RJN 19 — In re Bank of America California Unemployment Benefits Litigation (Dkt. 590-21, S.D. Cal. No. 3:21-md-02992)

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U.S. District Court for the Southern District of California · No. 3:21-md-02992-GPC-MSB · Doc. 590-21 · 2025-10-17 · Docket on CourtListener

Full text

RJN 19 
Case 3:21-md-02992-GPC-MSB     Document 590-21     Filed 10/17/25     PageID.40543 
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Calculating the Road to Losing $400 
Billion Dollars 
January 20. 2022 I By: Slake.ttan 
Featured Viewpoint by Blake Hall I January 20, 2022 
Executive Summary 
ID.me stands by its estimate of $400 billion in fraudulent claims for 
unemployment Insurance during the pandemic. Here's a summary of the 
evidence: 
► Over $1 trillion was spent on unemployment benefits, according to the 
Pandemic Response Accountability Committee (PRAC).1 
► State workforce agencies were not equipped to perform identity verification, 
which created huge opportunities for fraud. Criminals shared fraud methods 
on the dark web. 
► States have reported massive fraud losses in the billions of dollars, including 
Arizona, California, Michigan and Nebraska, but many states do not have 
systems in place to detect and report fraud. In those states. fraud losses are 
likely even higher. 
► For the period March 27. 2020 to September 30, 2020, OO1:s Inspector 
General found that 60% of states did not complete required reporting for 
fraudulent payments. z 
► Multiple experts have corroborated estimates of hundreds of billions of 
dollars of fraud losses nationwide. 
► ID.me's view of identity and eligibility fraud in the 27 states we support is 
likely the first integrated assessment of fraud trends. 
► ID.me has substantial additional evidence of Identity theft fraud that state 
audits do not have the ability to detect. 
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► ID.me will be releasing a comprehensive Unemployment After Action Report 
in the coming weeks. 
► It will likely take years for states to fully audit the fraud during the pandemic. 
Meanwhile, all available data from the states, experts, and ID.me supports 
$400 billion dollars lost. 
Unemployment benefits are administered at the 
state level 
States differ in their technological maturity, their ability to detect improper 
payments, and with respect to compliance with Department of Labor (DOL) 
requirements. This reality makes it difficult for the federal government to rapidly 
and reliably quantify fraud at a national level as antiquated technology prevents 
accurate reporting just as those systems proved unable to stop fraud while 
efficiently delivering benefits. 
Historically, eligibility requirements in the states protected the program from bad 
actors who would seek to steal government benefits. Employers were notified. 
and could contest. UI payments for employees who lost their job Involuntarily 
and not for cause. As a result. employers provided an effective check against 
fraud. Success rates were relatively low, the process is fairly involved. and the 
weekly payouts were lower than during the pandemic. In Virginia. UI payouts 
range from a $60 weekly minimum to a $378 weekly maximum.3 
The Payment Integrity Information Act (PIIA) requires programs to report an 
annual improper payment rate below 10 percent. Improper payments can 
include overpayments to eligible individuals e.g .. a person finding a job but still 
receiving UI payments for several weeks. Unprecedented and sudden reform to 
the UI system during the pandemic shattered the existing protections in place to 
combat fraud while sweetening the pot for fraudsters. 
Given this background, there is a concerning lack of transparency tied to 
improper payments that persists today. Many states cannot detect fraud at all, 
let alone report it. In a May 28, 2021 report. DOt:s Inspector General listed the 
following in a section titled "STATES DID NOT REPORT OVERPAYMENTS AND 
FRAUDULENT PAYMENTS:" 4 
► For the period March 2020-September 2020, 42% of states did not complete 
required reporting for overpayments and 60% did not complete reporting for 
fraudulent payments. 
► 60% of the Pandemic Unemployment Assistance (PUA) states. 38% of the 
Federal Unemployment Compensation Program (FPUC), and 45% of the 
Pandemic Emergency Unemployment Compensation (PEUCJ reported No 
Fraudulent Payments. 
► Officials in 17 /SO states (34%) reported their IT systems did not allow them to 
complete improper payment detection and recovery. 
The Inspector General's report asserts that states were either not reporting, or 
underreporting, fraud and improper payments. This situation is attributable to 
decades of chronic underfunding and to a slew of new programs that 
overwhelmed state agencies. 
