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Home Court filings In re Plaid Inc. Privacy Litigation — N.D. Cal., No. 4:20-cv-03056-DMR Defendant Plaid Inc.s Answer to Consolidated Amended Class Action Complaint for Damages…

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Defendant Plaid Inc.s Answer to Consolidated Amended Class Action Complaint for Damages and… — Plaid Privacy (Dkt. 130)

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Defendant Plaid Inc.'s Answer to the Consolidated Amended Class Action Complaint for Damages and Declaratory and Equitable Relief, filed June 4, 2021 as Doc. 130 in In re Plaid Inc. Privacy Litigation, No. 4:20-cv-03056-DMR, in the U.S. District Court for the Northern District of California. Plaid states that allegations not specifically admitted are denied, and admits that Plaid is not a bank and provides software used by third-party developers, including for Venmo. Plaid denies Paragraphs 8 and 9, as moot, citing the Court's dismissal with prejudice of the federal claims. The answer sets out defenses and prays that Plaintiffs take nothing and that judgment be entered in favor of Plaid. It demands a jury trial; signed /s/ Michael G. Rhodes.

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CourtU.S. District Court for the Northern District of California
Filed2021-06-04

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“Defendant Plaid Inc.s Answer to Consolidated Amended Class Action Complaint for Damages and… — Plaid Privacy (Dkt. 130).” U.S. District Court for the Northern District of California, No. 4:20-cv-03056-DMR, Doc. 130, filed 2021-06-04. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-plaid-privacy-cand-359040/2021-06-04-gov-uscourts-cand-359040-130-0-doc-130/, SHA-256 22ac991a5cb2b7e655760a3c41e70f221ccf36af55bd6ccb9d4421af318af0da.

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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT  
NO. 4:20-CV-3056-DMR 
 
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COOLEY LLP 
ATTORNEYS AT LAW 
SAN FRANCISCO 
COOLEY LLP 
MICHAEL G. RHODES (116127) 
(rhodesmg@cooley.com) 
WHITTY SOMVICHIAN (194463) 
(wsomvichian@cooley.com) 
KYLE C. WONG (224021)  
(kwong@cooley.com) 
LAUREN J. POMEROY (291604) 
(lpomeroy@cooley.com) 
ELLIE BARCZAK (329180)  
(ebarczak@cooley.com) 
101 California Street, 5th Floor 
San Francisco, CA 94111-5800 
Telephone: 
+1 415 693 2000 
Facsimile: 
+1 415 693 2222 
Attorneys for Defendant 
Plaid Inc. 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
IN RE PLAID INC. PRIVACY LITIGATION 
 
_____________________________________ 
THIS DOCUMENT RELATES TO: 
  
                                         ALL ACTIONS 
Case No. 4:20-cv-03056-DMR 
DEFENDANT PLAID INC.’S ANSWER TO 
CONSOLIDATED AMENDED CLASS ACTION 
COMPLAINT FOR DAMAGES AND 
DECLARATORY AND EQUITABLE RELIEF 
DEMAND FOR JURY TRIAL 
Judge: 
Donna M. Ryu 
 
Trial Date: None Set 
Date Action Filed: May 4, 2020 
 
 
 
 
 
 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 1 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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Defendant Plaid Inc. (“Plaid”) hereby answers Plaintiffs’ Consolidated Amended Class 
Action Complaint for Damages and Declaratory and Equitable Relief (the “Complaint”) (ECF No. 
61). Any and all allegations not specifically admitted herein are denied. Except otherwise stated, 
Plaid denies the factual allegations, if any, contained in the headings, subheadings, tables of 
contents, unnumbered paragraphs, figures, and footnotes in the Complaint. Plaid reserves the right 
to seek leave to amend or supplement its Answer as necessary. 
1. 
Plaid denies the allegations contained in Paragraph 1. 
2. 
Paragraph 2 contains legal conclusions and characterizations to which no response 
is required.  To the extent a response is required, Plaid admits that it is not a bank and denies all 
other allegations and characterizations in Paragraph 2.  
3. 
Paragraph 3 contains legal conclusions and characterizations to which no response 
is required.  To the extent a response is required, Plaid admits that it provides software used by 
third-party developers, including developers of Venmo, Coinbase, and Square’s CashApp. Plaid 
denies all other allegations and characterizations in Paragraph 3. 
4. 
Plaid admits that it provides a user interface to its clients to facilitate the process by 
which end-users can permission access to their financial account.  That user interface explains 
Plaid’s role in the process, including that Plaid uses encryption to help secure their data, and that 
the credentials the user shares with Plaid are kept private from the third-party application.  Plaid 
denies all other allegations and characterizations in Paragraph 4. 
5. 
Plaid denies the allegations contained in Paragraph 5. 
6. 
Plaid denies the allegations contained in Paragraph 6. 
7. 
Paragraph 7 is Plaintiffs’ characterization of their claims to which no response is 
required.  Plaid denies that Plaintiffs are entitled to any of the requested relief. 
8. 
Plaid denies Paragraph 8 as moot with respect to Plaintiffs’ claims that arise under 
the Computer Fraud and Abuse Act, 18 U.S.C. § 1030, and the Stored Communications Act, 18 
U.S.C. § 2701 in light of the Court’s dismissal with prejudice of these claims. (See ECF No. 125.) 
9. 
Plaid denies Paragraph 9 as moot in light of the Court’s dismissal with prejudice of 
Plaintiffs’ federal claims. (See ECF No. 125.) 
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PLAID’S ANSWER TO CONSOLIDATED 
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NO. 4:20-CV-3056-DMR 
 
