Exhibit 1 — Plaid Privacy (Dkt. 108.2)

Summary

Exhibit 1, Doc. 108-2, filed November 17, 2020 in No. 4:20-cv-03056-DMR in the U.S. District Court for the Northern District of California, is a complaint by The Toronto-Dominion Bank against Plaid Inc. in the U.S. District Court, District of New Jersey, Case 1:20-cv-14424-RMB-JS, stamped Document 1, filed October 14, 2020. It is titled a complaint for trademark counterfeiting, trademark infringement, false designation of origin, false advertising, and unfair competition under the Lanham Act, 15 U.S.C. § 1051. The bank alleges that Plaid created a user interface using its TD and TD BANK trademarks, logo and green color scheme to replicate its login page. The requests include statutory damages under 15 U.S.C. § 1117(c) of up to $2,000,000 for each type of service. It is signed /s/ Samuel V. Eichner.

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EXHIBIT 1 
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1 
 
 
UNITED STATES DISTRICT COURT 
DISTRICT OF NEW JERSEY 
 
THE TORONTO-DOMINION BANK, 
 
Plaintiff, 
 
v. 
 
PLAID INC., 
 
 
 
 
Defendant. 
 
 
 
 
 
               Civil Action No. ______ 
 
Document Electronically Filed 
 
 
 
COMPLAINT FOR TRADEMARK COUNTERFEITING, TRADEMARK 
INFRINGEMENT, FALSE DESIGNATION OF ORIGIN,  
FALSE ADVERTISING, AND UNFAIR COMPETITION 
 
Plaintiff The Toronto-Dominion Bank, by its undersigned attorneys, alleges as follows, 
upon actual knowledge with respect to its itself and its own acts, and upon information and belief 
as to all other matters: 
THE PARTIES 
1. 
Plaintiff The Toronto-Dominion Bank (“TD”) is a Chartered Bank, organized and 
existing under the laws of Canada, with its U.S. headquarters at 1701 Route 70 East, Cherry Hill, 
New Jersey, 08034.   
2. 
Upon information and belief, Plaid Inc. is a Delaware corporation with its 
headquarters at 85 Second Street, Suite 400, San Francisco, California 94105. 
NATURE OF THE ACTION 
3. 
This is an action for trademark counterfeiting, trademark infringement, false 
designation of origin, false advertising, and unfair competition under the Lanham Act, 15 U.S.C. 
§ 1051, et seq. and New Jersey statutory and common law.   
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4. 
TD brings this action because Defendant Plaid Inc. has created a user interface 
(“UI”) for financial services applications that uses TD’s TD and TD BANK trademarks, logo, 
and green color scheme to replicate TD’s genuine login page and to dupe consumers into 
believing they are entering their sensitive personal and financial information in the bank’s trusted 
and secure platform.  In reality, however, consumers are unwittingly giving their login 
credentials to Defendant, who takes the information, stores it on its servers, and uses it to mine 
consumers’ bank records for valuable data (e.g., transaction histories, loans, etc.), which 
Defendant monetizes by selling to third parties.  Defendant’s unscrupulous practices are the 
subject of a separate consumer class action for invasion of privacy and other wrongs.     
JURISDICTION AND VENUE 
5. 
This action arises under the federal Trademark Act, 15 U.S.C. § 1051, et. seq., 
and under New Jersey statutory and common law.  This Court has subject matter jurisdiction 
over this action pursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331, 1338(a) and (b).  This 
Court also has diversity jurisdiction under 28 U.S.C. § 1332 because TD and Defendant reside in 
different states—namely New Jersey and California, respectively—and the amount in 
controversy exceeds $75,000 exclusive of interest and costs.  Pursuant to 28 U.S.C. § 1367, this 
Court has supplemental jurisdiction over TD’s state law claims because those claims are 
substantially related to TD’s federal Lanham Act claims. 
6. 
This Court has personal jurisdiction over Defendant and venue is proper in the 
District of New Jersey pursuant to 28 U.S.C. § 1391(b) and (c) because TD is being harmed in 
this District; Defendant is conducting business in this District; and Defendant is using the 
unlawful TD mark, logo, and green color scheme in this District. 
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TD, ITS SERVICES, AND ITS FAMOUS TRADEMARKS 
7. 
TD is a diversified financial services company that offers a broad spectrum of 
financial products and services to consumers, small businesses, and commercial clients.   
8. 
With approximately 89,000 employees and deep community roots dating back 
more than 150 years, TD is one of the ten largest and best-known banks in the United States.  TD 
offers a broad array of retail, small business, and commercial banking and other financial 
products and services to millions of customers through its extensive network of approximately 
1,300 physical locations in the U.S. alone. 
9. 
TD has used the name and trademark TD in the U.S.—alone and/or with other 
word and/or design elements, including BANK—since at least as early as September 1969 to 
identify its various financial services (the “TD Marks”). 
10. 
TD has obtained a number of federal trademark registrations for its TD and TD 
BANK marks (among others) for a variety of financial and computer/software goods and 
services, including: 
Mark 
Reg. No. 
Reg. Date 
Products/Services 
1649009 
06-25-1991 
Various banking and financial services in Class 36. 
3037995 
01-03-2006 
Various banking and financial services in Class 36. 
3041170 
01-10-2006 
Various banking and financial services in Class 36. 
TD 
3041792 
01-10-2006 
Various financial services in Class 36. 
TD 
4388813 
08-20-2013 
Various banking and financial goods in Classes 9 and 16. 
 
