Declaration of Steven Weisbrot on Behalf of Angeion Group, LLC in Support of 146 Terminate… — Plaid Privacy (Dkt. 149)

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Supplemental Declaration of Steven Weisbrot on behalf of Angeion Group, LLC, Doc. 149, filed October 7, 2021 in In re Plaid Inc. Privacy Litigation, Master Docket No. 4:20-cv-03056-DMR, U.S. District Court for the Northern District of California, Oakland Division. Steven Weisbrot states that he is the President and Chief Executive Officer of the class action notice and claims administration firm Angeion Group, LLC. The declaration gives cost estimates for three notice scenarios, including mailing a postcard notice to approximately 62 million records at approximately $22 million, and reviews claims rates from prior administrations. It states that Angeion estimates the anticipated claims rate in this Settlement will likely fall in the range of 1% - 4%. It is dated October 7, 2021.

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1 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
 
IN RE PLAID INC. PRIVACY  
LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
SUPPLEMENTAL DECLARATION OF  
STEVEN WEISBROT ON BEHALF 
OF ANGEION GROUP, LLC 
 
 
I, Steven Weisbrot, hereby declare under penalty of perjury pursuant to 28 U.S.C. § 1746 
that the following is true and correct: 
1. 
I am the President and Chief Executive Officer at the class action notice and claims 
administration firm Angeion Group, LLC (“Angeion”). My credentials where previously provided 
in my Declaration that was submitted to the Court on August 5, 2021 (ECF No. 135-4). 
2. 
The purpose of this Supplemental Declaration is to provide the Court with additional 
information regarding the costs associated with sending the class notice (in the form of a postcard) 
via U.S. Mail to every proposed Class Member for whom Plaid has a physical mailing address, as 
well as to provide an analysis of claims rates that Angeion reviewed and the factual basis that 
supported Angeion’s estimated claims rate. 
3. 
In summary, we have prepared cost estimates associated with the following 3 scenarios for 
the Court’s consideration: 
I. 
Mail Notice to all Class Members with a Physical Mailing Address; 
II. 
Email Notice to all Class Members with Email Addresses and Mail Notice to Class 
Members with Mailing Addresses but no Email Addresses12; and 
 
1 For clarity, sub para II was the direct notice plan previously submitted to the court as outlined in my prior declaration. 
2 Angeion was informed based on Plaid’s current information that there are approximately 277,000 Class Member 
records that have mailing addresses but no email addresses. 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 1 of 8

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2 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
III. 
Email Notice to all Class Members with Email Addresses, Mail Notice to Class 
Members with Mailing Addresses but no Email Addresses and Mail Notice to Class 
Members whose Email Notice could not be delivered, i.e., bounce-backs. 
4. 
Angeion was informed that Plaid currently estimates that it has approximately 62 million 
unique email addresses for certain Class Members and has approximately 62 million physical 
mailing addresses for certain Class Members. Angeion utilized these totals to formulate the below 
estimates and also provided estimated costs associated with a 1%- and 4% claims filing rate.3 
Estimated Costs to Mail Notice to all Class Members  
with Physical Mailing Addresses 
 
5. 
The estimated cost to mail a postcard notice to the approximate 62 million records for whom 
Plaid has physical mailing addresses is approximately $22 million, of which approximately $20.1 
million is solely postage costs, with the remaining $1.8 million for printing and labor costs, 
including any requisite data work, formatting the notice and the costs for utilizing the United States 
Post Office (“USPS”) National Change of Address database.   
6. 
Angeion assumes that approximately 10% of the postcard notices (approximately 6.2 
million notices) will be returned by the USPS as undeliverable4. As described in my prior 
Declaration, Notices returned to Angeion by the USPS with a forwarding address will be re-mailed 
to the new address provided by the USPS; Notices returned to Angeion by the USPS without 
forwarding addresses will be subjected to an address verification search (commonly referred to as 
“skip tracing”) utilizing a wide variety of data sources, including public records, real estate records, 
electronic directory assistance listings, etc., to locate updated addresses, and for any Class Members 
where a new address is identified through the skip trace process, a Notice will be re-mailed to that 
address. 
7. 
Angeion estimates that the cost to process 6.2 million undeliverable notices, skip trace and 
re-mail approximately 3.78 million notices will be $3.7 million. This estimate may vary based on 
 
4 This is only an estimate. The number of notices that are returned as undeliverable by the USPS will not be known until 
after the initial mailing is complete and is dependent on several factors, including inter alia, the quality and recency of 
the address information provided by Plaid and whether Class Members filed a change of address card with the USPS. 
3 As discussed in greater detail below, Angeion estimates a claims rate of 1%-4%. 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 2 of 8

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3 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
the actual number of notices returned as undeliverable by the USPS and the success rate of skip 
tracing, which will dictate the actual number of notices that will need to be re-mailed. The estimated 
$3.67 million cost is in addition to the initial mailing costs discussed in paragraph 3.  
8. 
The below chart summarizes an estimate of overall administration costs if notice is provided 
by mail to all Class Members for whom Plaid has physical mailing addresses. The below estimate 
also provides for the difference in costs if there is a 1% claims rate versus a 4% claims rate. 
 