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10. 
Paragraph 10 contains legal conclusions to which no response is required.  To the 
extent that a response is required, without admitting that elements of the Class Action Fairness Act 
have been met, Plaid does not dispute jurisdiction under 28 U.S.C. § 1332(d) under the Class Action 
Fairness Act. 
11. 
Paragraph 11 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid admits that it has conducted business in the State of 
California and, without admitting any of the complained of acts and omissions, does not dispute 
this Court’s exercise of personal jurisdiction. 
12. 
Paragraph 12 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid admits that it does business in this District and, without 
admitting the events or omissions alleged in Plaintiffs’ Complaint, does not dispute the propriety 
of venue in this District. 
13. 
Paragraph 13 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid admits that it is headquartered in San Francisco and, without 
admitting any of the alleged conduct purportedly giving rise to Plaintiffs’ claims, does not dispute 
the propriety of assignment to the Oakland Division of this District. 
14. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 14 and, on that basis, denies them. 
15. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 15 and, on that basis, denies them. 
16. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 16 and, on that basis, denies them. 
17. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 17 and, on that basis, denies them. 
18. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 18 and, on that basis, denies them. 
19. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 19 and, on that basis, denies them. 
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20. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 20 and, on that basis, denies them. 
21. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 21 and, on that basis, denies them. 
22. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 22 and, on that basis, denies them. 
23. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 23 and, on that basis, denies them. 
24. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 24 and, on that basis, denies them. 
25. 
Plaid admits that it is a financial technology company and that it describes its 
business as follows: “We started out by building the technical infrastructure APIs that connect 
consumers, traditional financial institutions, and developers. Today, we add key insights to the data 
access we provide with our suite of analytics products.”  Plaid further admits that it is a Delaware 
corporation with its principal place of business at 1098 Harrison Street, San Francisco, California 
94103.  Plaid admits that on January 13, 2020 it announced that it signed a definitive agreement to 
be acquired by Visa; however Plaid subsequently announced the mutual termination of the pending 
acquisition on January 12, 2021.  Except as specifically admitted herein, Plaid denies all allegations 
in Paragraph 25. 
26. 
Plaid admits that it was founded in 2012 by Zach Perret and William Hockey with 
the intention of building a personal financial management tool but shortly thereafter pivoted its 
focus to building the fintech infrastructure layer that would make innovating in financial services 
easier for other developers so that those developers could build tools to help people live healthier 
financial lives.  Except as specifically admitted herein, Plaid denies all allegations in Paragraph 26. 
27. 
Plaid admits that Perret and Hockey presented at NYC Data Business Meetup in 
February 2013.  Plaid admits that the quoted language, but not the non-quoted characterizations, 
was said among other language during the cited presentation (though it has been taken out of 
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context).  Plaid denies all other allegations contained in Paragraph 27 except as specifically 
admitted herein. 
28. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appears among other language on the cited job posting pages (though it has been taken out of 
context). Plaid denies all other allegations and characterizations in Paragraph 28 except as 
specifically admitted herein. 
29. 
Plaid admits that the cited interview describes the origin of the Plaid name.  Plaid 
denies all other allegations and characterizations in Paragraph 29 except as specifically admitted 
herein.  
30. 
Plaid admits that Venmo was one of its earliest clients.  Plaid denies all other 
allegations and characterizations in Paragraph 30 except as specifically admitted herein. 
31. 
Plaid admits that it provides software used by third-party developers, including 
developers of Venmo, Coinbase, and Square’s CashApp.  Plaid lacks sufficient knowledge or 
information to admit or deny the remainder of the allegations in Paragraph 31 and, on that basis, 
denies them. 
32. 
In response to the second sentence of Paragraph 32, Plaid admits that it provides 
products and services that enable consumers to easily and securely link their financial accounts 
with third-party applications of their choosing and that can help application developers authenticate 
financial accounts.  Plaid admits that authenticating bank accounts is important for the safety and 
security of payment transfers using mobile apps. Plaid lacks sufficient knowledge or information 
to admit or deny the fourth sentence of Paragraph 32 and, on that basis, denies it.  Plaid denies all 
allegations and characterizations of Paragraph 32 except as specifically admitted herein. 
33. 
Plaid admits that a small number of financial institutions currently offer an OAuth 
implementation to companies with which they have executed a data access agreement; the OAuth 
flow allows their customers to authenticate their financial account without giving a third party 
access to their login information.  Plaid denies that OAuth is “typical.”  Plaid denies all allegations 
and characterizations of Paragraph 33 except as specifically admitted herein.  
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NO. 4:20-CV-3056-DMR 
 
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34. 
Plaid admits that at one time (but not currently), Plaid provided linking services 
using banking credentials that were collected from consumers by app developers in line with 
industry standards. Plaid admits that, in order to mitigate risk and minimize proliferation of 
credentials in the ecosystem, it subsequently created Plaid Link, which allowed Plaid to collect 
credentials directly from the consumer.  Plaid denies all allegations and characterizations in 
Paragraph 34 except as specifically admitted herein. 
35. 
Plaid admits that the quoted language, but not the non-quoted characterizations, was 
said in the cited interview (though it has been taken out of context). Plaid denies all other allegations 
and characterizations in Paragraph 35 except as specifically admitted herein. 
36. 
Plaid admits that it provides a user interface, called Plaid Link, that enables 
consumers to securely link their financial accounts with third-party applications of their 
choosing.   Plaid denies all allegations in Paragraph 36 except as specifically admitted herein. 
37. 
Plaid denies the allegations contained in Paragraph 37. 
38. 
Plaid admits that a consumer choosing to link their financial account to Venmo will 
be prompted to select their financial institution from a list (of over 11,000 financial institutions) 
and that that list may include the name, URL, and logo of the financial institution to assist 
consumers in correctly identifying and linking their financial institution. Plaid admits that at one 
time (but not at present) a user of the Venmo app seeking to link an account at Chase, Citibank, or 
Bank of America may have seen images similar to the format reflected in Paragraph 38.  Plaid 
denies all allegations in Paragraph 38 except as specifically admitted herein. 
39. 
Plaid admits that at one time (but not at present) a user of the Venmo app seeking to 
link a financial account at Chase, Citibank, or Bank of America may have seen screens prompting 
the consumer to enter their Chase Bank or Citi Bank “User ID” or their Bank of America “Online 
ID,” respectively.  Plaid admits that, for certain financial institutions, it has collected login 
information with users’ permission as described in its End User Privacy Policy.  Plaid denies all 
allegations in Paragraph 39 except as specifically admitted herein. 
40. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appears among other language on the cited pages (though it has been taken out of context). Plaid 
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denies all other allegations and characterizations in Paragraph 40 except as specifically admitted 
herein. 
41. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appears among other language on the cited page (though it has been taken out of context). Plaid 
denies all other allegations and characterizations in Paragraph 41 except as specifically admitted 
herein. 
42. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appeared at one point in time among other language on the cited page (though it has been taken out 
of context). Plaid denies all other allegations and characterizations in Paragraph 42 except as 
specifically admitted herein. 
43. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appeared among other language on the cited page (though it has been taken out of context). Plaid 
denies all other allegations and characterizations in Paragraph 43 except as specifically admitted 
herein. 
44. 
Plaid admits that the quoted language, but not the non-quoted characterizations, 
appeared among other language within the Consumer Protection Principles released by the 
Consumer Financial Protection Bureau (“CFPB”) on October 18, 2017 (though it has been taken 
out of context). Plaid avers that the CFPB Principles also state that “[c]onsumers are generally able 
to authorize trusted third parties to obtain such information from account providers to use on behalf 
of consumers, for consumer benefit, and in a safe manner.”  Plaid denies all other allegations and 
characterizations in Paragraph 44. 
45. 
Plaid admits that the quoted language appears among other language in Plaid’s 
February 2017 response to CFPB’s Request for Information (though it has been taken out of 
context). Plaid denies all other allegations and characterizations in Paragraph 45 except as 
specifically admitted herein. 
46. 
Plaid admits that the quoted language was said in reference to the early days of Plaid 
and among other things in the cited interview (though it has been taken out of context). Plaid denies 
all other allegations and characterizations in Paragraph 46 except as specifically admitted herein. 
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NO. 4:20-CV-3056-DMR 
 
