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Home Court filings Brooks v. Thomson Reuters Corporation Exhibit 2 - Letter from Consumer Reports — Brooks v. Thomson Reuters Corporation (Dkt. 288-2, N.D. Cal. No. 3:21-cv-01418)

Court filing

Exhibit 2 - Letter from Consumer Reports — Brooks v. Thomson Reuters Corporation (Dkt. 288-2, N.D. Cal. No. 3:21-cv-01418)

Filed October 28, 2025 in Brooks v. Thomson Reuters Corporation; one of 127 filings from this case.

Record facts

CourtU.S. District Court for the Northern District of California
Filed2025-10-28

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 288-2 · 2025-10-28 · Docket on CourtListener

Full text

EXHIBIT 2 
 
 
 
 
Case 3:21-cv-01418-EMC     Document 288-2     Filed 10/28/25     Page 1 of 5

​October 22, 2025​
​The Honorable Edward M. Chen​
​United States District Court for the Northern District of California​
​450 Golden Gate Avenue, San Francisco, CA 94102​
​RE: Brooks v. Thomson Reuters Corp., Case No. 3:21-cv-01418-EMC​
​Dear Judge Chen,​
​Consumer Reports (CR) is an independent, nonprofit, and nonpartisan organization dedicated​
​to creating a fair and just marketplace for all. For nearly ninety years, we have empowered​
​consumers by combining research and testing, investigative journalism, consumer education,​
​and effective advocacy. From seatbelts to standards for toxin-free baby-food, many of the​
​safeguards in the marketplace we take for granted are the result of CR’s work.​
​CR’s Capacity and Work on Privacy​
​CR is the largest and most trusted consumer organization in the nation with laboratories,​
​journalists, and policy teams focused on many issues including data privacy, digital rights, and​
​financial fairness. Our work in the privacy space—especially within California—has contributed​
​to the advancement of consumer protections in the digital marketplace. CR has played a central​
​role in the passage, implementation, and enforcement of the California Consumer Privacy Act​
​(CCPA). Recently, we​​co-sponsored​​the California Location Privacy Act, legislation that would​
​create commonsense protections around the collection and use of consumers’ precise​
​geolocation data, including banning the sale of it outright. We help California residents exercise​
​their data rights through​​Permission Slip​, our free app through which consumers can send​
​hundreds of companies legally enforceable requests to stop selling or delete their data. We also​
​coordinate​​Global Privacy Control​, a browser signal, legally binding in California, that informs​
​websites of a user’s privacy preferences.​
​CR’s Approach to Cy Près Awards​
​Consumer Reports strongly supports the principle that settlements in class action cases​
​should, whenever feasible, provide direct compensation to affected consumers. When direct​
​distribution is not possible, however, we accept cy-près awards as an appropriate mechanism​
​to advance the interests of the class and consumers in the marketplace.​
​Since the early 1980s, CR has managed more than sixty-five cy-près awards. These funds have​
​enabled us to educate, engage, and protect consumers in ways that complement the goals of​
​the underlying litigation. Through careful stewardship, we ensure that every cy-près award we​
​receive is used to deliver benefits aligned with the intent of the settlement and the interests of​
​the affected class.​
​Consumer Reports​
​101 Truman Ave, Yonkers, NY 10703​
​1​
Case 3:21-cv-01418-EMC     Document 288-2     Filed 10/28/25     Page 2 of 5