 
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Mark 
Reg. No. 
Reg. Date 
Products/Services 
Various financial and banking services in Classes 35, 36, 
38, and 41, including online banking services and online 
banking account services featuring account information 
reporting, automated clearing house, wire transfer and stop 
payment services; online mortgage banking, consumer and 
commercial lending services, investment brokerage, and 
stock brokerage services; banking services and online 
banking services, namely, providing customers with online 
access to account information, account management and 
reports, and electronic transactions via the Internet and 
computer networks.  
4388814 
08-20-2013
Various banking and financial goods and services in Classes 
9 and 16.  
Various financial and banking services in Classes 35, 36, 
38, and 41, including online banking services and online 
banking account services featuring account information 
reporting, automated clearing house, wire transfer and stop 
payment services; online mortgage banking, consumer and 
commercial lending services, investment brokerage, and 
stock brokerage services; banking services and online 
banking services, namely, providing customers with online 
access to account information, account management and 
reports, and electronic transactions via the Internet and 
computer networks.  
4332605 
05-07-2013
Various banking and financial goods in Classes 9 and 16. 
Various financial and banking services in Classes 35, 36, 
38, and 41, including online banking services and online 
banking account services featuring account information 
reporting, automated clearing house, wire transfer and stop 
payment services; online mortgage banking, consumer and 
commercial lending services, investment brokerage, and 
stock brokerage services; banking services and online 
banking services, namely, providing customers with online 
access to account information, account management and 
reports, and electronic transactions via the Internet and 
computer networks. 
TD BANK 
3788055 
05-11-2010
Various banking and financial services in Class 36. 
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Mark 
Reg. No. 
Reg. Date 
Products/Services 
3854367 
09-28-2010
Banking services in Class 36. 
3845809 
09-07-2010
Banking services in Class 36. 
3979909 
06-21-2011
Various banking and financial services in Class 36. 
These registrations are all incontestable.  Printouts of the registrations, taken from the U.S. 
Patent and Trademark Office’s online database, are attached as Exhibit A.   
11.
In addition to the TD Marks, consumers identify TD and its services by the color
green, which has been TD’s corporate color for decades and has been continuously and 
prominently used with, in, and throughout TD’s marks, website, advertisements, promotions, 
branches, and app (see examples below).  
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12. 
TD customers can access their accounts online via TD’s website and mobile app.  
There, consumers can view and manage their accounts, deposit checks, pay bills, transfer and 
send money, and more.   
13. 
When consumers access their TD accounts online, they are presented with a login 
screen with the TD name, mark, and logo—presented in green—where they enter their name and 
password, i.e.: 
 
