Court filing
[Redacted] Declaration of Steven Weisbrot — Brooks v. Thomson Reuters Corporation (Dkt. 250.1)
No. 3:21-cv-01418-EMC · Doc. 250-1 · Docket on CourtListener
Full text
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 1 of 30
1 Andre M. Mura (SBN 298541) Geoffrey A. Graber (SBN 211547)
Ezekiel S. Wald (SBN 341490) Karina G. Puttieva (SBN 317702)
2 GIBBS LAW GROUP LLP COHEN MILSTEIN SELLERS &
1111 Broadway, Suite 2100 TOLL PLLC
3 1100 New York Ave. NW, Fifth Floor
Oakland, CA 94607
4 Telephone: (510) 350-9700 Washington, DC 20005
Facsimile: (510) 350-9701 Telephone: (202) 408-4600
5 amm@classlawgroup.com Facsimile: (202) 408-4699
zsw@classlawgroup.com ggraber@cohenmilstein.com
6 kputtieva@cohenmilstein.com
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Attorneys for Plaintiffs and the Class
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12 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
13 SAN FRANCISCO DIVISION
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CAT BROOKS and RASHEED Case No. 3:21-cv-01418-EMC-KAW
15 SHABAZZ, individually and on behalf of
all others similarly situated,
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Plaintiffs, SUPPLEMENTAL DECLARATION OF
17 STEVEN WEISBROT OF ANGEION GROUP
v. RE: SETTLEMENT ADMINISTRATION
18 PROTOCOL & PROPOSED NOTICE PLAN
THOMSON REUTERS CORPORATION,
19 Redacted - Publicly Filed Version
Defendant.
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Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 2 of 30
1 I, Steven Weisbrot, declare and state as follows:
2 1. I am the President and Chief Executive Officer at the class action notice and claims
3 administration firm Angeion Group, LLC (“Angeion”). Angeion specializes in designing,
4 developing, analyzing, and implementing large-scale, un-biased, legal notification plans.
5 2. My credentials were provided in my previous declaration describing the proposed
6 Notice Plan (“Notice Plan Declaration”) (Dkt. No. 241-2).
7 3. The purpose of this declaration is to provide the Court with additional information
8 pursuant to this Court’s Order re: Supplemental Briefing and/or Evidence (“Order”) (Dkt. No. 246).
9 CLASS SIZE, CLAIMS RATE & ESTIMATED AWARD AMOUNT
10 4. Angeion has been informed that while determining the class size with exact precision
11 is not possible, it is Angeion’s understanding the estimated class size to be approximately forty
12 million people based on data from the U.S. Census Bureau. See Plaintiffs’ Motion for Preliminary
13 Approval (Dkt. No. 241 at 8-9).
14 5. Angeion previously estimated that the claims rate in this settlement will be between
15 1% and 2.5%. Notice Plan Declaration, ¶ 45.
16 6. For illustrative purposes, the chart below provides the total number of claims that
17 correspond to claims rates of 1% and 2.5% based on a class size of forty million individuals.
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Claims Rate Total Claims
19 1.00% 400,000
2.50% 1,000,000
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7. The chart below illustrates the estimated per claim award amounts based on these
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claims rates. Note: the number of claims submitted affects the estimated total administration costs.
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The estimated award amounts also assume Attorneys’ Fees in the amount of $6,875,000.00,
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Expenses in the amount of $700,000.00, and Service Awards totaling $10,000.00.
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Claims Rate Estimated Award Amount
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1.00% $48.78
26 2.50% $19.43
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Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 3 of 30
1 SETTLEMENT NOTICE & ADMINISTRATION COSTS
2 8. Angeion’s detailed estimate to provide notice and administration services is attached
3 hereto as Exhibit A. Pursuant to the Court’s Order, Angeion respectfully requests that this Exhibit be
4 filed under seal.
5 9. Included in Exhibit A is Angeion’s adjusted detailed estimate assuming a class size of
6 40,000,000 and a 2.5% claim filing rate. Additional costs for publication and translation services
7 (discussed below) have also been incorporated into this revised estimate.
8 ADDITIONAL NOTICE DETAILS
9 10. This section addresses the questions posed in sections G, H, and I of the Order.
10 Should there be some kind of publication notice as well in recognition that all class members
11 may not use computers or use them in such a way that they would be exposed to the proposed
12 media campaign?