What the states are saying 
Despite these reporting deficiencies. states have already published massive 
fraud losses: 
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► Michigan reported losing $8.5 billion dollars in fraud according to a recent 
audit by Deloitte.5 Michigan has a population of slightly less than 10 million 
people. Calculated on a national basis, the percentage of identified fraud 
would equate to $281 billion dollars. 
► Arizona reported $5.8 billion dollars in fraud6 (though they were able to 
recover $1 .4 billion). Arizona has a population of about 7.3 million people. 
Calculated on a national basis, this would equate to $262 billion dollars in 
fraud. 
► California reported $20 billion dollars in fraud.7 Calculating the per capita 
rate on a national basis, the total lost would equate to $167 billion dollars in 
fraud. 
► A 2020 audit of improper unemployment payments in Nebraska found that 
two-thirds of money was misspent. 8 
These figures are based primarily on identity theft. cross-matching, and 
associated overpayments tied to the Pandemic Unemployment Assistance (PUA} 
program in particular. Eligibility fraud (i.e., people applying for unemployment in 
states where they are not eligible, prisoners, people who are employed, etc.} that 
went undetected and fraud targeted at programs other than PUA that weren't 
audited will increase these numbers further. Overpayments to eligible claimants 
will Increase the total amount lost beyond explicit fraud as well. 
Notably, California and Arizona were the first states to implement identity 
verification and other fraud tools that conformed to the NIST 800-63-3 Identity 
Assurance Level 2 and Authenticator Assurance Level 2 standards. It is rational to 
believe the fraud rate was worse in slower moving states and in states that lack 
the ability to detect or report fraud at all. 
What the experts are saying 
Multiple cybersecurity experts, analysts. and law enforcement officials 
corroborate hundreds of billions of dollars of loss in line with I0.me·s estimates 
of $400 billion, about a 40% loss rate: 
Rachel Greszler, Research Fellow in Economics, Budgets, and Entitlements at the 
Heritage Foundation, testified before the Subcommittee on Financial Institutions 
and Consumer Protection (August 2021): "My analysis estimates that S357 billion 
worth of payments will have gone to non-unemployed individuals ... While some 
states have successfully recovered hundreds of millions. or up to a couple billion 
dollars. total recoveries will likely pale in comparison to the magnitude of fraud."9 
Jon Coss, who heads a unit within Thomson Reuters that is helping states detect 
fake unemployment insurance claims. is on record saying that. "From my 
experience, when this is all said and done, we are going to be counting in the 
hundreds of billions of dollars. not the tens of billions." The U.S. Department of 
Labor's Inspector general estimated that at least $87 billion in fraudulent and 
improper payments were going to be processed by September 2021, which was 
based on a historic assumption of 10% fraud-but he acknowledged that figure 
is likely too conservative where fraud has "exploded" to "unprecedented" levels. 
Instead, Coss noted that "between 4096 and 5096 of the claims his group hos 
analyzed seem highly suspect."10 
On July 1 2021, "Supervisory Special Agent Keith Givens, with the FBI in Orlando, 
told [investigators] they have reports of up to $250 billion in unemployment 
fraud nationwide." Enhanced unemployment benefits did not end until 
September 6, 2021. 11 
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On July 1 2021, "Supervisory Special Agent Keith Givens. with the FBI in Orlando. 
told [investigators] they have reports of up to $250 billion in unemployment 
fraud nationwide." Enhanced unemployment benefits did not end until 
September 6. 2021.11 
"David Prosnitz, president of Personnel Planners, said bogus claims typically 
make up less than 1 % of the claims his firm sees when assisting employers with 
unemployment insurance issues. But during certain periods of the pandemic, 
that share has surged to upwards of 50% of claims. he said." This fraud was 
explicitly tied to Traditional UI claims and not to the Pandemic Unemployment 
Assistance program that crime rings targeted initially.12 
Douglas Holmes, president of UWC - Strategic Services on Unemployment & 
Workers' Compensation, an advocacy organization for businesses. told 
Bloomberg Law: "Fraud rings look for easy targets that produce revenue with 
minimal risk .. .When PUA is no longer on the board, they'll look to other places to 
exploit. They'll look to regular UI." 