 
                 Website Login Screen 
 
              App Login Screen 
14. 
TD uses multiple industry-accepted security practices, including firewalls, 
encryption, and multilayered authentication controls, to safeguard its customers’ privacy and the 
security of their financial information entered online and through TD’s mobile apps.  Day in and 
day out, consumers trust and rely on these and other measures to protect their identities, hard-
earned money, and sensitive and valuable financial information.     
15. 
For years, TD has extensively advertised, marketed, and promoted its TD-branded 
services through a variety of high profile national and local media, including television, radio, 
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Internet, direct mail, and print advertisements.  In just the last two years alone, TD spent around 
30 million annually on certain advertising activities.   
16. 
TD has also promoted itself, its marks, and its services through various high-
profile sponsorships of athletics, arts and entertainment, community events, and more, including 
the Boston Bruins professional NHL team, Boston Celtics professional NBA team, Somerset 
Patriots minor league baseball team, Greenville Drive minor league baseball team, Mayor’s Cup 
pro cycling race, U.S. Olympic Biathlon teams, Kimmel Center, TD James Moody Jazz Festival, 
TD Stage at the Peace Center, annual TD Five Boro Bike Tour in New York, and annual TD 
Beach to Beacon 10K. 
17. 
TD owns the naming rights to multiple sports and entertainment venues, including 
New Jersey’s TD BANK BALLPARK, Boston’s TD GARDEN, Florida’s TD BALLPARK, and 
the College of Charleston’s TD ARENA (depicted below): 
   
          
 
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18. 
As a result of its tremendous success, TD has received extensive media coverage, 
including in widely circulated media, such as Businessweek, Forbes, Investor’s Business Daily, 
Business Insider, Wall Street Journal, American Banker, Huffington Post, Washington Post, 
BuzzFeed, CNN, CNBC, New York Times, PBS, Fox News, and Yahoo! Finance. 
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19. 
Over the years, TD has also received numerous corporate and business awards, 
including:  
• Fortune 500 list of America’s largest companies 
• Fortune’s Great Places to Work: Finance and Insurance 
• Reader’s Digest list of Most Trusted Brand Award in the Bank/Trust Company 
Category 
• Forbes’ list of World’s Best Banks 
• Forbes’ list of Best Employers for Diversity 
• American Banker’s Most Powerful Women in Banking 
• J.D. Power’s highest-ranked bank in U.S. Retail Banking Satisfaction Study 
• Forbes’ list of Best Employers for New Grads 
• National LGBT Chamber of Commerce “Best of the Best: Corporation for Inclusion”  
20. 
The TD mark has become well-known and famous by virtue of extensive public 
exposure and the tremendous success of TD’s products and services. 
DEFENDANT AND ITS WRONGFUL ACTS 
21. 
Defendant, a financial technology (“fintech”) company, offers a financial 
technology infrastructure product, consisting of software and a UI that connects third-party 
applications (“apps”) to consumers’ bank accounts, without ever having the consumers login to 
the accounts.   
22. 
Defendant’s Plaid product is used in several popular payment and investment 
apps, including Venmo, Coinbase, Square’s Cash App, and Stripe, each of which allows 
consumers to send and receive money from their TD and other financial accounts.   
23. 
When connecting a third-party app to consumers’ bank accounts, Defendant’s 
Plaid product uses an authentication process that differs from, and bypasses, the customary 
authentication process.  
24. 
Typically, when consumers access their bank accounts via a third-party webpage 
or app, this is done via an “OAuth” process that redirects the consumers from the original third-
party webpage or app directly to their bank’s own webpage or app.  Once there, consumers enter 
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their login credentials and are then redirected back to the original third-party webpage or app.  
Behind the scenes, the bank returns a “token” that allows the original webpage or app to access 
the consumer’s bank identification as necessary and authorized by the consumer, but without 
giving the third-party webpage or app provider access to the consumer’s login information. 
25. 
Instead of redirecting consumers from the third-party app to their bank’s website 
or app, the Plaid product’s authentication sidesteps the “OAuth” process by creating “dummy” 
screens that replicate the banks’ login pages, giving consumers the impression that they have 
been transported to their bank’s website or app and are logging into their account.  In reality, 
consumers are giving their credentials to Defendant, who then uses the information to log into 
the banks’ systems while the consumer remains in the third-party app. 
26. 
For example, a consumer using Venmo who wants to connect to their TD account 
is presented with a “selection” screen that displays the TD Marks among other bank names and 
logos, e.g.: 
 