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47. 
Plaid denies the allegations contained in Paragraph 47. 
48. 
Plaid denies the allegations contained in Paragraph 48. 
49. 
Plaid denies the allegations contained in Paragraph 49. 
50. 
Plaid denies the allegations contained in Paragraph 50. 
51. 
Plaid admits that the quoted language appears among other language in a March 
2013 job posting on the cited page (though it has been taken out of context). Plaid denies all other 
allegations and characterizations in Paragraph 51 except as specifically admitted herein. 
52. 
Plaid admits that the block-quoted language appears among other language on the 
cited page (though it has been taken out of context). Plaid denies all other allegations and 
characterizations in Paragraph 52 except as specifically admitted herein. 
53. 
Plaid admits that it may collect certain information from financial accounts with 
users’ permission, as described in its End User Privacy Policy. Plaid denies all other allegations 
and characterizations in Paragraph 53 except as specifically admitted herein. 
54. 
Plaid admits that the quoted language was said during the cited interview (though it 
has been taken out of context). Plaid denies all other allegations and characterizations in Paragraph 
54 except as specifically admitted herein. 
55. 
Plaid admits that the quoted language appears among other language on the cited 
page and in the cited interview (though it has been taken out of context). Plaid denies all other 
allegations and characterizations in Paragraph 55 except as specifically admitted herein. 
56. 
Plaid admits that it may collect certain information from financial accounts with 
users’ permission, as described in its End User Privacy Policy. Plaid denies all other allegations 
and characterizations in Paragraph 56 except as specifically admitted herein. 
57. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 57 and, on that basis, denies them. 
58. 
Plaid admits that its products and services enable consumers to securely link 
financial accounts at over 11,000 financial institutions with thousands of third-party apps of their 
choosing.  Plaid admits that Visa agreed to purchase Plaid for $4.9 billion in cash and 
approximately $400 million in retention equity and deferred equity but denies that the proposed 
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NO. 4:20-CV-3056-DMR 
 