13 11. After conferring with the Parties, notice of the settlement will be published in the
14 California regional edition of USA Today for a duration of five (5) weeks. One (1) black and white
15 ¼-page insertion in the California regional edition of USA Today will be published each week
16 commencing seven (7) days after an Order granting preliminary approval is entered and concluding
17 on or around thirty-five (35) days after the issuance of that Order.
18 The class is defined as those who lived in California during a set period of time. Can the parties
19 provide more information as to how people who moved away from California will get notice if
20 the target audience is primarily California residents?
21 12. The Notice Plan Declaration provides for an additional allocation of digital and social
22 media advertisements to be served both nationally and specifically targeted within the top six states
23 where Californians have relocated over the class period.1 Id. ¶ 31.
24 A settlement website will be maintained, with copies of the long-form notice available in English
25 and Spanish. See Mot. at 4. Should the notice be available in other languages given the diverse
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27 1
See 2023 Allied US Moving Migration Report, https://www.allied.com/migration-map (Last visited
September 17, 2024).
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1 population in California?
2 13. The United Census Bureau - California State Profile indicates that English and Spanish
3 account for nearly 84% of the language type spoken at home in California, with “Asian and Pacific
4 Islander languages” accounting for 10.2%.2 Further, Census 2020 identified the top five (5) non-
5 English languages spoken in California as: Spanish, Chinese, Vietnamese, Tagalog, and Korean.3
6 14. The additional cost to translate the Long-Form Class Notice is provided in Exhibit A.
7 While it has been Angeion’s experience that making the Long-Form notice available in multiple
8 languages is not common, even in California classes/subclasses, Angeion is prepared to translate the
9 notices as directed by the Court.
10 15. It is also worth noting that if needed, Angeion can utilize its live translation services
11 that are designed to support over 350 different languages to provide support to Settlement Class
12 Members.
13 Could the settlement administrator contact class members to clear up any conflicts? (where
14 both a claim form and opt out is submitted)
15 16. Angeion will work with Class Counsel to resolve any conflicts in which Settlement
16 Class Members submit both a claim form and exclusion form.
17 Language of Class Notice (Section I of the Order)
18 17. The Long-Form Class Notice has been revised to incorporate the edits outlined in the
19 Order and is attached hereto as Exhibit B. It is important to note that Angeion generally advises
20 against providing an estimated payment amount in the notice(s) when that payment amount is
21 determined by the number of valid claims submitted. It has been Angeion’s experience that if the
22 number of claims submitted deviates from what was anticipated, resulting in a lower payment amount
23 than estimated, the class member reaction is both vocal and strongly negative. This is in contrast to
24 similar settlement payment amounts where the award amount was not provided in the notice, i.e., not
25 creating expectations from class members and the class member response to the payment amount
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See United Census Bureau: California State Profile
27 https://data.census.gov/profile/California?g=040XX00US06 (Last visited September 19, 2024);
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https://census.ca.gov/wp-content/uploads/sites/4/2019/06/LACAP.pdf (Last visited September 19, 2024)
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1 issued was negligible, if not non-existent.
2 18. The Claim Form requirement that a claimant provide their exact California address
3 was deliberate as part of our holistic defense-in-depth fraud prevention efforts. The California address
4 requirement has been removed but text was added to the attestation section that states: “I understand
5 that the Settlement Administrator may contact me to request additional information to confirm my
6 membership in the Settlement Class and that failure to provide the Settlement Administrator with the
7 requested information may result in the denial of my Claim Form.” The revised Claim Form is
8 attached hereto as Exhibit C.
9 19. The Exclusion Form has been revised to inform Settlement Class Members that they
10 may submit their Exclusion Form online at ClearPrivacySettlement.com, or by completing and
11 submitting the Exclusion Form by mail. The revised Exclusion Form is attached hereto as Exhibit D.
12 20. The Sample Digital Ads have been revised to state: “If you resided in California for
13 any period of time between December 3, 2016 and [October 30, 2024], you may be entitled to a
14 payment from a class action settlement. Click here for more information.” We incorporated the
15 reference to a settlement payment but recommend against adding additional text, such as an estimated
16 payment range, which would decrease the font size displayed on the ads, potentially making them
17 difficult to read. Once the digital ad is clicked, the individual is directed to the Settlement Website
18 where additional information about the Settlement, including the estimated payment amounts, will be
19 prominently displayed pursuant to the Court’s instruction. The revised Sample Digital Ads are
20 attached hereto as Exhibit E.