​Representative Cases​
​CR has previously been designated as a cy-près recipient in several significant privacy​
​and consumer protection cases, including:​
​●​ ​Thomas H. Krakauer v. Dish Network LLC​, Case No. 1:14-cv-00333-CCE-JEP (U.S.​
​Court of Appeals for the Fourth Circuit, 2019). The Honorable Catherine C. Eagles of the​
​Middle District of North Carolina presided. The case resulted in a judgment exceeding​
​$60 million under the Telephone Consumer Protection Act (TCPA). CR was approved as​
​one of the cy-près recipients as part of a competitive process. Our work focuses on​
​increasing privacy protections such that telemarketers do not have access to the data​
​required to target consumers.​
​●​ ​Google LLC Street View​, Case No. 3:10-md-02184 (N.D. Cal. Mar. 18, 2020). The​
​Honorable Charles R. Breyer presided over a $13 million settlement concerning​
​allegations of unauthorized data collection from Wi-Fi networks. Through a competitive​
​process, CR received a cy-près award to support consumer research, public awareness,​
​and advocacy on data collection and privacy practices.​
​●​ ​James Cottle, et al. v. Plaid Inc.​, Case No. 20-cv-03056-DMR (N.D. Cal. July 20,​
​2022). The Honorable Donna M. Ryu approved a $58 million settlement arising from​
​allegations that Plaid collected and used consumer financial data without consent. CR​
​was named a cy-près recipient for its work on data privacy education and advocacy.​
​Other cy-près awards of the last five years include:​
​●​ ​Johns v. Visa (CA)​​— California Court of Appeal, First Appellate District (underlying​
​JCCP 4335, San Francisco Superior Court).​
​●​ ​Visa/Mastercard credit-debit card litigation​​— U.S. District Court, Eastern District​
​of New York (MDL 1720; Payment Card Interchange Fee & Merchant Discount​
​Antitrust Litigation).​
​●​ ​Pool Products Distribution Market Antitrust Litigation​​— U.S. District Court,​
​Eastern District of Louisiana (MDL 2328).​
​●​ ​Robrinzine v. Big Lots Stores, Inc.​​— U.S. District Court, Northern District of Illinois.​
​●​ ​Mollicone v. Universal Handicraft, Inc.​​— U.S. District Court,​​Southern District of​
​Florida.​
​●​ ​Ramos v. Hopele of Fort Lauderdale, LLC​​— U.S. District Court, Southern District of​
​Florida (Fort Lauderdale Division).​
​Consumer Reports​
​101 Truman Ave, Yonkers, NY 10703​
​2​
Case 3:21-cv-01418-EMC     Document 288-2     Filed 10/28/25     Page 3 of 5

​●​ ​Koller v. Deoleo USA, Inc.​​— U.S. District Court, Northern District of California (No.​
​3:14-cv-02400-RS).​
​●​ ​Cortes v. National Credit Adjusters, LLC​​— U.S. District Court, Eastern District of​
​California (No. 2:16-cv-00823-MCE-EFB).​
​●​ ​Will Kaupelis et al. v. Harbor Freight Tools USA, Inc.​​— U.S. District Court,​
​Central District of California (No. 8:19-cv-01203).​
​●​ ​Jane Loomis v. Slendertone Distribution, Inc.​​— U.S. District Court, Southern District​
​of California (No. 3:19-cv-00854).​
​●​ ​Vanover v. Helio LLC​​— Superior Court of California, County of Los Angeles (Case No.​
​BC414842).​
​●​ ​Richard Desio et al. v. InSinkErator et al.​​— U.S. District Court, Eastern District of​
​Washington (No. 2:15-cv-00346).​
​●​ ​Bechtel and Thoennes v. Sole Fitness (Fitness Equipment Services, LLC d/b/a​
​Sole Fitness)​​— U.S. District Court, Southern District of Ohio, Western Division (No.​
​1:19-cv-00726).​
​●​ ​Keurig (K-Cups) Settlement​​— U.S. District Court, Northern District of California (Smith​
​v. Keurig Green Mountain, Inc., No. 4:18-cv-06690-HSG).​
​●​ ​Woodard et al. v. Labrada​​— U.S. District Court, Central District of California (No.​
​5:16- cv-00189-JGB-SP).​
​●​ ​Walker v. Nautilus, Inc.​​— U.S. District Court, Southern District of Ohio, Eastern​
​Division (No. 2:20-cv-3414; Judge Edmund A. Sargus, Jr.).​
​Through each of these awards, CR’s has managed funds to support initiatives that​
​protect consumer interests.​
​Conflicts of Interest​
​Consumer Reports has no significant relationships with any of the individuals associated​
​with this case including plaintiffs, defendants, counsel, and judicial representatives.​
​Consumer Reports​
​101 Truman Ave, Yonkers, NY 10703​
​3​
Case 3:21-cv-01418-EMC     Document 288-2     Filed 10/28/25     Page 4 of 5

​Summary​
​We appreciate the Court’s consideration of Consumer Reports as a cy-près recipient for residual​
​funds from Brooks v. Thomson Reuters Corp., Case No. 3:21-cv-01418-EMC. We are​
​committed to ensuring that these funds are used to achieve outcomes consistent with the​
​objectives of the litigation—benefiting consumers and promoting fair and transparent market​
​practices through consumer-facing tools that help Californians exercise their privacy rights;​
​policy and regulatory work aimed at data brokers; and research, public education, and watchdog​
​reporting on broker practices.​
​Respectfully submitted,​
​Lynn Melander Moore​
​Lynn Melander Moore​
​Director, Philanthropic Partnerships​
​Consumer Reports​
​(914) 378-2958 | (m) 814.431.5588​
​lynn.moore@consumer.org​
​Consumer Reports​
​101 Truman Ave, Yonkers, NY 10703​
​4​
Case 3:21-cv-01418-EMC     Document 288-2     Filed 10/28/25     Page 5 of 5

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