Crane Hasshold. senior director of threat research at Agari, a cybersecurity 
research firm, told NBC News "They(Nigerian crime rings) are seeing essentially 
trillions of dollars that is up for grabs. This is their World Series. This is their 
Super Bowl." 13 
What DOL's Office of the Inspector General is 
saying 
The Department of Labor's Inspector General site notes that improper payments 
tied to unemployment insurance total at least $87 billion.14 However, this 
estimation uses the improper payment rate from prior to the pandemic and 
be/are the "Super Bowl" of fraud kicked off. DOt:s Inspector General noted that 
based on initial findings "the (pandemic) rate will be higher than 10%." Given the 
increased fraud rates. this approach underestimates the actual levels of fraud. 
Additionally. many states removed or relaxed the eligibility requirements they 
had in place for the traditional UI system. 35 states waived the one-week waiting 
period before distribution of traditional UI benefits. 16 states decided UI claims 
would not be charged against an employer's experience rating - a m etric that 
can lead to higher UI charges for an employer - to discourage employers from 
contesting claims.15 California and Florida suspended UI certification and 
Michigan relaxed checks due to the massive number of claims filed.16 1718 
Given these actions. employers that typically serve as the Identity verification and 
eligibility adjudication gatekeepers with state workforce agencies were either 
removed from the claims certification process or had reduced incentives to 
report fraudulent claims. To Florida and California's credit, they were among the 
very first states to adopt identity verification. However, identity verification and 
eligibility verification are two different controls, opening the door to out-of -state 
applicants who could use their own identity to fraudulently apply for aid in those 
states. 
What the data says about eligibility fraud 
Eligibility fraud exploded during the pandemic. Eligibility fraud is distinct from 
identity fraud in that the person who is verifying their identity is that person -
they just aren't eligible in the state where they are applying. While states should 
use a national clearinghouse to check if an identity filed a claim in another state, 
many of them do not cross-check claims. A May 21, 2021 Department of Labor 
Inspector General report found that 44 of 50 states (88%) did not perform all 
eight recommended cross-matches for claims.19 By contrast, ID.me as a shared 
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service for login and identity verification is inherently networked across all 
states. 
Due to our network. ID.me can monitor two key metrics that provide insight into 
eligibility fraud. First. we can see if the same person/identity is applying for 
unemployment in multiple states. Second, we can see the percentage of the time 
that a person's state issued government ID matches, or does not match, the state 
where that person is applying for unemployment benefits.On July 10, 2021, out 
of state licenses as a percentage of identities verified for a given state peaked at 
66.2%. On September 6, 2021, the day that enhanced federal unemployment 
benefits ended, the percentage of out-of-state government IDs used for identity 
verification dropped from 30.2% to 10.7%. The rate briefly rose again when 
individuals realized they could still apply for unemployment benefits 
retroactively. ID.me monitored the dark web chat rooms where people shared 
this information about eligibility fraud with each other. During this period in 
October, out of state licenses rose to 49.1 % of identities used to verify in a given 
state. 
Once the retroactive application date expired, out-of-state government IDs fell 
back to 7 - 11%, which appears to be the steady state range absent substantial 
fraudulent attacks. 
Figure 1 below shows the massive drop in out of state applicants when 
enhanced federal benefits ended. Eligibility fraud on an industrial scale is the 
only plausible explanation. 
Considering that 17 of 50 states (34%) told DOL's Inspector General their IT 
systems do not allow them to complete improper payment detection and 
recovery, ID.me's view of identity and eligibility fraud in the 27 states we support 
is likely the first integrated assessment of fraud trends.20 This status quo means 
that fraud is underreported. If 17 of 50 states cannot detect it at all, then it is 
unlikely the remaining states can capture all of it accurately. 
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Figure 1: Out of state applicants dropped 14% on September 6, the day federal 
benefits ended (in brown). 
ID.me's video chat verification team monitored significant patterns that support 
massive eligibility fraud. One video chat agent wrote to ID.me·s executive 
leadership team that she was having trouble sleeping after verifying tens of 
people with state licenses from the South who were applying for unemployment 
benefits in Western states. These out of state applicants should be audited 
retroactively as the percentage of ineligible claims is likely very high. 
The quantitative data and the qualitative feedback from help desk agents points 
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strongly towards record eligibility fraud. This eligibility fraud will stack on top of 
identity theft fraud. 
ID.me has substantial additional evidence of fraud patterns that state auditors 
likely do not have the ability to detect. We will be releasing a comprehensive 
Unemployment After Action Report detailing all of these topics and how fraud 
attacks changed over time in the coming weeks. 