21 CONCLUSION
22 21. As discussed in the Notice Plan Declaration, the proposed Notice Plan provides for a
23 comprehensive state-of-the-art multi-faceted media campaign designed to deliver an approximate
24 75.30% reach and the implementation of a dedicated Settlement Website and toll-free telephone line
25 where Settlement Class Members can learn more about their rights and options pursuant to the terms
26 of the Settlement. This percentage is calculated using objective syndicated advertising data relied
27 upon by most advertising agencies and brand advertisers. It is further verified by sophisticated media
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1 software and calculation engines that cross reference which media is being purchased with the media
2 habits of our specific Target Audience. What this means in practice is that 75.30% of our Target
3 Audience will see an advertisement concerning the settlement an average of 3.09 times each.
4 22. The Federal Judicial Center states that a publication notice plan that reaches 70% of
5 class members is one that reaches a “high percentage” and is within the “norm.” Barbara J. Rothstein
6 & Thomas E. Willging, Federal Judicial Center, “Managing Class Action Litigation: A Pocket Guide
7 or Judges,” at 27 (3d Ed. 2010).
8 23. It remains my professional opinion that the proposed Notice Plan will provide full and
9 proper notice to Settlement Class Members and is the best practicable notice under the circumstances,
10 fulfilling all due process requirements, fully comporting with Fed. R. Civ. P. 23, and the Northern
11 District’s Procedural Guidance for Class Action Settlements.
12 I hereby declare under penalty of perjury that the foregoing is true and correct.
13 Dated: September 25, 2024
____________________
14 STEVEN WEISBROT
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EXHIBIT FILED UNDER SEAL
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 8 of 30
EXHIBIT B
REVISED LONG-FORM NOTICE
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 9 of 30
United States District Court for the Northern District of
California
Brooks v. Thomson Reuters Corp.
Case No. 3:21-cv-01418
Class Action Notice
Authorized by the U.S. District Court
Did you reside in There is a To be part of this
California for any $27,500,000 settlement, you
period of time settlement of a should:
between lawsuit.
December 3, 2016 Read this notice.
and [October 30, You may be
2024]? entitled to money. Respond by [date].
The amount
depends on the
number of claims
submitted but is
estimated between
$19 and $48.
Important things to know:
• If you take no action, you will still be bound by the settlement, and your rights
will be affected.
• You can learn more at: ClearPrivacySettlement.com.
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 10 of 30
Table of Contents
Table of Contents .............................................................................................................. 2
About This Notice .............................................................................................................. 3
Why did I get this notice? ...................................................................................................................... 3
What do I do next? ................................................................................................................................... 3
What are the most important dates?................................................................................................. 4
Learning About the Lawsuit ............................................................................................. 4
What is this lawsuit about?.................................................................................................................... 4
Why is there a settlement in this lawsuit?........................................................................................ 4
What happens next in this lawsuit? .................................................................................................... 5
Learning About the Settlement ....................................................................................... 5
What does the settlement provide? ................................................................................................... 5
How do I know if I am part of this settlement?.............................................................................. 6
How much will my payment be? ......................................................................................................... 6
Deciding What to Do ......................................................................................................... 7
How do I weigh my options? ................................................................................................................ 7
Submitting a Claim ............................................................................................................ 9
How do I get a payment if I am a class member? ......................................................................... 9
Do I have a lawyer in this lawsuit? ...................................................................................................... 9
Do I have to pay the lawyers in this lawsuit? ................................................................................ 10
Opting Out ........................................................................................................................ 10
What if I don't want to be part of this settlement? .................................................................... 10
How do I opt out?................................................................................................................................... 11
Objecting .......................................................................................................................... 11
What if I disagree with the settlement? .......................................................................................... 11
Doing Nothing ................................................................................................................. 12
What are the consequences of doing nothing? .......................................................................... 12
Key Resources .................................................................................................................. 12
How do I get more information? ...................................................................................................... 12
2
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 11 of 30
About This Notice
Why did I get this notice?