Defendant’s Plaid UI Selection Screen on Venmo 
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27. 
Once a consumer using Venmo selects TD BANK, the consumer is presented with 
a “credential” screen, which purposefully imitates the look and feel of TD’s login page and 
prompts consumers to enter their user name and password: 
 
Defendant’s Plaid UI Credential Screen on Venmo 
28. 
After receiving the consumer’s login credentials, the Plaid UI presents a “loading” 
screen, which also uses TD’s name, mark, logo, and green color scheme to make users believe 
they are interacting directly with the bank’s real webpage or app: 
  
Defendant’s Plaid UI Loading Screen on Venmo 
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29. 
On information and belief, the Plaid UI takes consumers through these or similar 
steps and presents consumers with screens using TD’s name, mark, logo, and green color scheme 
on all third-party apps that use Defendant’s Plaid product. 
30. 
After taking consumers’ login credentials, Defendant sends the information to its 
servers, where it is kept and used to collect data from all accessible accounts (e.g., checking, 
savings, and credit card)—not just the specific account a customer may have intended to connect 
to the third-party app.   
31. 
Defendant tracks “typically 24 months of transaction data, including geolocation, 
merchant, and category information,” which it stores and analyzes using machine learning.  (See 
https://plaid.com/products/transactions/.)  This valuable personal financial information is then 
offered and sold to third-party apps.  (See https://plaid.com/pricing/.)   
32. 
According to an individual identified as a former Plaid programmer, Defendant 
“develop[ed] methodologies for bypassing the anti-scraping measures on several banking 
websites” and “ignore[ed] banks’ refusals” to grant Defendant access to bank customers’ 
information.  (See https://news.ycombinator.com/item?id=17692291.) 
33. 
Defendant has boasted that “[o]ver a quarter of people with US bank accounts” 
and “tens of millions of users” have connected financial accounts using Plaid.  (See 
https://plaid.com/overview-privacy/; https://plaid.com/documents/plaid-for-financial-
institutions.pdf.) 
34. 
Defendant has conceded that it is able to obtain consumers’ sensitive financial 
information by using TD’s and other banks’ “branding elements” because they give “end-users [] 
a greater sense of security and familiarity when they recognize their institution’s look-and-feel.”  
(See https://blog.plaid.com/improved-search/.)   
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35. 
Defendant has also touted that the “native experience” of consumers entering 
login credentials for “personal financial data without ever leaving the original app” “increase[es] 
user conversion.”  (See https://fin.plaid.com/articles/demystifying-screenless-exchange/.)    
36. 
On April 17, 2020, TD sent a letter to Defendant accusing Defendant of 
trademark infringement and unfair competition, and demanding that Defendant promptly cease 
its use of TD’s marks and branding.   
37. 
On May 1, 2020, Defendant responded to TD denying liability and refusing to 
stop using TD’s name, mark, logo, and green color scheme.   
38. 
On May 4, 2020, a consumer class action lawsuit was filed against Defendant, 
Cottle v. Plaid Inc., No. 3:20-cv-03056 (N.D. Cal. filed May 4, 2020), alleging that Defendant 
deceptively and fraudulently collects, stores, aggregates, and monetizes consumers’ sensitive 
financial credentials and transactions in violation of consumers’ privacy, the Computer Fraud 
and Abuse Act, and other laws.   
INJURY TO TD AND THE PUBLIC 
 
39. 
Defendant’s use of TD’s name, mark, and green color scheme to mimic TD’s 
genuine login pages is likely to confuse and deceive people into believing that they have been 
forwarded to TD’s website or app and that they are providing their login credentials to TD—not 
to Defendant or anyone else.   
40. 
Defendant’s unauthorized use of TD’s name, mark, and green color scheme is 
likely to cause confusion, mistake, and deception as to the source or origin of Defendant, its 
business, and/or its commercial activities with TD. 
41. 
Defendant’s unauthorized use of TD’s name, mark, and green color scheme has 
damaged and irreparably injured and, if permitted to continue, will further damage and 
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irreparably injure TD, TD’s name and marks, TD’s reputation and goodwill, and the public’s 
interest in being free from confusion, mistake, and deception.  
42. 
Defendant intentionally used TD’s name, mark, and green color scheme to trick 
people into believing that they were at TD’s site or app in order to obtain their valuable and 
private financial information.  As a result, Defendant acted knowingly, willfully, in reckless 
disregard of TD’s rights, and in bad faith. 
43. 
TD and the public have no adequate remedy at law. 
FIRST CLAIM FOR RELIEF 
Federal Trademark Counterfeiting Under 
Sections 32(1)(b), 34(d) of the Lanham Act, 15 U.S.C. §§ 1114(1)(b), 1116(d) 
 
44. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 43 of this Complaint. 
45. 
Defendant has used and continues to use a counterfeit of TD’s federally registered 
TD Marks (including Reg. Nos. 4388813, 4388814,  and 4332605) in connection with the sale, 
offering for sale, and distribution of online financial services in violation of Sections 32(1)(b), 
34(d) of the Lanham Act, 15 U.S.C. §§ 1114(1)(b), 1116(d). 
SECOND CLAIM FOR RELIEF 
Federal Trademark Infringement Under 
Section 32(a) of the Lanham Act, 
15 U.S.C. § 1114(1) 
 
46. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 45 of this Complaint. 
47. 
Without TD’s consent, Defendant used and continues to use in commerce 
reproductions, copies, and colorable imitations of TD’s registered TD and TD BANK marks in 
connection with the offering, distribution, and advertising of services, which is likely to cause 
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confusion, or to cause mistake, or to deceive, in violation of Section 32(1) of the Lanham Act, 15 
U.S.C. § 1114(1). 
THIRD CLAIM FOR RELIEF 
Federal Trademark Infringement, False Designation 
of Origin, and Unfair Competition Under 
Section 43(a)(1)(A) of the Lanham Act, 
15 U.S.C. § 1125(a)(1)(A) 
48. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 47 of this Complaint. 
49. 
Defendant’s actions described above are likely to cause confusion, mistake, or 
deception as to the origin, sponsorship, or approval of Defendant, Defendant’s services/goods, 
and/or Defendant’s commercial activities by or with TD, and thus constitute trademark 
infringement, false designation of origin, and unfair competition in violation of Section 
43(a)(1)(A) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A). 
FOURTH CLAIM FOR RELIEF 
False Advertising 
Section 43(a)(1)(B) of the Lanham Act, 
15 U.S.C. § 1125(a)(1)(B) 
 
50. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 49 of this Complaint. 
51. 
The aforesaid acts of Defendant constitute false and misleading descriptions and 
misrepresentations of fact in commerce which, in commercial advertising and promotion 
misrepresent the nature, characteristics, and qualities of TD’s and Defendant’s goods, services, 
and/or commercial activities. 
FIFTH CLAIM FOR RELIEF 
Trademark Counterfeiting Under 
N.J. Stat. § 56:3-13.16 
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52. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 51 of this Complaint. 
53. 
TD’s TD Marks are protected at common law. 
54. 
Defendant’s actions described above constitute use without TD’s consent of 
reproductions, counterfeits, copies, or colorable imitations of TD’s Marks in connection with 
Defendant’s sale, distribution, offering for sale, and advertising in New Jersey of goods or 
services that is likely to cause confusion or mistake or to deceive as to the source of origin of the 
goods or services. 
55. 
Defendant’s actions constitute a violation of N.J. Stat. § 56:3-16.  
SIXTH CLAIM FOR RELIEF 
Unfair Competition Under 
N.J. Stat. § 56:4-1 
 
56. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 55 of this Complaint. 
57. 
Defendant’s actions described above constitute the misappropriation for 
Defendant’s own use of TD’s name, brand, trademarks, reputation, and goodwill in violation of 
N.J. Stat. § 56:4-1. 
 
SEVENTH CLAIM FOR RELIEF 
Trademark Infringement, Unfair Competition, False Designation of Origin, 
and Misappropriation 
Under New Jersey Common Law 
 
58. 
TD repeats and realleges each and every allegation set forth in paragraphs 1 
through 57 of this Complaint. 
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59. 
Defendant’s actions described above are likely to cause confusion, mistake, or 
deception as to the origin, sponsorship, or approval of Defendant, Defendant’s services/goods, 
and/or Defendant’s commercial activities by or with TD, and thus constitute common-law 
trademark infringement, unfair competition, false designation of origin, and misappropriation of 
TD’s Marks and goodwill under the common law of New Jersey. 
 