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sale was consummated.  Plaid denies all other allegations and characterizations in Paragraph 58 
except as specifically admitted herein. 
59. 
Plaid denies the allegations contained in Paragraph 59. 
60. 
Plaid admits that the quoted language appears among other language on the cited 
page (though it has been taken out of context). Plaid denies all other allegations and 
characterizations in Paragraph 60 except as specifically admitted herein. 
61. 
Plaid denies the allegations contained in Paragraph 61. 
62. 
Plaid admits that Visa agreed to purchase Plaid but denies that the proposed sale 
was consummated.  Plaid denies all other allegations and characterizations in Paragraph 62 except 
as specifically admitted herein. 
63. 
Plaid admits that the quoted language in the first sentence of Paragraph 63 appears 
among other language in a 2015 job posting on the cited page (though it has been taken out of 
context and has nothing to do with the sale of data).  Plaid denies all other allegations and 
characterizations in Paragraph 63 except as specifically admitted herein. 
64. 
Plaid admits that the quoted language was said during the cited interview of Zach 
Perret in May 2019 (though it has been taken out of context). Plaid denies all other allegations and 
characterizations in Paragraph 64 except as specifically admitted herein. 
65. 
Plaid denies the allegations and characterizations in the first sentence of Paragraph 
65.  Plaid lacks sufficient knowledge or information to admit or deny the allegations in the second 
sentence of Paragraph 65, which refer to the opinions of other entities and quote from third-party 
sources, and, on that basis, denies them. 
66. 
Plaid admits that it has developed a user interface, called Plaid Link, that app 
developers can integrate within their app to enable consumers to securely link their financial 
accounts with third-party applications of their choosing.  The fifth sentence of Paragraph 66 is a 
legal conclusion to which no response is required.  To the extent that a response is required, Plaid 
denies the allegations in the fifth sentence of Paragraph 66.  Plaid denies all other allegations and 
characterizations in Paragraph 66 except as specifically admitted herein. 
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67. 
Plaid admits that at one time (but not at present) a user of the Venmo app seeking to 
link a financial account may have seen images similar to the format reflected in Paragraph 67. Plaid 
denies all other allegations in Paragraph 67 except as specifically admitted herein. 
68. 
Plaid admits that at one time a user of the Venmo app seeking to link a financial 
account may have seen the text quoted in Paragraph 68. Plaid denies all other allegations and 
characterizations in Paragraph 68 except as specifically admitted herein. 
69. 
Plaid admits that at one time (but not at present) a user of the Venmo app seeking to 
link a financial account may have seen the text quoted in Paragraph 69. Plaid denies all other 
allegations and characterizations in Paragraph 69 except as specifically admitted herein. 
70. 
Plaid denies the allegations in Paragraph 70.  
71. 
Plaid admits that the block-quoted language has appeared among other language in 
past iterations of Plaid’s Privacy Policy (though it has been taken out of context).  Plaid denies all 
other allegations and characterizations in Paragraph 71 except as specifically admitted herein. 
72. 
Plaid admits that at one time (but not at present) a user of the Venmo app seeking to 
link a financial account may have seen images similar to the format reflected in Paragraph 72. Plaid 
denies all other allegations in Paragraph 72 except as specifically admitted herein. 
73. 
Paragraph 73 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 73. 
74. 
Plaid denies the allegations in Paragraph 74.  
75. 
Plaid denies the allegations in Paragraph 75.  
76. 
Plaid admits that the quoted language in the second and third sentence of Paragraph 
76 appears among other language on the cited pages (though they have been taken out of context 
and have nothing to do with disclosures to consumers).  Plaid denies all other allegations and 
characterizations in Paragraph 76 except as specifically admitted herein. 
77. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 77, which refer to third-party sources, and, on that basis, denies them. 
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78. 
Plaid denies the first sentence of Paragraph 78.  Plaid lacks sufficient knowledge or 
information to admit or deny the remainder of the allegations in Paragraph 78, which refer to the 
opinions of other entities and quote from third-party sources, and, on that basis, denies them. 
79. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 79, which refer to the opinions of other entities and quote from third-party sources, and, 
on that basis, denies them. 
80. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 80, which refer to the opinions of other entities and quote from third-party sources, and, 
on that basis, denies them. 
81. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 81, which refer to the opinions of other entities and quote from third-party sources, and, 
on that basis, denies them. 
82. 
Plaid denies the allegations contained in Paragraph 82.  
83. 
Plaid denies the allegations contained in Paragraph 83. 
84. 
The first sentence of Paragraph 84 contains legal conclusions to which no response 
is required.  To the extent that a response is required, Plaid denies the allegations in the first 
sentence of Paragraph 84.  Plaid lacks sufficient knowledge or information to admit or deny the 
remainder of the allegations in Paragraph 84, which refer to third-party materials, and, on that basis, 
denies them. 
85. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 85, which refer to third-party materials, and, on that basis, denies them.  
86. 
Paragraph 86 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
87. 
Paragraph 87 contains legal conclusions to which no response is required.   
88. 
Plaid admits that the quoted language appears among other language in a document 
published by the CFPB in October 2017 entitled “Consumer Protection Principles: Consumer-
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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Authorized Financial Data Sharing and Aggregation.”  Plaid denies all other allegations in 
Paragraph 88 except as specifically admitted herein. 
89. 
Plaid admits that the quoted language appears among other language in Plaid’s 
October 2016 publication: “Financial data access methods: Creating a balanced approach.”   Plaid 
avers that it builds its products with transparency in mind and complies with applicable laws and 
regulations concerning consumer disclosure.  Plaid denies all other allegations in Paragraph 89 
except as specifically admitted herein. 
90. 
Plaid admits that at one point (but not currently) the block-quoted language appeared 
among other language in Plaid’s Terms of Use.  Plaid denies all other allegations and 
characterizations in Paragraph 90 except as specifically admitted herein. 
91. 
Plaid admits that the block-quoted language appears among other language in 
Plaid’s Developer Policy.  Plaid denies all other allegations in Paragraph 91 except as specifically 
admitted herein. 
92. 
Plaid admits that the block-quoted language appeared among other language in 
Plaid’s February 2017 response to the CFPB’s RFI. 
93. 
Plaid admits that the block-quoted language appeared among other language in 
Plaid’s March 2019 letter to the U.S. Senate Committee on Banking, Housing and Urban 
Affairs.  Plaid admits that consumer permission and control are core principles, and that Plaid has 
developed disclosures and privacy policies designed to help consumers understand which 
information is collected and how it is used, shared and stored. Plaid denies all other allegations in 
Paragraph 93 except as specifically admitted herein. 
94. 
Admitted. 
95. 
Paragraph 95 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
96. 
Paragraph 96 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies that it violates any of the referenced provisions. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 12 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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97. 
Paragraph 97 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies that it violates any of the referenced provisions. 
98. 
Paragraph 98 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
99. 
Plaid denies the allegation contained in Paragraph 99. 
100. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 100 and, on that basis, denies them. 
101. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 101 and, on that basis, denies them. 
102. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 102 and, on that basis, denies them. 
103. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 103 and, on that basis, denies them. 
104. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 104 and, on that basis, denies them. 
105. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 105 and, on that basis, denies them. 
106. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 106 and, on that basis, denies them. 
107. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 107 and, on that basis, denies them. 
108. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 108 and, on that basis, denies them. 
109. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 109 and, on that basis, denies them. 
110. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 110 and, on that basis, denies them. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 13 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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111. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 111 and, on that basis, denies them. 
112. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 112 and, on that basis, denies them. 
113. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 113 and, on that basis, denies them. 
114. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 114 and, on that basis, denies them. 
115. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 115 and, on that basis, denies them. 
116. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 116 and, on that basis, denies them. 
117. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 117 and, on that basis, denies them. 
118. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 118 and, on that basis, denies them. 
119. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 119 and, on that basis, denies them. 
120. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 120 and, on that basis, denies them. 
121. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 121 and, on that basis, denies them. 
122. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 122 and, on that basis, denies them. 
123. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 123 and, on that basis, denies them. 
124. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 124 and, on that basis, denies them. 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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125. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 125 and, on that basis, denies them. 
126. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 126 and, on that basis, denies them. 
127. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 127 and, on that basis, denies them. 
128. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 128 and, on that basis, denies them. 
129. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 129 and, on that basis, denies them. 
130. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 130 and, on that basis, denies them. 
131. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 131 and, on that basis, denies them. 
132. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 132 and, on that basis, denies them. 
133. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 133 and, on that basis, denies them. 
134. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 134 and, on that basis, denies them. 
135. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 135 and, on that basis, denies them. 
136. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 136 and, on that basis, denies them. 
137. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 137 and, on that basis, denies them. 
138. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 138 and, on that basis, denies them. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 15 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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139. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 139 and, on that basis, denies them. 
140. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 140 and, on that basis, denies them. 
141. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 141 and, on that basis, denies them. 
142. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 142 and, on that basis, denies them. 
143. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 143 and, on that basis, denies them. 
144. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 144 and, on that basis, denies them. 
145. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 145 and, on that basis, denies them. 
146. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 146 and, on that basis, denies them. 
147. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 147 and, on that basis, denies them. 
148. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 148 and, on that basis, denies them. 
149. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 149 and, on that basis, denies them. 
150. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 150 and, on that basis, denies them. 
151. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 151 and, on that basis, denies them. 
152. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 152 and, on that basis, denies them. 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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153. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 153 and, on that basis, denies them. 
154. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 154 and, on that basis, denies them. 
155. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 155 and, on that basis, denies them. 
156. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 156 and, on that basis, denies them. 
157. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 157 and, on that basis, denies them. 
158. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 158 and, on that basis, denies them. 
159. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 159 and, on that basis, denies them. 
160. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 160 and, on that basis, denies them. 
161. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 161 and, on that basis, denies them. 
162. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 162 and, on that basis, denies them. 
163. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 163 and, on that basis, denies them. 
164. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 164 and, on that basis, denies them. 
165. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 165 and, on that basis, denies them. 
166. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 166 and, on that basis, denies them. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 17 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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167. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 167 and, on that basis, denies them. 
168. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 168 and, on that basis, denies them. 
169. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 169 and, on that basis, denies them. 
170. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 170 and, on that basis, denies them. 
171. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 171 and, on that basis, denies them. 
172. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 172 and, on that basis, denies them. 
173. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 173 and, on that basis, denies them. 
174. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 174 and, on that basis, denies them. 
175. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 175 and, on that basis, denies them. 
176. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 175 and, on that basis, denies them. 
177. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 177 and, on that basis, denies them. 
178. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 178 and, on that basis, denies them. 
179. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 179 and, on that basis, denies them. 
180. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 180 and, on that basis, denies them. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 18 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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181. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 181 and, on that basis, denies them. 
182. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 182 and, on that basis, denies them. 
183. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 183 and, on that basis, denies them. 
184. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 184 and, on that basis, denies them. 
185. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 185 and, on that basis, denies them. 
186. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 186 and, on that basis, denies them. 
187. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 187 and, on that basis, denies them. 
188. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 188 and, on that basis, denies them. 
189. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 189 and, on that basis, denies them. 
190. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 190 and, on that basis, denies them. 
191. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 191 and, on that basis, denies them. 
192. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 192 and, on that basis, denies them. 
193. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 193 and, on that basis, denies them. 
194. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 194 and, on that basis, denies them. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 19 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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195. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 195 and, on that basis, denies them. 
196. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 196 and, on that basis, denies them. 
197. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 197 and, on that basis, denies them. 
198. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 198 and, on that basis, denies them. 
199. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 199 and, on that basis, denies them. 
200. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 200 and, on that basis, denies them. 
201. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 201 and, on that basis, denies them. 
202. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 202 and, on that basis, denies them. 
203. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 203 and, on that basis, denies them. 
204. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 204 and, on that basis, denies them. 
205. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 205 and, on that basis, denies them. 
206. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 206 and, on that basis, denies them. 
207. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 207 and, on that basis, denies them. 
208. 
Paragraph 208 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 208. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 20 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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209. 
Paragraph 209 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 209. 
210. 
Paragraph 210 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 210. 
211. 
Paragraph 211 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 211. 
212. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 212, which refer to a third-party survey, and, on that basis, denies them. 
213. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations and 
characterizations in Paragraph 213, which refer to a third-party survey, and, on that basis, denies 
them.  
214. 
Paragraph 214 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 214. 
215. 
Paragraph 215 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 215. 
216. 
Paragraph 216 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 216. 
217. 
Paragraph 217 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations.  
218. 
Paragraph 218 contains legal conclusions to which no response is required.  Plaid 
also lacks sufficient knowledge or information to admit or deny the allegations in Paragraph 218, 
which refers to positions of third parties, and, on that basis, denies them. 
219. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 219, which refers to statements and positions of third parties, and, on that basis, denies 
them. 
220. 
Plaid denies the allegations in Paragraph 220. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 21 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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221. 
Paragraph 221 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 221. 
222. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 222, which refers to statements and positions of third parties, and, on that basis, denies 
them. 
223. 
Paragraph 223 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 223. 
224. 
Paragraph 224 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 224. 
225. 
Paragraph 225 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 225. 
226. 
Paragraph 226 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 226. 
227. 
Paragraph 227 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 227. 
228. 
Plaid denies that Plaintiffs and Class members suffered loss of use and control to 
Plaid of their own sensitive financial information.  Plaid lacks sufficient knowledge or information 
to admit or deny the remainder of the allegations in Paragraph 228 and, on that basis, denies them. 
229. 
The first sentence of Paragraph 229 contains legal conclusions to which no response 
is required.  To the extent that a response is required, Plaid denies those allegations.  Plaid further 
denies the allegations and characterizations in the second sentence of Paragraph 229. 
230. 
Plaid denies the allegations in Paragraph 230. 
231. 
Paragraph 231 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 231. 
232. 
Plaid denies the allegations in the first sentence of Paragraph 232.  Plaid lacks 
sufficient knowledge or information to admit or deny the allegations in the block-quoted portion of 
Paragraph 232 and, on that basis, denies them. 
233. 
Plaid denies the allegations in Paragraph 233. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 22 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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234. 
Plaid denies the allegations in Paragraph 234. 
235. 
Plaid denies the allegations in Paragraph 235. 
236. 
Paragraph 236 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 236. 
237. 
Paragraph 237 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid admits that Plaid’s headquarters and principal place of 
business are in California.  Except as specifically admitted herein, Plaid denies the allegations in 
Paragraph 237. 
238. 
Paragraph 238 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 238. 
239. 
Paragraph 239 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 239. 
240. 
Plaid denies the allegations in Paragraph 240. 
241. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 241 and, on that basis, denies them. 
242. 
Paragraph 242 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 242. 
243. 
Paragraph 243 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 243. 
244. 
Paragraph 244 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 244. 
245. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein. 
246. 
Paragraph 246 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
247. 
Paragraph 247 contains Plaintiffs’ proposed class definition, to which no response 
is required. Plaid denies that any class can be certified under Rule 23. 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 23 of 41

