Clean Long-Form Notice — Brooks v. Thomson Reuters Corporation (Dkt. 261.2)

Record facts

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 261-2 · 2024-10-15 · Docket on CourtListener

Summary

A court-authorized long-form class action notice, Document 261-2, filed October 15, 2024 in Brooks v. Thomson Reuters Corp., Case No. 3:21-cv-01418-EMC, in the U.S. District Court for the Northern District of California. It describes a proposed $27,500,000 settlement of claims that Thomson Reuters made information about California residents available for sale through its CLEAR product, which Thomson Reuters denies. The notice defines the class as people who resided in California between December 3, 2016 and October 31, 2024 whose information was made available through CLEAR, and estimates payments of between $19 and $48. December 6, 2024 is the deadline to submit a claim form, object or opt out, and a settlement approval hearing is set for February 13, 2025. Class counsel will request up to $6,875,000, or 25% of the fund, in fees and up to $700,000 in costs.

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Class Action Notice 
Authorized by the U.S. District Court 
 
 
Did you reside in 
California for 
any period of 
time between 
December 3, 
2016 and 
October 31, 
2024? 
 
 
There is a 
$27,500,000 
settlement of a 
lawsuit.  
 
You may be 
entitled to 
money.  
 
The amount 
depends on the 
number of claims 
submitted but is 
estimated 
between $19 and 
$48. 
 
 
To be part of this 
settlement, you 
should:  
 
Read this notice. 
 
Respond by 
December 6, 2024. 
 
 
 
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: www.ClearPrivacySettlement.com.  
United States District Court for the Northern District of 
California 
Brooks v. Thomson Reuters Corp. 
Case No. 3:21-cv-01418 
Case 3:21-cv-01418-EMC     Document 261-2     Filed 10/15/24     Page 1 of 13

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Table of Contents 
 
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? .............................................................................. 6 
How do I know if I am part of this settlement? ............................................................ 6 
How much will my payment be? ................................................................................... 7 
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 
 
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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 
Form 
You must submit a claim to receive payment. You will be 
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 submit a claim form: December 6, 2024 
Your deadline to object or opt out: December 6, 2024  
Settlement approval hearing: February 13, 2025  
Learning About the Lawsuit 
What is this lawsuit about? 
In December 2020, this class action 
lawsuit was filed against Thomson 
Reuters. The lawsuit was 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. The lawsuits claim that Thomson 
Reuters violated Californians' privacy rights by selling access to their 
personal information without Californians' consent. 
Thomson Reuters denies that it did anything wrong. 
All of the case documents that have been filed publicly in this case are 
also available online through the Court's Public Access to Court 
Electronic Records (PACER) system at https://ecf.cand.uscourts.gov. 
This case is called Brooks v. Thomson Reuters Corp. and the case 
number is 3:18-cv-01418-EMC. You may obtain case documents by 
visiting the office of the Clerk of the Court for the United States District 
Court for the Northern District of California, San Francisco Division, 
between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding 
Court holidays. 
Why is there a settlement in this lawsuit? 
Where can I learn more? 
You can get a complete copy of 
the proposed settlement and 
other key documents in this 
lawsuit at:  
www.ClearPrivacySettlement.com 
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In 2024, the parties agreed to settle, which 
means they have reached an agreement to 
resolve the lawsuit. Both sides want to avoid 
the risk and expense of further litigation.  
The settlement is on behalf of the 
Californians who brought the case and all 
members of the settlement class, which 
includes all persons who, between 
December 3, 2016 and October 31, 2024, 
both resided in the State of California and 
whose information Thomson Reuters made 
available through the CLEAR product. The 
Court has not decided this case in favor of either side. 
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: 1:30 p.m. PT on February 13, 2025. 
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 www.ClearPrivacySettlement.com.  
Learning About the Settlement  
What is a class action 
settlement? 
A class action settlement is 
an agreement between 
the parties to resolve and 
end the case. Settlements 
can provide money to 
class members and 
changes to the practices 
that caused the harm.  
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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 Reuters has agreed 
to implement, can be found at www.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 www.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 
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3, 2016 and October 31, 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. 
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 
Claim 
Opt out 
Object 
Do 
Nothing 
Can I receive settlement 
money if I . . . 
YES 
NO 
YES (If 
you also 
submit a 
claim) 
NO 
Am I bound by the terms of 
this lawsuit if I . . . 
YES 
NO 
YES 
YES 
Can I pursue my own case if 
I . . . 
NO 
YES 
NO 
NO 
Will the class lawyers 
represent me if I . . . 
YES 
NO 
NO 
YES 
 
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Choose the best path for you: 
Are you satisfied with 
the proposed 
settlement?
Yes
Do you want to 
receive a payment?
Yes
Submit a claim 
form
No
Do nothing
No
Do you want to file 
your own lawsuit 
or not be bound by 
this lawsuit?
Yes
Opt out of 
the 
settlement
No
I don't like the 
proposed 
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 
www.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 31, 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 December 6, 2024 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 
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 
 
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 that will be received by December 6, 2024 
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 www.ClearPrivacySettlement.com and either submit the 
opt-out form online at www.ClearPrivacySettlement.com or mail it to 
the Settlement Administrator at: 
 
CLEAR Privacy Settlement  
Attn: Opt Outs 
P.O. Box 58220 
Philadelphia, PA 19102 
 
Whether you submit the opt-out form online or send it by mail, it must 
be received by the settlement administrator by December 6, 2024 to 
be valid. 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 
www.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 December 6, 2024; 
(2) includes the case name and number (Brooks v. Thomson Reuters 
Corp., No. 3:21-cv-01418) 
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(3) includes your full name, address and telephone number, and email 
address (if you have one); 
(4) states the reasons for your objection;  
(5) says whether either you or your lawyer intend to appear at the final 
approval hearing and your lawyer's name;  
(6) your signature. 
Your letter must be received by the Court by December 6, 2024 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 
You may also file your objection on the docket in this Action through 
the Court's PACER or Electronic Case Filing system by December 6, 
2024. For instructions on how to file, visit 
www.cand.uscourts.gov/cases-e-filing/. 
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 
www.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 
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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 www.ClearPrivacySettlement.com 
• access the Court Electronic Records (PACER) system online or by 
visiting the Clerk’s office of the Court (address below). 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Resource 
Contact Information 
Case website  
www.ClearPrivacySettlement.com 
Settlement 
Administrator  
CLEAR Privacy Settlement 
c/o Settlement Administrator 
1650 Arch Street, Suite 2210 
Philadelphia, PA 19103 
1-855-969-4049 
info@clearprivacysettlement.com 
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 
CONTACT) 
U.S. District Court 
San Francisco Courthouse, Courtroom 5 - 17th 
Floor 
450 Golden Gate Avenue 
San Francisco, CA 94102 
Case 3:21-cv-01418-EMC     Document 261-2     Filed 10/15/24     Page 13 of 13

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