Court filing
Exhibit 1 - Declaration of Jonathan Shaffer of Angeion Group — Brooks v. Thomson Reuters Corporation (Dkt. 288.1)
No. 3:21-cv-01418-EMC · Doc. 288-1 · Docket on CourtListener
Full text
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 1 of 13
EXHIBIT 1
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 2 of 13
1 Andre M. Mura (SBN 298541) Geoffrey A. Graber (SBN 211547)
Ezekiel S. Wald (SBN 341490) Karina G. Puttieva (SBN 317702)
2 GIBBS MURA LLP COHEN MILSTEIN SELLERS &
1111 Broadway, Suite 2100 TOLL PLLC
3 Oakland, CA 94607 1100 New York Ave. NW, Suite 800
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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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
12 SAN FRANCISCO DIVISION
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14 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC-KAW
individually and on behalf of all others
15 similarly situated, DECLARATION OF JONATHAN P.
Plaintiff, SHAFFER WITH POST-
16 DISTRIBUTION ACCOUNTING
v.
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18 THOMSON REUTERS CORPORATION,
19 Defendants.
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Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 3 of 13
1 I, Jonathan P. Shaffer, declare and state as follows:
2 1. I am a Senior Project Manager with Angeion Group (“Angeion”), located at 1650
3 Arch Street, Suite 2210, Philadelphia, PA 19103. I am over 21 years of age and am not a party to this
4 action and I have personal knowledge of the facts set forth herein.
5 2. Angeion submitted declarations leading up to Final Approval of the Settlement in this
6 action, detailing the services Angeion provided in: mailing CAFA Notices, creating and implementing
7 a media notice program (including digital banner ads, Social Media ads (Facebook, Instagram,
8 YouTube), Legal Influencer videos (Instagram and TikTok), Paid Search, Sponsored Class Action
9 Website Listing, and a press release), creating a website with an online claims portal, processing
10 Claims and requests for exclusions, corresponding with Claimants, and communicating with the
11 Parties’ counsel regarding each of these steps; and the result of those services. (Dkt. Nos. 273-2 and
12 277).
13 3. On February 21, 2025, the Court granted final approval to the Settlement and ordered
14 that a Post-Distribution Accounting be filed with the Court and posted on the Settlement Website
15 within 21 days after the completion of the distribution of settlement funds (Dkt. No. 80).
16 4. On April 15, 2025, Angeion sent distribution payments to the claimants who submitted
17 valid claims.
18 5. Pursuant to the United States District Court for the Northern District of California’s
19 Procedural Guidance for Class Action Settlements, Angeion Group, LLC submits the following Post
20 Distribution Accounting Report:
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22 SETTLEMENT DETAILS
23 Total Settlement Fund Gross Settlement Fund: $27,646,323.751
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Total Number of Class Members up to 40,000,000
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$27,500,000 in initial funding plus $146,323.75 interest received.
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 4 of 13
1 NOTICE DETAILS
2 Media Notice
3 ▪ Banner Ads
▪ Social Media Ads
4 Methods of Notice ▪ Paid Search
5 ▪ Legal Influencer videos
▪ Sponsored Class Action Website
6 Listing
▪ Press Release
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Total Number of Digital Banner Ad
51,555,443
8 Impressions Served
9 Total Number of Social Media Ad
24,959,875
Impressions Served
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CLAIM FORM SUBMISSIONS, EXCLUSIONS AND OBJECTIONS
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14 752,034 Claim form Submissions
Total Number of Claim Forms Submitted
15 ▪ 750,439 On-line submissions
▪ 1,595 Mail submissions
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Total Number of Valid Claim Forms
125,2412
17 Submitted and Approved
18 Percentage of Valid Claim Forms (relative
0.313%
to Class)
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20 Total Number of Opt-Outs Submitted 50
21 Percentage of Opt-Outs Submitted
0.000001%
(relative to Class)
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23 Total Number of Objections Submitted 0
24 Percentage of Objections Submitted 0.000%
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27 For more information regarding the significant volume of fraudulent claims, see the Declaration of
Steve Weisbrot, ECF No. 273-2 (unredacted and filed under seal at ECF No. 272-3).