 
 
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PLAID’S ANSWER TO CONSOLIDATED 
AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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248. 
Paragraph 248 contains Plaintiffs’ proposed class definition, to which no response 
is required. Plaid denies that any class can be certified under Rule 23. 
249. 
Paragraph 249 contains exclusions from Plaintiffs’ proposed class definition, to 
which no response is required. Plaid denies that any class can be certified under Rule 23. 
250. 
Paragraph 250 contains legal conclusions to which no response is required.  Plaid 
denies that Plaintiffs can modify their proposed Class definitions as a matter of right. 
251. 
Paragraph 251 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 251. 
252. 
Paragraph 252 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid lacks sufficient knowledge or information to admit or deny 
the allegations in Paragraph 252, which refer to statistics relating to third parties, and, on that basis, 
denies them. 
253. 
Paragraph 253 contains legal conclusions to which no response is required.  Plaid 
denies that any class can be certified under Rule 23. 
254. 
Paragraph 254 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 254 and denies that any 
class can be certified under Rule 23. 
255. 
Paragraph 255 contains legal conclusions to which no response is required.  Plaid 
denies that any class can be certified under Rule 23. 
256. 
Paragraph 256 contains legal conclusions to which no response is required.  Plaid 
denies that any class can be certified under Rule 23. 
257. 
Paragraph 257 contains legal conclusions to which no response is required.  Plaid 
denies that any class can be certified under Rule 23. 
258. 
Paragraph 258 contains legal conclusions to which no response is required.  Plaid 
denies that any class can be certified under Rule 23. 
259. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein.   Paragraph 259 contains legal 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 24 of 41