What the data says about identity fraud 
The introduction of the Pandemic Unemployment Assistance (PUA) program 
introduced an entirely new attack vector. For this program, anyone could verify 
their identity and self-assert eligibility i.e. self-employed, sharing economy 
worker, etc. By all accounts, the fraud targeting this program was astronomical 
and likely dwarfs eligibility fraud. International crime rings, foreign students, 
Nuke Bizzle, a Memphis rapper, and more began targeting unemployment. 
ID.me's analysis of PUA claims signals fraud occurred in over 50% of all claims 
filed in multiple states. An early review in Nebraska. which looked at all statewide
payments through June 2020, found roughly 66 percent of unemployment 
money was misspent.21
The dropoff in claims filed after implementation of ID.me provides evidence of 
the enormous magnitude of fraudulent claims as criminals would rather 
abandon a state than risk leaving a trail of their fraud in ID.me's verification 
process. Arizona provided a testimonial of this impact "Due to the significant 
decrease in new suspected fraudulent claims from a record high of nearly 
570.400 claims filed the week ending October 10th, compared to just 6,700 the 
week ending November 12th after the implementation of ID.me, DES is 
expanding this partnership to detect fraud among existing claimants."22
After Arizona applied ID.me verification to continued PUA claims, on December 4, 
2020, continued claims decreased by 68.3%, virtually all of which were confirmed 
as fraudulent. Out of 268,556 existing claims, only 85,174 of those claims were 
legitimate . 
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Weekly New Ari%ona PUA Claim$ 
Publicly available data demonstrates an immense scale of fraud perpetrated 
across the country, in Colorado, New York, Florida, California, Nevada, 
Pennsylvania, Louisiana, and the list goes on. We can help anyone interested in 
diving into these numbers to access publicly available data that corroborates it. 
What the criminals are saying 
ID.me set up a dark web Threat Intelligence Cell to monitor criminal 
communications as they open-sourced attacks. As a result, we were able to 
actively watch crime rings as they adapted to new security controls and began to 
attack states and programs with weaker verification. Criminals often wrote our 
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best testimonials. At the same time, we could see them actively organizing to 
target the weakest states and avoiding ID.me by name. As a result, we are 
confident that fraud rates are higher in states that moved more slowly and with 
weaker controls. 
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This dark web ,chatter is inde,pendent;Jy verifiable .. Criminals use forums to 
organize; however,. those same forums mak:e them vulnerabl,e to observation. 
Cezary Podkul. a reporter a ProPub ica, wrote· extenSirve,!y about these forums in 
a deeply researched a,rticle. 23 
conclusion 
Prior to the pandemic,. unemployment benefits had built in protections to control 
for identity theft and elligilbility fraud. A state workforce .agency wo,uld .simply 
contact an employer to confirm a LI.I daim was valid. If the employe,r didn't 
recogn z.e the employee on the claim, o disput,ed the claim, they would enga,ge 
with the workforce agency.. Employers were incentivized to r,espond if something 
was amiss as they risk,ed pa,ying a higher UI tax ·for highE!r turnover rates. 
This feedback loop effectively contained fraud a:s ,exp,e1rts cited above note. 
Fraudulent daims totaled l,ess than 1 % prior to the pandemic. Improper 
payments we.re mainly more mundane errors i1ike overpayments if an individual 
fiound work but continued to, receive p-ayment. 
During the pandemic, the employer to workforce, agency feedback l1oop was 
removed. This effectfrovely took the brakes off the system. With a trill",0111 doll,ars of 
unemployment entering the ,economy, relaxed controls. and ·fewer ffeedback 
loops, co11ditio11s were ideal for a criminal "Super Bowl." 
It will U ely take years to folly audit the fraud that happened during the 
pandemic. It is quite possible they wHI never be able to fully a1udit the fraud dlue 
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to its vast scale. In the interim, all available data points from the states. experts. 
and our data supports $400 billion dollars lost. 