JURY DEMAND 
60. 
Pursuant to Fed. R. Civ. P. 38, TD respectfully demands a trial by jury on all 
issues properly triable by a jury in this action. 
PRAYER FOR RELIEF 
WHEREFORE, TD respectfully requests that this Court enter judgment in its favor on 
each and every claim for relief set forth above and award it relief, including but not limited to the 
following: 
A. 
An Order declaring that Defendant’s uses of the TD Marks knowingly and 
willfully infringe TD’s TD Marks and green color scheme, constitute counterfeiting of TD’s 
registered marks, and constitute unfair competition, as detailed above. 
B. 
An Order enjoining Defendant, its officers, directors, employees, agents, 
subsidiaries, distributors, dealers, app partners, related companies, and all persons in active 
concert or participation with any of them: 
1. 
From using, registering, or seeking to use or register any name, mark, 
trade name, company name, domain name, source identifier, or designation 
comprised of or containing TD, the color green, or any similar term(s) in any 
manner likely to cause confusion with TD and/or its marks or to otherwise injure 
TD and/or its reputation; 
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2. 
From representing, by any means whatsoever, directly or indirectly, that 
Defendant, its services/goods, and/or its activities originate from, are sponsored 
by, or are associated, affiliated, or connected with TD in any way;  
3. 
From creating login and other screens, materials, or imagery that mimic or 
purport to be real TD screens, materials, or imagery; and 
4. 
From assisting, aiding, and/or abetting any other person or business entity 
in engaging in or performing any of the activities referred to in subparagraphs 
B(1) through (3) above. 
C. 
An Order requiring Defendant to immediately retract and destroy all products, 
packaging, signage, advertisements, promotional materials, stationary, forms, and/or materials 
and things that contain or bear TD, or any other name, mark, trade name, company name, source 
identifier, or designation that contains or is confusingly similar to TD’s marks. 
D. 
An Order directing that, within thirty (30) days after the entry of the injunction, 
Defendant file with this Court and serve on TD’s attorneys a report in writing and under oath 
setting forth in detail the manner and form in which Defendant has complied with the injunction. 
E. 
An Order requiring Defendant to account for and pay to TD all profits arising 
from Defendant’s unlawful acts, and increasing such profits, for payment to TD in accordance 
with 15 U.S.C. § 1117 and other applicable laws. 
F. 
An Order requiring Defendant to pay statutory damages in accordance with 15 
U.S.C. § 1117(c) of up to $2,000,000 for each type of service sold, offered for sale, or distributed 
by Defendant under the TD Marks. 
G. 
An Order requiring Defendant to pay TD actual damages, in an amount to be 
determined (but exceeding $75,000), caused by the foregoing acts, and trebling such damages in 
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accordance with 15 U.S.C. § 1117, N.J. Stat. §§ 56:3-13.16 and other applicable laws. 
H. 
An Order requiring Defendant to pay TD all of its litigation expenses, including 
reasonable attorneys’ fees and costs under 15 U.S.C. § 1117, N.J. Stat. §§ 56:3-13.16, New 
Jersey common law, and other applicable laws.  
I. 
An Order requiring Defendant to pay TD punitive damages in an amount to be 
determined due to the foregoing willful acts.  
J. 
Other relief as the Court may deem appropriate. 
Dated: October 14, 2020 
 
 
/s/ Samuel V. Eichner  
 
 
Samuel V. Eichner (Bar No. 902302012) 
Douglas A. Rettew (pro hac vice to be filed) 
Jessica L. Hannah (pro hac vice to be filed) 
FINNEGAN, HENDERSON, FARABOW, 
   GARRETT & DUNNER LLP 
901 New York Avenue, NW 
Washington, D.C. 20001-4413 
(202) 408-4000 (phone) 
(202) 408-4400 (fax) 
Email: samuel.eichner@finnegan.com 
Email: doug.rettew@finnegan.com  
Email: jessica.hannah@finnegan.com  
 
Case 1:20-cv-14424-RMB-JS   Document 1   Filed 10/14/20   Page 20 of 20 PageID: 20
Case 4:20-cv-03056-DMR     Document 108-2     Filed 11/17/20     Page 21 of 21

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