This notice is to tell you about the settlement of a class action lawsuit,
Brooks v. Thomson Reuters Corp. brought on behalf of current and former
California residents who allege that Thomson Reuters made information
about them available for sale through its product, CLEAR. You received
this notice because you may be a member of the group of people
affected, called the “class.” You may be entitled to monetary relief as
a part of this class action settlement. At this time, it is impossible to
precisely estimate how much money is available per class member, as
it will depend on how many class members submit claims. Current
estimates suggest that you may be entitled to between $19 and $48.
This notice gives you a summary of the terms of the proposed settlement
agreement, explains what rights class members have, and helps class
members make informed decisions about what action to take.
What do I do next?
Read this notice to understand the settlement and to determine if you are
a class member. Then, decide if you want to:
Options More information about each option
Submit a Claim You must submit a claim to receive payment. You will be
Form bound by the settlement.
Do Nothing Get no payment. Give up rights resolved by settlement.
Opt Out Get no payment. Allows you to bring another lawsuit
against Thomson Reuters about the same issues.
Object Tell the Court why you don’t like the settlement. If you
object, you are still a member of the class unless you also
submit a timely opt out. If you object, you must also submit
a claim form to receive money.
Read on to understand the specifics of the settlement and what each
choice would mean for you.
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What are the most important dates?
Your deadline to object or opt out: [date]
Settlement approval hearing: [date]
Your deadline to submit a claim form: [date]
Learning About the Lawsuit
What is this lawsuit about?
In December 2020, this class action lawsuit was
filed against Thomson Reuters. The lawsuit was Where can I learn
brought on behalf of current and former more?
California residents who allege that Thomson You can get a complete copy
Reuters made information about them available of the proposed settlement
for sale through its product, CLEAR. The lawsuits and other key documents in
claim that Thomson Reuters violated this lawsuit at:
Californians' privacy rights by selling access to ClearPrivacySettlement.com
their personal information without Californians'
consent.
Thomson Reuters denies that it did anything wrong.
Why is there a settlement in this lawsuit?
In 2024, the parties agreed to settle, which
means they have reached an agreement to
What is a class action
resolve the lawsuit. Both sides want to avoid settlement?
the risk and expense of further litigation. A class action settlement is
an agreement between the
The settlement is on behalf of the Californians parties to resolve and end
who brought the case and all members of the the case. Settlements can
settlement class, which includes all persons provide money to class
who, between December 3, 2016 and [October members and changes to
30, 2024], both resided in the State of the practices that caused
California and whose information Thomson the harm.
Reuters made available through the CLEAR
product. The Court has not decided this case in favor of either side.
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What happens next in this lawsuit?
The Court will hold a Fairness hearing to decide whether to approve the
settlement. The hearing will be held at:
Where: United States District Court for the Northern District of California,
San Francisco Courthouse, Courtroom 5, 17th Floor, 450 Golden Gate
Avenue, San Francisco, CA 94102
When: [time] on [date].
The Court has directed the parties to send you this notice about the
proposed settlement. Because the settlement of a class action decides the
rights of all members of the proposed class, the Court must give final
approval to the settlement before it can take effect. Payments will only be
made if the Court approves the settlement.
You don’t have to attend, but you may at your own expense. You may also
ask the Court for permission to speak and express your opinion about the
settlement. If the Court does not approve the settlement or the parties
decide to end it, it will be void and the lawsuit will continue. The date of
the hearing may change without further notice to members of the
class. To learn more and confirm the hearing date, go to
ClearPrivacySettlement.com.
Learning About the Settlement
What does the settlement provide?
The settlement provides both monetary and injunctive relief to class
members. More specifically, the settlement pays money to current and
former California residents whose information was allegedly made
available through Thomson Reuters' product, CLEAR, and will require
Thomson Reuters to change some of its practices in operating CLEAR.
Thomson Reuters has agreed to enhance its opt-out procedure for
Californians looking to delete their personal information from CLEAR or
review the information about them in CLEAR, make more information
about CLEAR available to Californians who want to know more about how
their information is used, and make a series of changes to CLEAR's settings
and Thomson Reuters' practices in managing CLEAR. The full terms of the
settlement, including the specific business practice changes that Thomson
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Reuters has agreed to implement, can be found at
ClearPrivacySettlement.com.
Thomson Reuters has agreed to pay $27,500,000 into a settlement fund.