 
 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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conclusions to which no response is required.  To the extent that a response is required, Plaid denies 
the allegations in Paragraph 259. 
260. 
Paragraph 260 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
261. 
Paragraph 261 contains legal allegations to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 261.  
262. 
Paragraph 262 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 262. 
263. 
Paragraph 263 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 263. 
264. 
Paragraph 264 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 264. 
265. 
Paragraph 265 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 265. 
266. 
Paragraph 266 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 266. 
267. 
Paragraph 267 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 267. 
268. 
Paragraph 268 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 268. 
269. 
Paragraph 269 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 269. 
270. 
Plaid denies Paragraph 270 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
271. 
Plaid denies Paragraph 271 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
272. 
Plaid denies Paragraph 272 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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273. 
Plaid denies Paragraph 273 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
274. 
Plaid denies Paragraph 274 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
275. 
Plaid denies Paragraph 275 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
276. 
Plaid denies Paragraph 276 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
277. 
Plaid denies Paragraph 277 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
278. 
Plaid denies Paragraph 278 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
279. 
Plaid denies Paragraph 279 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
280. 
Plaid denies Paragraph 280 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
281. 
Plaid denies Paragraph 281 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
282. 
Plaid denies Paragraph 282 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
283. 
Plaid denies Paragraph 283 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
284. 
Plaid denies Paragraph 284 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
285. 
Plaid denies Paragraph 285 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
286. 
Plaid denies Paragraph 286 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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287. 
Plaid denies Paragraph 287 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
288. 
Plaid denies Paragraph 288 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
289. 
Plaid denies Paragraph 289 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
290. 
Plaid denies Paragraph 290 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
291. 
Plaid denies Paragraph 291 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
292. 
Plaid denies Paragraph 292 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
293. 
Plaid denies Paragraph 293 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
294. 
Plaid denies Paragraph 294 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
295. 
Plaid denies Paragraph 295 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
296. 
Plaid denies Paragraph 296 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
297. 
Plaid denies Paragraph 297 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
298. 
Plaid denies Paragraph 298 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
299. 
Plaid denies Paragraph 299 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
300. 
Plaid denies Paragraph 300 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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301. 
Plaid denies Paragraph 301 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
302. 
Plaid denies Paragraph 302 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
303. 
Plaid denies Paragraph 203 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
304. 
Plaid denies Paragraph 304 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
305. 
Plaid denies Paragraph 305 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
306. 
Plaid denies Paragraph 306 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
307. 
Plaid denies Paragraph 307 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
308. 
Plaid denies Paragraph 308 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
309. 
Plaid denies Paragraph 309 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
310. 
Plaid denies Paragraph 310 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
311. 
Plaid denies Paragraph 311 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
312. 
Plaid denies Paragraph 312 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
313. 
Plaid denies Paragraph 313 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
314. 
Plaid denies Paragraph 314 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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NO. 4:20-CV-3056-DMR 
 
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315. 
Plaid denies Paragraph 315 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
316. 
Plaid denies Paragraph 316 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
317. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein. 
318. 
Paragraph 318 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
319. 
Paragraph 319 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 319.  
320. 
Paragraph 320 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 320. 
321. 
Paragraph 321 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 321.   
322. 
Paragraph 322 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 322.   
323. 
Paragraph 323 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 323. 
324. 
Paragraph 324 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 324. 
325. 
Paragraph 325 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 325. 
326. 
Plaid denies Paragraph 326 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
327. 
Plaid denies Paragraph 327 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
328. 
Plaid denies Paragraph 328 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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329. 
Plaid denies Paragraph 329 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
330. 
Plaid denies Paragraph 330 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
331. 
Plaid denies Paragraph 331 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
332. 
Plaid denies Paragraph 332 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
333. 
Plaid denies Paragraph 333 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
334. 
Plaid denies Paragraph 334 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
335. 
Plaid denies Paragraph 335 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
336. 
Plaid denies Paragraph 336 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
337. 
Plaid denies Paragraph 337 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
338. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein. 
339. 
Paragraph 339 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
340. 
Paragraph 340 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 340. 
341. 
Paragraph 341 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 341. 
342. 
Paragraph 342 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 342. 
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NO. 4:20-CV-3056-DMR 
 
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343. 
Paragraph 343 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 343. 
344. 
Paragraph 344 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 344. 
345. 
Paragraph 345 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 345. 
346. 
Paragraph 346 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 346. 
347. 
Paragraph 347 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 347. 
348. 
Paragraph 348 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 348. 
349. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein. 
350. 
Paragraph 350 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
351. 
Paragraph 351 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
352. 
Plaid lacks sufficient knowledge or information to admit or deny the allegations in 
Paragraph 352 and, on that basis, denies them. 
353. 
Paragraph 353 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
354. 
Paragraph 354 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid responds that it complies with applicable laws and 
regulations. 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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355. 
Paragraph 355 contains legal conclusions to which no response is required.  To the 
extent a response is required, Plaid denies the allegations in Paragraph 355. 
356. 
Plaid realleges and incorporates by reference the foregoing admissions, denials, 
averments, and responses as though fully set forth herein. 
357. 
Paragraph 357 contains Plaintiffs’ characterization of their action, to which no 
response is required.  Plaid denies that any class can be certified under Rule 23. 
358. 
Paragraph 358 contains legal conclusions to which no response is required.   To the 
extent that a response is required, Plaid denies the allegations in Paragraph 358. 
359. 
Paragraph 359 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 359. 
360. 
Paragraph 360 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 360. 
361. 
Paragraph 361 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 361. 
362. 
Paragraph 362 contains legal conclusions to which no response is required.  To the 
extent that a response is required, Plaid denies the allegations in Paragraph 362. 
363. 
Paragraph 363 is Plaintiffs’ characterization of their claims to which no response is 
required.  Plaid denies that Plaintiffs are entitled to any of the requested relief. 
364. 
Plaid denies Paragraph 364 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
365. 
Plaid denies Paragraph 365 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
366. 
Plaid denies Paragraph 366 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
367. 
Plaid denies Paragraph 367 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
368. 
Plaid denies Paragraph 368 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
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AMENDED COMPLAINT 
NO. 4:20-CV-3056-DMR 
 
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369. 
Plaid denies Paragraph 369 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
370. 
Plaid denies Paragraph 370 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
371. 
Plaid denies Paragraph 371 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
372. 
Plaid denies Paragraph 372 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
373. 
Plaid denies Paragraph 373 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
374. 
Plaid denies Paragraph 374 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
375. 
Plaid denies Paragraph 375 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
376. 
Plaid denies Paragraph 376 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
377. 
Plaid denies Paragraph 377 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
378. 
Plaid denies Paragraph 378 as moot in light of the Court’s dismissal with prejudice 
of this claim.  (See ECF No. 125.) 
 
PRAYER FOR RELIEF 
To the extent a response is required, Plaid denies that Plaintiffs or class members have 
suffered any harm or damage of any kind and denies that Plaintiffs or class members are entitled to 
the relief sought or any other relief.  
 
