recommends Neutrogena products — making it closer to a marketing and sales tool than to medical care.

Plaintiffs filed a Second Amended Complaint in July 2024 adding three additional plaintiffs (Christine Borovoy, Andy Sajnani, and Patricia Biewald). Johnson & Johnson filed a second motion to dismiss, which Judge Shipp denied again on March 7, 2025, holding that Skin360 users were not "patients in a healthcare setting" under BIPA.

After losing both motions to dismiss, the parties participated in mediation in Chicago on August 5, 2025. They reached an agreement in principle, executed a settlement term sheet on October 23, 2025, and filed the formal Settlement Agreement for preliminary court approval on February 17, 2026.

In 2023, Johnson & Johnson spun off its consumer division — which includes Neutrogena — into a standalone company called Kenvue Inc. Kenvue is now the settling defendant. Kenvue does not admit liability and denies wrongdoing.

Who Qualifies?

The proposed settlement class covers all individuals who, while in Illinois, performed a Skin360 skin assessment using any version of the tool — including Neutrogena Skin360, Neostrata Skin360, and any Skin360 collaborations with other brands — via mobile app or web browser, between December 9, 2019 and May 5, 2023.

Settlement documents estimate approximately 11,000 class members. This is an Illinois-only settlement because BIPA is an Illinois state law. Excluded from the class are Kenvue/J&J employees, judges, attorneys involved in the case, and anyone who opts out.

How Much Could I Get?

The total settlement fund is $4.7 million and is non-reversionary, meaning no money goes back to Kenvue under any circumstances. After deductions for court-approved attorneys' fees (up to 33.33% of the fund, approximately $1.567 million), litigation costs (approximately $50,000), service awards for the class representatives, and settlement administration expenses, the remaining net fund will be divided equally (pro rata) among all class members who submit valid claims.

If all approximately 11,000 eligible class members file claims, each person could receive roughly $427 before fees, or approximately $280 after fees. If fewer people file claims, individual payouts would be higher.

You do not need to prove you suffered any financial loss or actual harm to file a claim. BIPA is a statutory damages law — the violation of your privacy rights alone is sufficient. You only need to submit a sworn attestation under penalty of perjury that you used the Skin360 tool while in Illinois during the class period. Payments will be made by check or electronic transfer within 21 days of the settlement's effective date.

What Happens to My Facial Data?

Beyond cash payments, the settlement includes significant non-monetary relief specifically addressing what happens to the facial images Skin360 collected from you.

Kenvue is required to delete all facial images collected through Skin360 skin assessments during the class period (December 9, 2019 through May 5, 2023). The company must confirm that deletion is complete within 14 days of final court approval.

Going forward, Kenvue must also create a clear user notice and written consent form for any future use of the Skin360 tool, so that users understand exactly what biometric data is being collected and can give informed consent before any scan. The company must also adopt and follow a formal written policy governing how long biometric data is retained and when it is permanently destroyed.

What Happens to Unclaimed Money?

Any funds remaining in the settlement after all valid claims are paid — including uncashed checks — will be donated to the Electronic Privacy Information Center (EPIC), a well-known digital privacy nonprofit, as a cy pres recipient approved by the court. No remaining funds will be returned to Kenvue.

How Do I File a Claim?

Claim filing details have not yet been released. The settlement is currently awaiting preliminary court approval. Once approved, notice will be sent to class members by email, direct mail, and media. Class members will then have 90 days from the date notice is first sent to submit a claim form online or by mail.

The claim form will require a written attestation under penalty of perjury confirming that you used the Skin360 tool while you were in Illinois during the class period. No receipts, screenshots, or proof of financial loss are needed.

This page will be updated with the official settlement website URL and claim filing instructions once they become available.

Why This Case Matters

The Neutrogena Skin360 settlement adds to a growing wave of BIPA enforcement actions against consumer technology products that use facial recognition or facial analysis without adequate disclosure. Other notable BIPA settlements include Facebook's $650 million facial recognition settlement, Google's $100 million Google Photos settlement, and YouTube's $6 million Face Blur settlement.

Judge Shipp's ruling that Skin360 users are not "patients in a healthcare setting" — and that the app is a consumer beauty/marketing tool, not a medical service — is likely to be cited in future cases involving wellness apps, beauty technology, and AI-driven skin analysis tools. The ruling effectively means that companies cannot avoid BIPA by labeling a consumer product as a "health" or "wellness" service.

Under BIPA, statutory damages range from $1,000 per negligent violation to $5,000 per intentional violation for each person scanned. With approximately 11,000 class members, Kenvue's potential exposure could have exceeded $55 million on a negligent basis alone. The $4.7 million settlement represents a significant discount for the company — but it provides guaranteed compensation to class members without the risk of years of additional litigation.

Case Information

Caption: Melzer, et al. v. Johnson & Johnson Consumer Inc., Case No. 3:22-cv-03149
Court: U.S. District Court for the District of New Jersey
Judge: Hon. Michael A. Shipp
Settlement Fund: $4,700,000 (non-reversionary)
Estimated Per Person: ~$427 before fees, ~$280 after fees
Attorney Fees: Up to 33.33% (~$1.567M) + ~$50K costs
Defendant: Kenvue Inc. / Kenvue Brands LLC (formerly Johnson & Johnson Consumer Inc.)
Class Period: December 9, 2019 – May 5, 2023
Estimated Class Size: ~11,000 individuals
Location: Illinois residents only
Claim: Violation of Illinois BIPA §§15(a), 15(b), 15(c), 15(d) — facial geometry scans without notice, consent, or retention policy
Plaintiffs: Helene Melzer, Christine Borovoy, Andy Sajnani, Patricia Biewald
Plaintiffs' Counsel: Mazie Slater Katz & Freeman LLC; Parasmo Lieberman Law; Schwartz Law PLLC
Claim Deadline: 90 days from first notice (TBD — settlement awaiting preliminary approval)
Cy Pres: Unclaimed funds to Electronic Privacy Information Center (EPIC)
Filed: May 26, 2022 | Settlement filed: February 17, 2026

How Do I Find Class Action Settlements?

Find all the latest class actions you can qualify for by getting notified of new lawsuits as soon as they are open to claims:

Sources

• Global Cosmetics News — J&J Agrees to $4.7M Settlement Over Skin360 BIPA Claims (Feb 2026)
• ID Tech — Kenvue Agrees to $4.7M BIPA Settlement Over Skin-Scanning App (Feb 2026)
• Cosmetics Business — Neutrogena Owner Agrees $4.7M Settlement Over Skin360 Claims
• RetailBoss — J&J Settles Class Action Over Alleged BIPA Facial Scan Violations
• Happi — Kenvue Agrees to $4.7 Million Skin360 Settlement

Filing Class Action Settlement Claims

This settlement is awaiting preliminary court approval. Claim filing details are not yet available. This page will be updated when the settlement website launches and claim forms become available. OpenClassActions.com is a consumer advocacy and class action news site, and is not a class action administrator or a law firm.

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