Footnotes 
1. Pandt:micevffsight.i,ov. "funding Ove~: Acussed Janwity 20. 2022. https://w-.p•ndemlcovenlght.gOY/dau,4num•ctn'e-, 
tools/fundin.g~vervlew 
2. hnps://www,olg.dol.,gov/pubflUrecporu/o.no21119.z1.ooc..o3.31s.pdf 
3. "fAC(s • Gcnc:ret Unemploymc,nt lnsur4nu1,"Vltp\l,1 Employment Commission, .«eu~ Jo--,u•ry 17, 
2022. https:/fwww.vec.virginia.3ov/faqd3ene,al•unempklym-ent•i.nsu:ranc.e-
que,,donsf:--:textsCurrentl~20the%20meximum%20weekly%20bcnefit.ea.med%20in~20the%.20base-%20perk,d.. 
, . hupw'/www.otg,dol,gov/public/reporu/oa/2021/19-21-004-03-315,pdf 
$. ~Gov. WM:me< sohdlflH •nwfr•ud mc.surts to pro.«t uncmplO)'CO wor~rs. • M'C:h!gan Otp• rvnl!flt of Labor and Economk Opporwnlty, 29 O«. 
2021, hups://www.michigan.gov/leo/0,5863,7,336,94422_97241_98585_99416_986S7•574687-,00.html 
6. Christi~ Sob ond Nielson, Steve. -SCommers got SS..8 billion In frtlludt.ilen.! joble-:ss p.,ymen:-S from Ari: 0n11 OES: FOX 10 Phoeni~ 30 Sept. 
202\, https~/www,tox10phoenl.1t.co1'1Vnew..s/5-&--bfllion•ln•fraudule-nts..Jobi.s.t-paymenl$-wer~sent-out-by-de 
7. Beam, Adam. "Ca.llfornla's untmploy,,t,tnt fraud reaches at ltast S20 bilhon,• Los M.ge~s Times. 25, Oct, 
2021. hups://www.latimes.com/california/story/2021-10.25/cAlifornias,unemploym«it•fraud~20.bi1Hon 
8. Kucera, Krls.. lette-.r to John Albin. 16 Ce'- 2020. https://audh:ors.ne-brasko.gov/APA._Reports/2020/SA2l· 12162020-
July .. 1.,.2019. through J um:~30 .. 2020. CAFR...E•rly. Manasemenl., let tu .pdf 
9. Subcommittee on Finandal lnSti'tutioru: and Consume,r ProtK'don Conwnlttee on Banking. HousinS,. and U.rban A/fai~. P.rtttffl'il'tg Co11sv1Mrs from 
Ftnondol F.ro/Jd ond Sc oms in rh• l¾md~mlc R«CNtry fconomy. CongrnJionof testimony. Gres:~. Ro<:hicl, 3Aug. 
2021, https://www.lMnking.unate.gov/imo/media/doc/Gre-s;zlet'%20Testimon~208·l ·Z1.pdf 
10. Podku~ Ce.:,,uy, "How Unemploymen: Insurance ~aud Expk,ded Outing the Pande,mlc." P.roPubllC6, 26 July 
2021, https://www.pt0publka,o,g/ankle/how-une,nployrnent-lnsw,•nc~fraud-e:>tplode-ckSurlng•the--pand~lc 
11. McGt\'e,m, Kylie, '"FBI~ Uniemplc,y,ne,nt fraiid ts•• crlsiS Situation.'" ABC Actlo'1 News, 1 July 2021, hups.;//www.•bc•cclonnews,coMlnews/local• 
,w;wt,li,tom-inva;tipttt/fbl0 u:nltfflploymc:nt,fr•1.1d•i..,.-crisi1•1in.1aUon 
12. 12. {tllfolla, Robert. •p an~k fraud may shift,. bring more buSiness costs." Bloombe,tg l4w. 18 Au:gu~n 
2-021. https://new1..bloombergfaw.com/d.tlly-labonepwt/p,1nd~mk•wnemployment•fraud•m•y•shfft~bring-rnore-buslne,n-<oiu 
13. Has.sold, Cra1te, "Scattered Canary Cyberolme Ring Exploits the COVJ0· 19 Pandemic wtth ffaudulent Unempl~t and CARES Act 
Claims.""~. 19 May 2020, hup1://www.•g•ri.com/emall,1«urlty•blogtcovld--1._unc:mploym,mt>fraud•car••ctl 
14. ~OOl-OIG Ovt-rllght of ;:1,.,c Un,cmployme:nt lnsuro.nc.c Progr•n\ • United Swm Oeportm-enr of (c,t,or, o-cce$Si1Cd 17 J•n. 