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 5 of 13
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2 SETTLEMENT PAYMENT DETAILS
3 Physical Checks sent by the
United States Postal Service
4 (“USPS”) first-class mail,
Method(s) of Payment to Class Members
5 postage prepaid; Venmo,
Zelle and Virtual Prepaid
6 Card.
7 Total Number of Cash Payments Issued to Class Members 125,241
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Total Class Members distributed via ACH (% of Total) 4,434 (3.54%)
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Total Class Members distributed via Checks (% of Total) 10,707 (8.55%)
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11 Total Class Members distributed via PayPal (% of Total) 24,035 (19.19%)
12 Total Class Members distributed via Venmo (% of Total) 35,712 (28.51%)
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Total Class Members distributed via Virtual Prepaid Cards (%
25,055 (20.01%)
14 of Total)
15 Total Class Members distributed via Zelle (% of Total) 25,298 (20.20%)
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Total Cash Amount Distributed to Class Members 19,548,867.69
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Each claimant received
18 Average Recovery Per Claimant
$156.09.
19 Each claimant received
Median Recovery Per Claimant
20 $156.09.
21 As of October 17, 2025, 905
Total Number of Payments Issued to Class Members and Not
checks have not been
22 Cashed/Cleared
cashed.
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As of October 17, 2025,
24 checks worth a total of
Total Value of Payments Not Cashed/Cleared
$141,261.45 have not been
25 cashed.
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As of October 17, 2025,
Total Number of Payments Issued to Class Members that have
27 124,336 checks have
Cashed/Cleared
cashed/cleared.
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 6 of 13
1 As of October 17, 2025,
checks worth a total of
2 Total Value of Payments that have Cashed/Cleared
$19,407,606.24 have
cashed/cleared.
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4 Smallest Payment Amount $156.09
5 Largest Payment Amount $156.09
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Total Amount Remaining in Settlement Fund $136,739.59
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Total Administration Costs $545,000.00
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Attorneys’ Fees $6,875,000.00
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10 Attorneys’ Costs Excluding Expert Costs $402,851.54
11 Expert Costs $268,033.75
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Attorneys' Fees as a Percentage of the Settlement Fund 25%
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Total Attorneys' Fees and Costs $7,545,885.29
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15 Plaintiffs’ counsel’s final lodestar total $5,559,647.50
16 Lodestar Multiplier 1.24
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18 6. A second distribution to Authorized Claimants3 is not economically feasible in my
19 professional opinion. Angeion estimates the administrative cost to effectuate a second round of
20 payments to the 124,336 Authorized Claimants would be approximately $49,167. After deducting
21 anticipated administration costs, there would be approximately $87,572.59 remaining in the
22 Settlement Fund that could be distributed to Authorized Claimants. The pro rata payment amount
23 would be approximately $0.70 per Claimant, as reflected in the chart below. It has been Angeion’s
24 general experience that lower check amounts often result in a higher percentage of uncashed checks,
25 as Class Members are less motivated to cash/negotiate a check for that lower amount. Furthermore,
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27 Authorized Claimants are Class Members who have successfully received their payment and
excludes the 905 individuals who have not yet cashed their checks.
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 7 of 13
1 the costs associated with distributing the payments would surpass the actual value of the payment
2 itself. In light of this, Angeion has recommended to the Parties that a second distribution is not
3 economically feasible and recommends the remaining funds be distributed pro rata to Cy Pres
4 Recipient(s), as contemplated in the Parties’ settlement agreement and the Court’s Final Approval
5 Order.
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7 Second Distribution Fund Calculation
8 Total Amount Remaining in the
$136,739.59
9 Settlement Fund
10 Approximate Administrative Costs to
$49,167
Effectuate a Second Distribution
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Approximate Total Remaining in the
12 $87,572.59
Settlement Fund for a Second Distribution
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Second Distribution Class Member Pro Rata Settlement Benefit
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124,336 @ $0.70 $87,035.20
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17 Rounding Variance (Undistributed) $537.39
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19 7. The pre-paid digital payment card (virtual Prepaid Mastercard) product offered to
20 Settlement Class Members in this case has many of the features of pre-paid digital payment cards
21 offered outside the class action context, but also includes certain additional consumer-friendly
22 features designed specifically for class action usage, including:
23 a) No activation or load fees;
24 b) The ability of the cardholder to transfer balances at any time and at no cost to the
25 cardholder;
26 c) No inactivity fees to the cardholder until after 12 consecutive months of inactivity;
27 d) Proactive email reminder to cardholders at 11 months to encourage use; and,
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 8 of 13
1 e) Refund of inactivity fees if the cardholder re-engages through a use of value on the
2 card following service fee assessment.