AFFIRMATIVE DEFENSES 
Plaid asserts the following affirmative defenses to the remaining claims in Plaintiffs’ 
Consolidated Amended Class Action Complaint for Damages and Declaratory and Equitable Relief 
(the “Complaint”) for: (1) alleged invasion of privacy (intrusion into private affairs) (the “Invasion 
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NO. 4:20-CV-3056-DMR 
 
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of Privacy Claim”); (2) alleged violations of the California Constitutional Right to Privacy (Article 
I, Section I of the California Constitution) (together, with the Invasion of Privacy claim, the 
“Privacy Claims”); (3) alleged violations of the California Anti-Phishing Act of 2005 (the “APA 
Claims”); (4) alleged deceit (i.e., alleged violations of California Civil Code sections 1709 and 
1710) (the “Deceit Claims”); and (5) alleged unjust enrichment (i.e., Plaintiffs’ quasi-contract claim 
for restitution and disgorgement) (the “Unjust Enrichment Claim”).  
Plaid asserts these affirmative defenses without assuming the burden of proof for such 
defenses that would otherwise fall on Plaintiffs.  Further, Plaid reserves the right to supplement or 
amend these affirmative defenses as discovery is further conducted and does not knowingly or 
intentionally waive any applicable affirmative defense.  Finally, Plaid repeats, re-alleges, and 
incorporates by reference herein each and every response to every paragraph above and below as if 
fully set forth in each of Plaid’s affirmative defenses below. 
FIRST DEFENSE 
Plaintiffs’ Complaint fails to state any claims for which relief may be granted against Plaid. 
SECOND DEFENSE 
Plaintiffs’ Deceit Claims are barred, in whole or in part, because Plaintiffs ratified Plaid’s 
alleged conduct.  
On information and belief, to the extent Plaintiffs used Plaid at all, Plaintiffs knowingly 
consented to use Plaid’s services when they chose to link their financial account(s) to third-party 
applications of their choosing and agreed to Plaid’s End User Privacy Policy.  On information and 
belief, Plaintiffs, after learning of Plaid’s role in connecting their financial account(s) to third party 
applications of their choosing, continued on a voluntary basis to use Plaid’s services and/or chose 
not to disconnect their linked accounts from their chosen third-party applications and/or chose not 
to request that Plaid delete their data.  On information and belief, Plaintiffs knowingly consented 
to use Plaid’s services when they chose to re-link their financial account(s) to their selected third-
party applications or initiated new connections between their financial account(s) and additional 
third-party applications and agreed to Plaid’s End User Privacy Policy.  
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NO. 4:20-CV-3056-DMR 
 
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Plaintiffs received substantial benefits by taking affirmative action to link their financial 
accounts through Plaid, and at the same time waived any right to claim any damages related to that 
use.  Plaintiffs’ Deceit Claims are thus barred, in whole or in part, by Plaintiffs’ ratification of 
Plaid’s alleged conduct. 
THIRD DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
by the relevant and applicable statutes of limitations for each respective claim.  
As set forth above, Plaintiffs had actual or imputed (or, at a minimum, constructive) 
knowledge of Plaid’s products and services, with which they appear to take issue in their 
Complaint, since at least 2017.  Because of Plaintiffs’ actual, imputed, and/or constructive 
knowledge of Plaid’s alleged conduct dating back to at least 2017, any limitations periods 
associated with Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims should not be 
tolled.  Accordingly, since Plaintiffs did not bring any claims against Plaid until 2020, Plaintiffs’ 
Privacy Claims, APA Claims, and Deceit Claims are therefore barred, in whole or in part, by the 
relevant statutes of limitations. 
FOURTH DEFENSE 
Plaintiff’s Privacy Claims and APA Claims are barred, in whole or in part, because Plaintiffs 
consented, impliedly or expressly, to Plaid’s alleged conduct. 
On information and belief, to the extent Plaintiffs used Plaid at all, Plaintiffs knowingly 
consented to use Plaid’s services when they chose to link their financial account(s) to third-party 
applications of their choosing and agreed to Plaid’s End User Privacy Policy.  On information and 
belief, Plaintiffs, after learning of Plaid’s role in connecting their financial account(s) to third party 
applications of their choosing, continued on a voluntary basis to use Plaid’s services and/or chose 
not to disconnect their linked accounts from their chosen third-party applications and/or chose not 
to request that Plaid delete their data.  On information and belief, Plaintiffs knowingly consented 
to use Plaid’s services when they chose to re-link their financial account(s) to their selected third-
party applications or initiated new connections between their financial account(s) and additional 
third-party applications and agreed to Plaid’s End User Privacy Policy.   
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NO. 4:20-CV-3056-DMR 
 