This money will be divided among the class members and will also be used
to pay for costs and fees approved by the Court, including attorneys' fees
(which is $6,875,000 or 25% of the settlement fund), attorneys' costs
incurred in litigating this case (which will not exceed $700,000) and the
cost of administering this settlement (expected to be no more than
$485,000). After deductions, remaining funds will be divided equally
among class members who timely submit claim forms. A precise estimate
of the amount each class member will receive is not possible at this time,
as it depends on the number of claims that are submitted. However,
based on current estimates, it is expected that class members may
receive between $19 and $48. Members of the settlement class will
“release” their claims as part of the settlement, which means, at a
minimum, they cannot sue Thomson Reuters for the same issues in this
lawsuit. The full terms of the release can be found at
ClearPrivacySettlement.com.
If there is money left over after the claims process is completed, it will be
donated to organization(s) approved by the Court.
How do I know if I am part of this settlement?
If you resided in California for any period of time between December 3,
2016 and [October 30, 2024], and were 18 years old (or older) during that
time, you may be a member of the class and entitled to money.
How much will my payment be?
The amount of the payments to individual class members will depend on
the number of valid claims submitted. Because the final payment amount
cannot be calculated before all claims for compensation are received and
verified, it is not possible to provide the precise amounts of the payment
for each valid claim before the deadline to file claims. However, based on
current estimates, individual class members can expect to receive
between $19 and $48.
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Deciding What to Do
How do I weigh my options?
You have four options. You can stay in the settlement and submit a claim,
you can opt out of the settlement, you can object to the settlement, or you
can do nothing. This chart shows the effects of each option:
Submit a Do
Opt out Object
Claim Nothing
YES (If
Can I receive settlement you also
YES NO NO
money if I . . . submit a
claim)
Am I bound by the terms
YES NO YES YES
of this lawsuit if I . . .
Can I pursue my own case
NO YES NO NO
if I . . .
Will the class lawyers
YES NO NO YES
represent me if I . . .
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Choose the best path for you:
Are you satisfied with the
proposed settlement?
Yes No
Do you want to Do you want to file
receive a payment? your own lawsuit or
not be bound by this
lawsuit?
Yes No
Yes No
Do nothing
Submit a claim I don't like the
Opt out of
form proposed
the
settlement settlement (but
want to be a part
of it still)
Object in writing
and/or appear in
court to explain
why you don't like
it. You are still a
member of the
class, and are still
entitled to money if
you submit a claim
form
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Submitting a Claim
How do I get a payment if I am a class member?
If you wish to receive money, you must submit a completed claim form to
the Settlement Administrator online or download a claim form at
ClearPrivacySettlement.com and mail a completed form to the Settlement
Administrator (address below). To submit a proper claim form, you will
have to sign a statement that you lived in California for any period of time
between December 3, 2016 and [October 30, 2024]. That statement will be
made under penalty of perjury, which means that if you knowingly provide
false information in that statement, it is a felony.
You must submit a claim form by [date] to receive money from the
settlement.
Do I have a lawyer in this lawsuit?
In a class action, the court appoints class representatives and lawyers to
work on the case and represent the interests of all the class members. For
this settlement, the Court has appointed the following individuals and
lawyers.
Your lawyers:
Andre M. Mura Geoffrey A. Graber
Gibbs Law Group LLP Cohen Milstein Sellers & Toll PLLC
1111 Broadway, Suite 2100 1100 New York Ave. NW, Fifth
Oakland, CA 94067 Floor
Washington, DC 20005
These are the lawyers who negotiated this settlement on your behalf.
If you want to be represented by your own lawyer, you may hire one at
your own expense.
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Do I have to pay the lawyers in this lawsuit?
Lawyers' fees and costs will be paid from the Settlement Fund. You will
not have to pay the lawyers directly.
To date, your lawyers have not been paid any money for their work or the
expenses that they have paid for the case. To pay for some of their time
and risk in bringing this case without any guarantee of payment unless
they were successful, your lawyers will request, as part of the final approval
of this Settlement, that the Court approve a payment for their legal
services, a request that will not ask for more than $6,875,000 (25%) total in
attorneys’ fees plus the reimbursement of out-of-pocket expenses (which
will not exceed $700,000). Your lawyers will also ask the Court to approve
the costs of administering this settlement as those costs are incurred,
which are currently estimated to be $485,000.