3 8. Angeion directs the distribution of funds from the Settlement Account to Class
4 Members via digital payment options through enterprise-wide agreements with two vendors: Digital
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5 Disbursements and Blackhawk.
6 9. Digital Disbursements is responsible for establishing and implementing the payment
7 election feature on the Settlement Website that allows Class Members to select their preferred
8 payment method from the menu of digital payment options. At the time of distribution, Digital
9 Disbursements facilitates digital payments to Settlement Class Members through Venmo and Direct
10 Deposit.
11 10. Blackhawk is the digital payment solutions vendor engaged to facilitate and manage
12 pre-paid digital payment cards issued by the bank to Class Members.
13 11. Upon receipt, Class Members can use their digital payment card to complete purchases
14 wherever virtual Mastercard is accepted. Class Members also can choose to transfer the existing
15 balance loaded to their digital payment card to another account at any time (via Zelle, ACH, Venmo,
16 or PayPal) for no fee.
17 12. It is my further understanding that Class Members retain the full value of their balances
18 at all times, apart from the potential imposition of certain fully disclosed fees and the state-law-
19 required escheatment process described below.
20 13. The Settlement Website disclosed to Class Members that after a 12-month period of
21 inactivity on a digital payment card, the digital payment card will incur inactivity service fees from
22 the card issuer on any remaining balance until activity resumes.
23 14. The Settlement Website describes information relating to the prepaid Mastercard,
24 including the following information concerning inactivity and other fees:
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https://www.digitaldisbursements.com/.
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 9 of 13
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15 15. Class Members who receive a digital payment card can avoid inactivity service fees
16 simply by using the value of the card at least once every twelve months or by transferring all or part
17 of the value of the card to another account via Zelle, ACH, Venmo, or PayPal.
18 16. A “Card Replacement Fee” only would be incurred by Class Members who choose to
19 request a physical card as opposed to using the virtual card provided by email. A “Foreign Transaction
20 Fee” only would be incurred by Class Members who choose to use the card for foreign transactions.
21 17. It is also my understanding that any inactivity service fees charged against the balance
22 on a dormant pre-paid digital payment card will be restored and added back to the value of the card
23 if Blackhawk determines, through a periodic review of account activity, that the Class Member re-
24 engages through a use of value on the card following service fee assessment. This will be done
25 automatically by Blackhawk. This feature, in addition to those noted above, makes the pre-paid digital
26 card offered as a payment option to Class Members more consumer-friendly than other types of
27 payment or gift cards available on the market.
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 10 of 13
1 18. In any case, no portion of any inactivity or other service fee applied to any Class
2 Member’s card is paid to Angeion.
3 19. In certain settlements, Angeion generates revenue in connection with class settlements
4 in addition to amounts paid from the class settlement fund.
5 20. Angeion may receive revenue in connection with settlements apart from payments
6 from the settlement itself, including with respect to settlements for which Blackhawk acts as
7 Angeion’s subcontractor as the issuer of pre-paid cards to Class Members. The revenue generated by
8 Angeion from Blackhawk does not result in any increased cost to the settlement account, does not
9 depend on the extent to which class members in this case use or do not use their cards, and does not
10 reduce the funds available to be distributed to Class Members in this case.
11 21. The timing and/or extent to which Class Members who elect the digital payment card
12 actually use the funds on the card has no impact on Angeion’s compensation from Blackhawk. In
13 other words, Angeion’s remuneration from Blackhawk is in no way dependent on Class Members
14 using the digital payment cards they receive as part of the Settlement. Angeion intends to work with
15 the parties to ensure that as many Class Members as possible who have elected to digital payment
16 cards use them.