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Plaintiffs thus consented to Plaid’s practices when they linked their financial accounts to 
third-party applications of their choosing using Plaid and agreed to Plaid’s privacy 
policy.  Moreover, Plaintiffs’ continued use of third-party applications, all while knowing of those 
applications’ use of Plaid’s products and services, implies and indicates that Plaintiffs consented to 
all practices disclosed in Plaid’s privacy policy. 
FIFTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, Deceit Claims, and Unjust Enrichment Claim are 
barred, in whole or in part, by the doctrine of waiver.  
On information and belief, to the extent Plaintiffs used Plaid at all, Plaintiffs knowingly 
consented to use Plaid’s services when they chose to link their financial account(s) to third-party 
applications of their choosing and agreed to Plaid’s End User Privacy Policy.  On information and 
belief, Plaintiffs, after learning of Plaid’s role in connecting their financial account(s) to third party 
applications of their choosing, continued on a voluntary basis to use Plaid’s services and/or chose 
not to disconnect their linked accounts from their chosen third-party applications and/or chose not 
to request that Plaid delete their data.  On information and belief, Plaintiffs knowingly consented 
to use Plaid’s services when they chose to re-link their financial account(s) to their selected third-
party applications or initiated new connections between their financial account(s) and additional 
third-party applications and agreed to Plaid’s End User Privacy Policy.   
Plaintiffs thus waived their Privacy Claims, APA Claims, Deceit Claims, and Unjust 
Enrichment Claim—and relinquished any other alleged enforceable rights and claims against 
Plaid—when they knowingly linked their financial accounts to third-party applications through 
Plaid and benefited from the third-party applications’ use of Plaid’s products and services. 
SIXTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, Deceit Claims, and Unjust Enrichment Claim are 
barred, in whole or in part, by the doctrine of laches.  
On information and belief, to the extent Plaintiffs used Plaid at all, Plaintiffs knowingly 
consented to use Plaid’s services when they chose to link their financial account(s) to third-party 
applications of their choosing and agreed to Plaid’s End User Privacy Policy.  On information and 
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belief, Plaintiffs, after learning of Plaid’s role in connecting their financial account(s) to third party 
applications of their choosing, continued on a voluntary basis to use Plaid’s services and/or chose 
not to disconnect their linked accounts from their chosen third-party applications and/or chose not 
to request that Plaid delete their data.  On information and belief, Plaintiffs knowingly consented 
to use Plaid’s services when they chose to re-link their financial account(s) to their selected third-
party applications or initiated new connections between their financial account(s) and additional 
third-party applications and agreed to Plaid’s End User Privacy Policy.   
The doctrine of laches thus bars Plaintiffs’ Privacy Claims, APA Claims, Deceit Claims, 
and Unjust Enrichment Claim because Plaintiffs had actual and/or constructive knowledge of 
Plaid’s alleged conduct in at least 2017, yet failed to bring any such claims against Plaid until 
2020.  During this delay, Plaid detrimentally relied on Plaintiffs’ delay and continued to develop 
its products and services and relationships with financial institutions and third-party 
applications.  This significant and improper delay now prevents Plaintiffs from asserting such 
claims. 
SEVENTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, Deceit Claims, and Unjust Enrichment Claim are 
barred, in whole or in part, by the doctrine of estoppel.  
On information and belief, to the extent Plaintiffs used Plaid at all, Plaintiffs knowingly 
consented to use Plaid’s services when they chose to link their financial account(s) to third-party 
applications of their choosing and agreed to Plaid’s End User Privacy Policy.  On information and 
belief, Plaintiffs, after learning of Plaid’s role in connecting their financial account(s) to third party 
applications of their choosing, continued on a voluntary basis to use Plaid’s services and/or chose 
not to disconnect their linked accounts from their chosen third-party applications and/or chose not 
to request that Plaid delete their data.  On information and belief, Plaintiffs knowingly consented 
to use Plaid’s services when they chose to re-link their financial account(s) to their selected third-
party applications or initiated new connections between their financial account(s) and additional 
third-party applications and agreed to Plaid’s End User Privacy Policy.   
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Plaintiffs’ conduct now estops them from bringing their Privacy Claims, APA Claims, 
Deceit Claims, and Unjust Enrichment Claim against Plaid.  Plaintiffs had actual and/or 
constructive knowledge of third-party applications’ use of Plaid’s products and services since at 
least 2017, continued to use the third-party applications using Plaid’s products and services with 
said knowledge, and subsequently used Plaid’s products and services to link their financial 
account(s) to additional third-party applications with said knowledge.  The doctrine of estoppel 
now bars them from asserting any such claims against Plaid. 
EIGHTH DEFENSE 
Plaintiffs’ APA Claims are barred by the doctrine of due process.  Plaintiffs’ statutory 
damages claims under California’s Anti-Phishing Act are grossly disproportionate to any such harm 
Plaintiffs allege they incurred.  Indeed, Plaintiffs have not alleged that they were the victims of a 
phishing scheme that led to identity theft, caused their accounts to be hijacked, or otherwise harmed 
or affected them in another way; rewarding them for the lack of any alleged harm would be grossly 
excessive.  The doctrine of due process prohibits the imposition of grossly excessive punishments 
on alleged tortfeasors, and thus prohibits Plaintiffs from seeking such damages against Plaid in this 
Action.  See generally BMW of N. Am., Inc. v. Gore, 517 U.S. 559 (1996). 
NINTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, Deceit Claims, and Unjust Enrichment Claim are 
barred, in whole or in part, because of Plaintiffs’ failure to mitigate or attempt to mitigate damages, 
if any such damages exist. 
On information and belief, Plaintiffs knowingly chose to use Plaid’s services by linking 
their financial account to third-party applications by expressly or impliedly agreeing via a user 
interface to Plaid’s involvement.  On information and belief, Plaintiffs, after learning of Plaid’s 
involvement in linking their various accounts with financial institutions to third party applications, 
continued on a voluntary basis to use the third-party applications (and therefore Plaid’s products 
and services) with knowledge that Plaid’s services were being used to provide linking and 
verification services to their financial institutions.  On information and belief, Plaintiffs voluntarily 
re-linked their financial accounts to third-party applications or initiated new connections between 
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their financial accounts and third-party applications by expressly or impliedly agreeing via a user 
interface to Plaid’s involvement and/or with knowledge that Plaid’s services were being used to 
provide linking and verification services to their financial institutions.  
 Plaintiffs have thus admitted to using apps incorporating Plaid’s products and services and, 
on information and belief, have voluntarily linked their financial accounts to additional third-party 
applications and permissioned Plaid to obtain additional information from their financial accounts 
even after they filed this lawsuit.  Should the Court award Plaintiffs any such damages, Plaintiffs’ 
failure to mitigate or attempt to mitigate damages must reduce Plaintiffs’ recovery from Plaid. 
TENTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
because Plaintiffs’ claimed injuries and damages, if any, were caused by the acts and omissions of 
persons, individuals, and entities other than Plaid.  To the extent Plaintiffs were not aware of the 
relevant third-party applications utilizing Plaid’s products and services, any such alleged injuries 
and damages were caused as a result of the acts and omissions of persons, individuals, and entities 
other than Plaid. 
ELEVENTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
because Plaintiffs would be unjustly enriched if they recovered from Plaid any of the damages 
alleged in the Complaint.  Plaintiffs have received significant benefit from third-party applications’ 
use of Plaid’s products and services, and to compensate Plaintiffs in addition to such benefits would 
impermissibly and unjustly enrich Plaintiffs. 
TWELFTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
by the doctrine of unclean hands because, among other reasons, Plaintiffs neglected to prosecute 
their claims against Plaid while (1) continuing to use Plaid’s products and services through various 
third-party applications and (2) reaping the benefits of the third-party applications’ use of Plaid’s 
products and services. 
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THIRTEENTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
because they are frivolous, designed to harass and annoy Plaid, and are not brought in good 
faith.  Throughout the litigation, Plaintiffs have already involved and incorporated 12 law firms and 
19 named Plaintiffs (some of whom were dropped from operative Complaint), and have levied over 
112 pages and 378 paragraphs of allegations at Plaid.  Though Plaintiffs’ Privacy Claims, APA 
Claims, and Deceit Claims remain active, it is clear that Plaintiffs’ litigation strategy has largely 
been used to harass and annoy Plaid with frivolous claims for Plaintiffs’ pecuniary gain. 
FOURTEENTH DEFENSE 
Plaintiffs’ Privacy Claims, APA Claims, and Deceit Claims are barred, in whole or in part, 
to the extent that Plaintiffs may have recovered any of the damages or other relief alleged in the 
Complaint from sources other than Plaid. 
*  *  * 
PRAYER FOR RELIEF 
WHEREFORE, Plaid prays as follows: 
1. 
That Plaintiffs take nothing by reason of the Complaint; 
2. 
That judgment be entered in favor of Plaid; 
3. 
That the Court award Plaid its costs incurred in defense of this action, including 
attorneys’ fees; and 
4. 
That the Court grant such other and further relief as it may deem proper. 
DEMAND FOR JURY TRIAL 
Plaid demands a jury trial on any claims or defenses to which such right is afforded. 
 
 
 
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NO. 4:20-CV-3056-DMR 
 
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Dated: June 4, 2021 
 
COOLEY LLP 
By:/s/ Michael G. Rhodes 
Michael G. Rhodes 
Attorneys for Defendant 
Plaid Inc. 
 
 
 250339390  
 
Case 4:20-cv-03056-DMR   Document 130   Filed 06/04/21   Page 41 of 41

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