2022, https;//www.oi;g.dol.gov/do1olguiover$lShtwork.htm 
15. '1.lnemployment Insurance Protections in Response to COVID-19: St.ate Oe,.,e,lop,mMts," Natk>MI Empfoyf,u.m low Ptofttt,. 27 Match 
2020, huprd/www,Mlp.org/publiution/unc.mployment~inwr•n«r-protectiof\l•r•sponM-c.ovid•19-tt•te-dev•loprntnW 
16. '"l..,bor s«rettry lssue:s O!~ to &nplO')'micnt Ot:11e.lopmcnt 0t-J),frvncnt to Svtipcnd Unempfoymcnt lnsur•ncc Cc:rtiflamons." Colifornk, lobor 
ond Wo.rkforc.• DtwlopmMt "8•ncy. 23 April 2020, http.s:/lwww.l,11.bor.ce.gov/2020/'04/23/la bo r-ucret.ory•'5sues,di rec-tive-t.o•emp loyment• 
d~op~nt-department-to-su.spcmcklnemploym.ent-lnsur•Me-<el't.tficadons/ 
17.0alfy, RyM, "'De Santis Waives Unemployment Re-cero"fkation Rul~ In Effort To Spee-d Cleal'fif1g Of Massive IHd:log." WUST Pvbfrc MedlO. 16Apnl 
2020, ht1:p~lwusfnc:wJ.wusf.u d.ffu/2020-04-16/d~nti1•waive:,:-unemploy~nt•re-certific.ation•rule-in~ffor1•to,speicd•de0-ring-of, 
mHsive-backlog 
18. "'Weut:iw Otd~r 2020-76: Temporary eicpansions in un~ploymcnI eligibility a.nd cos:-sharing - RESCINDEO; MichiJO"l,BfN. accessed l 7 ~n. 
2022. hup.s:/fwww.mkh1.gan,gov/whitmer/0,9309,7-l87-90499. to'10S-U.84.56-,00,htn'II 
1St •cOVID•l 9: Sates Scruggled io lmplicmicnt CARES Act UncmplO)'ment tnsvr.tnce PtogTams." U.S. ~m~ t of Lo-lx>r; 28 M•y 
2021. https:/fwww.oig.dol.gov/public/reporu/oanOZ1f1~21-004..03,l 1S.pdf 
20. "'COVID-t 9: S~u.•s StnJsg!ed to l.m.p!ement CARES An Ur.employment Jnsu(,9nce ProgrMns: U.S. b~rtm~n! of Labo,-, 28 M4y 
2021. hups://www.oig,dol.gov/pubUc/reports/o.a/2021/1._21-004.()3-31S.pdf 
21. Hammel. Paul. 'Audit()( alleges lax o-.-ersight o,,et «wld 1e!lef payments by Nebr.,sk.a lab« OepartmH!t," 01'1'Ktho World fktold, 16 Dec. 
2020. https://omaha.com/n,:w,Jstate-and•regional/g:ovr .... nd,politlCJ{auditor••lleges•l• .. oversight•ove.r-covid,relief..payments•by, 
nebfaska·labor-departmentlertide_96f3d'1d2•3fdf.11eb--a7bd•b7SdO84eed76.htmJ 
22. ·ocs Expands 10.M~ l~tity Verfficati0t1 fot Pandemic Unempk)yffl~t Assistance (l<)im.,nts: kilOl'IO D,po.rtmtm of fo:,.,,cmk Sttvtity, 19 Nov. 
2020, https://dewi..gov/tltttfdefault/flles:/medla/new•~eHe-11-19-2020-0ES..hp•ndt-lO.tne-ldentlty•VerlflcatM>n,pdfl 
tlm•=1622851639S90 
23. PodkuL Cei.aty, "How Unemp'°)'mem ln.wrance naud Exploded Outing the Pandemic.· ProPubliu, 26 Juty 
2021, https://www.propublka.org/a.rtkle/how•unemployment•ins.uranc.e-fraud•exploded-durlns•th.-pandemic 
Tags 
( ID.me ) ( ldontfty ) { Identity Auchtntkatlon ) ( ldontlty Vorinc.~tlon ) ( S.curity & fr-,11ud ) 
Case 3:21-md-02992-GPC-MSB     Document 590-21     Filed 10/17/25     PageID.40552 
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