Lawyers' fees and expenses will only be awarded if approved by the Court
as a fair and reasonable amount. You have the right to object to the
lawyers' fees even if you think the settlement terms are fair.
Your lawyers will also ask the Court to approve a payment of $5,000 to
each of the two Class Representatives for the time and effort they
contributed to the case. If approved by the Court, this will be paid from
the Settlement Fund.
Opting Out
What if I don't want to be part of this settlement?
You can opt out. If you do, you will not receive payment and cannot object
to the settlement. However, you will not be bound or affected by anything
that happens in this lawsuit and may be able to file your own case. You
cannot exclude yourself from the program changes called for by the
proposed settlement. The section below tells you how to submit an opt
out (by mail or online).
You must submit an opt out by [date] to exclude yourself from the
settlement.
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How do I opt out?
To opt out of the settlement, you must complete the opt out form
available at ClearPrivacySettlement.com and mail it by [date] to the
Settlement Administrator at:
CLEAR Privacy Settlement
Attn: Opt Outs
P.O. Box 58220
Philadelphia, PA 19102
Be sure to include your name, address, telephone number (and/or email
address), and signature. The full instructions for submitting an opt-out are
available at ClearPrivacySettlement.com.
You may also submit an opt-out form online at
ClearPrivacySettlement.com.
Objecting
What if I disagree with the settlement?
If you disagree with any part of the settlement (including the lawyers' fees)
but don’t want to opt out, you may object. If you object, you are still a
class member, and you must still submit a separate claim form if you want
to receive money from the settlement. When you submit your objection,
you must give reasons why you think the Court should not approve it and
say whether your objection applies to just you, a part of the class, or the
entire class. The Court will consider your views. The Court can only
approve or deny the settlement — it cannot change the terms of the
settlement. You may, but don’t need to, hire your own lawyer to help you.
To object, you must send a letter to the Court that:
(1) is received by [date];
(2) includes the case name and number (Brooks v. Thomson Reuters Corp.,
No. 3:21-cv-01418)
(3) includes your full name, address and telephone number, and email
address (if you have one);
(4) states the reasons for your objection;
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(5) says whether either you or your lawyer intend to appear at the final
approval hearing and your lawyer's name;
(6) your signature.
You must mail your letter to the Court by [date] for your objection to be
valid. Mail the letter to:
U.S. District Court
San Francisco Courthouse,
Courtroom 5 - 17th Floor
450 Golden Gate Avenue
San Francisco, CA 94102
Doing Nothing
What are the consequences of doing nothing?
If you do nothing, you will not get any money, but you will still be bound
by the settlement and its “release” provisions. That means you won’t be
able to start, continue, or be part of any other lawsuit against, at minimum,
Thomson Reuters about the issues in this case. Please see the settlement
agreement, which can be found at ClearPrivacySettlement.com for a full
description of the claims and persons who will be released if this
settlement is approved.
Key Resources
How do I get more information?
This notice is a summary of the proposed settlement. The complete
settlement with all its terms can be found here. To get a copy of the
settlement agreement or get answers to your questions:
• contact your lawyer (information below)
• visit the case website at ClearPrivacySettlement.com
• access the Court Electronic Records (PACER) system online or by
visiting the Clerk’s office of the Court (address below).
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Resource Contact Information
Case website ClearPrivacySettlement.com
Settlement CLEAR Privacy Settlement
Administrator c/o Settlement Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA 19103
[Phone Number]
[Email Address]
Your Lawyers Andre M. Mura
Gibbs Law Group LLP
1111 Broadway, Suite 2100
Oakland, CA 94067
Geoffrey A. Graber
Cohen Milstein Sellers & Toll PLLC
1100 New York Ave. NW, Fifth Floor
Washington, DC 20005
Court (DO NOT U.S. District Court
CONTACT) San Francisco Courthouse, Courtroom 5 - 17th
Floor
450 Golden Gate Avenue
San Francisco, CA 94102
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EXHIBIT C
REVISED CLAIM FORM
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 23 of 30
Brooks v. Thomson Reuters Corp.
Your claim must be
submitted online or Case No. 3:21-cv-01418-EMC TRC
received by: United States District Court, Northern District of California CLAIM
[DEADLINE]
CLEAR PRIVACY SETTLEMENT CLAIM FORM
I. SETTLEMENT CLASS MEMBER NAME AND CONTACT INFORMATION
Provide your name, mailing address, telephone and/or email address. You must notify the Settlement
Administrator if your contact information changes after you submit this Claim Form.