17 22. On October 7, 2025, Angeion updated the Settlement Website
18 (www.clearprivacysettlement.com) by adding a Frequently Asked Question (FAQ) regarding the
19 virtual Prepaid Mastercard. Much of information in this FAQ was previously available on the claim
20 submission page. The FAQ explains much of the above as a simplified version of the terms and
21 conditions, and that Angeion and Blackhawk have a contract that sets forth general terms for
22 engagements in which Angeion subcontracts with Blackhawk to provide a pre-paid digital payment
23 card option. Finally, the FAQ provides contact information for cardholder support (offered by
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 11 of 13
1 Blackhawk) should Class Members have any additional questions. A representative copy of the
2 website’s FAQ is attached here to as Exhibit A.
3 I declare under penalty of perjury under the laws of the United States of America that the
4 foregoing is true and correct.
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6 Executed on October 28, 2025.
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9 Jonathan P. Shaffer
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DECLARATION OF JONATHAN P. SHAFFER WITH POST-DISTRIBUTION ACCOUNTING
Case 3:21-cv-01418-EMC Document 288-1 Filed 10/28/25 Page 12 of 13
Exhibit A
10/24/25, 9:03 AM Case 3:21-cv-01418-EMC Document 288-1
FAQs - FiledSettlement
CLEAR Privacy 10/28/25 Page 13 of 13
Brooks v. Thomson Reuters Corp.
Case No. 3:21-cv-01418
United States District Court for the Northern District of California
Home Submit Claim Important Documents Opt Out FAQs Contact
FAQs
Key Resources
20. Prepaid Mastercard**
**When you selected your payment option, you were given information about the details of the Prepaid Mastercard. For your
convenience, we are updating the FAQs to also include this information.
Q1. What are the key terms of the Prepaid Mastercard Payment Selection?
A1.
DISCLOSURE
Monthly fee Per Purchase Fee ATM Withdrawal Cash Reload
$0.00 $0.00 NA NA
ATM Balance Inquiry (in network or out-of-network) NA
Customer service (automated or live agent) $0.00
We charge 3 other types of fees:
Inactivity (after 12 months with no transactions) $0.95 per month
Foreign Transaction Fee 2%
Card Replacement Fee, standard delivery $6.95
No overdraft/credit feature.
Register your card for FDIC insurance eligibility and other protections.
For general information about prepaid accounts visit cfpb.gov/prepaid.
For details and conditions for all fees and services call 844-340-1929
(toll free in USA); 682-324-9995 (outside USA) or visit www.MyPrepaidCenter.com.
Disbursements Prepaid Mastercard Virtual Card is issued by Pathward®, N.A., Member FDIC, pursuant to license by Mastercard
International Incorporated. Card is serviced by Blackhawk Network.
Mastercard and the circles design are registered trademarks of Mastercard International Incorporated. Card has no cash access
and cannot be used for recurring payments. Can be used where Debit Mastercard is accepted for online, phone/mail orders, or
in stores that accept mobile wallet. Valid for up to 12 months. Funds do not expire and may be available after the expiration
date, inactivity fee may apply. Terms and conditions apply.
Q: How do I activate my Virtual Prepaid Mastercard?
A: You can activate your Virtual Prepaid Mastercard by clicking on the link in your notification email.
Q: Can I transfer funds to my bank account?
A: Yes, You can transfer your remaining card balance to your bank account at no charge.
Q: Who runs the Prepaid Mastercard, and who do I contact if I have more questions about the card terms?
A: The Prepaid Mastercard is issued by Pathward® and serviced by Blackhawk Engagement Solutions. Angeion (the settlement
administrator in this case) and Blackhawk have a contract that sets forth general terms for engagements in which Angeion
subcontracts with Blackhawk to provide a pre-paid digital payment card option. Angeion receives income from Blackhawk when
Blackhawk issues a pre-paid card to a Class Member. The income Angeion receives from Blackhawk will not diminish or otherwise
impact any of the Settlement proceeds available for, or distributed to Class Members in this case.
If you have questions about the terms of your Prepaid Mastercard, you may reach Blackhawk’s cardholder support at 1-844-340-
1929.
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