First Name Last Name
Street Address
City State Zip Code
Email Address Telephone Number
II. PAYMENT SELECTION
Please select from one of the following payment options:
Venmo - Enter the mobile number associated with your Venmo account: __ __ __-__ __ __-__ __ __ __
Zelle - Enter the mobile number or email address associated with your Zelle account:
Mobile Number: __ __ __-__ __ __-__ __ __ __ or Email Address: ___________________________________
Virtual Prepaid Card - Enter your email address: ____________________________________
Physical Check - Payment will be mailed to the address provided in Section I above.
III. ATTESTATION & SIGNATURE
By signing below and submitting this Claim Form, I hereby swear under penalty of perjury that I resided in
California for any period of time between December 3, 2016 and [October 30, 2024].
I understand that the Settlement Administrator may contact me to request additional information to confirm my
membership in the Settlement Class and that failure to provide the Settlement Administrator with the requested
information may result in the denial of my Claim Form.
Signature Printed Name Date
Mail your completed Claim Form to:
CLEAR Privacy Settlement, c/o Settlement Administrator, 1650 Arch Street, Suite 2210, Philadelphia, PA 19103.
QUESTIONS? VISIT WWW.CLEARPRIVACYSETTLEMENT.COM OR CALL TOLL-FREE 1-XXX-XXX-XXXX
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 24 of 30
EXHIBIT D
REVISED EXCLUSION FORM
Case 3:21-cv-01418-EMC BrooksDocument 250-1Reuters
v. Thomson FiledCorp.
09/25/24 Page 25 of 30
Your request for Case No. 3:21-cv-01418-EMC
exclusion must be United States District Court, Northern District of California TRC
received by: EXCLUSION
[DATE] CLEAR PRIVACY SETTLEMENT
REQUEST FOR EXCLUSION
Instructions: Visit www.clearprivacysettlement.com to submit your Exclusion Form online or complete and
return this form to: CLEAR Privacy Settlement, Attn: Opt Outs, P.O. Box 58220, Philadelphia, PA 19102.
I. SETTLEMENT CLASS MEMBER NAME AND CONTACT INFORMATION
Provide your name, mailing address, telephone and/or email address.
First Name Last Name
Street Address
City State Zip Code
Email Address Telephone Number
II. SIGNATURE
By signing below and submitting this Request for Exclusion form, I swear under penalty of perjury that I resided
in California for any period of time between December 3, 2016 and [October 30, 2024] and wish to exclude myself
from the Settlement Class and do not wish to participate in the settlement in Brooks v. Thomson Reuters Corp.,
No. 3:21-cv-01418.
Signature Printed Name Date
QUESTIONS? VISIT WWW.CLEARPRIVACYSETTLEMENT.COM OR CALL TOLL-FREE 1-XXX-XXX-XXXX
Case 3:21-cv-01418-EMC Document 250-1 Filed 09/25/24 Page 26 of 30
EXHIBIT E
REVISED SAMPLE DIGITAL ADVERTISEMENTS
cv-01418-EMC Document 250-1 Filed 09/25/24 Pa
If you resided in California
for any period of time
between December 3, 2016
and [October 30, 2024],
you may be entitled to a
payment from a class
action settlement.
Click here for more information
cv-01418-EMC Document 250-1 Filed 09/25/24 Pa
If you resided in California
for any period of time between
December 3, 2016 and
If you resided in California for any
[October
period 30,between
of time 2024], December
you may
3,be entitled
2016 to a payment
and October 17, 2024, a class
action settlement
from a class may affect
action your
settlement.
rights.
Click here for more information
cv-01418-EMC Document 250-1 Filed 09/25/24 Pa
If you resided in California
for any period of time between
December 3, 2016 and [October
30, 2024], you may be entitled
If you resided in California for any
to
period payment
a of time from December
between
3,a2016 and
class October 17, 2024, a class
action
action settlement may affect your
settlement.
rights.
Click here for more information
cv-01418-EMC Document 250-1 Filed 09/25/24 Pa
If you resided in
California for any
period of time
between December
3, 2016 and [October
30, 2024], you may be
entitled to a payment
from a class action
settlement.
Click here for more information
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