Description 
1% Claims Rate 
4% Claims Rate 
Notice Costs 
$25,674,481 
$25,674,481 
Administration Costs 
$2,282,187 
$3,852,341 
Total Estimated Costs 
$27,956,668 
$29,526,822 
 
Estimated Costs to Email Notice to all Class Members with Email Addresses and Mail 
Notice to Class Members with Mailing Addresses but no Email Addresses 
 
9. 
The estimated cost to provide notice via email to all records with unique email addresses 
and to mail notice to the approximate 277,000 Class Members with mailing addresses (but no email 
addresses) is approximately $205,000. This estimate includes processing undeliverable mailed 
notices (as described in paragraphs 6 and 7 above) based on a 10% undeliverable rate. My prior 
Declaration described this proposed Notice Plan. 
 
Description 
1% Claims Rate 
4% Claims Rate 
Notice Costs 
$205,000 
$205,000 
Mailed Notice Costs 
$2,282,187 
$3,852,341 
Total Direct Notice Costs 
$2,487,187 
$4,057,341 
 
 
Email Notice to all Class Members with Email Addresses, Mail Notice to Class Members 
with Mailing Addresses but no Email Addresses and Mail Notice to Class Members whose 
Email Notice could not be delivered 
 
 
10. 
To provide an estimate of costs for this section, Angeion calculated the following two 
scenarios: 5% of email notices could not be delivered and 10% of email notices could not be 
delivered. For purposes of the estimate and based on information Plaid currently has available, 
Angeion calculated that mailing addresses would be available for as many as approximately 83% 
of the records for which email notice could not be delivered. 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 3 of 8

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4 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
Scenario 1:  5% of Email Notices could not be delivered: 
 
Description 
1% Claims Rate 
4% Claims Rate 
Notice Costs 
$1,303,065 
$1,303,065 
Administration Costs 
$2,282,187 
$3,852,341 
Total Estimated Costs 
$3,585,252 
$5,155,406 
 
Scenario 2:  10% of Email Notices could not be delivered: 
 
Description 
1% Claims Rate 
4% Claims Rate 
Notice Costs 
$2,376,659 
$2,376,659 
Administration Costs 
$2,282,187 
$3,852,341 
Total Estimated Costs 
$4,658,846 
$6,229,000 
 
Summary of Notice Plan Options 
11. 
This Declaration has detailed the estimated notice and administrative costs associated with 
the different direct notice options discussed herein. The below chart provides a direct comparison 
between these different options and the material difference in costs for the direct notice efforts 
associated with each scenario. 
Description 
1% Claims 
Rate 
4% Claims 
Rate 
Mail to all Class Members 
$27,956,668 $29,526,822 
Email to all Class Members & Mail to 277K 
$2,487,187 
$4,057,341 
Email to all Class Members, Mail to 277K and Mail to Email Bounce-backs 
(Assumes a 5% Email undeliverable rate) 
$3,585,252 
$5,155,406 
Email to all Class Members, Mail to 277K and Mail to Email Bounce-backs 
(Assumes a 10% Email undeliverable rate) 
$4,658,846 
$6,229,000 
 
Sample Claims Rates for Email versus Mailed Notice 
12. 
In response to the Court’s September 30, 2021, Civil Law and Motion Minute Order (ECF 
No. 146), Angeion identified and analyzed claims rates for prior administrations where only mailed 
notice or only email notice was utilized as the direct form of notice. It is important to note that 
oftentimes, a hybrid approach of email then mail, or email and mail is utilized (with or without a 
media/publication component), and that such determinations are made by the Parties based on 
several factors, including but not limited to, the available class member data, the costs of providing 
notice and the type of class that being noticed, i.e., whether the class is tech-savvy and/or 
communicated with the defendant via email only or mail only. The below charts illustrate sample 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 4 of 8

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5 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
claims filing rates for previous administrations where only email or mailed notice was utilized for 
the direct notice component. 
 
Case No. 
# Class Members 
# Claims 
Claims Rate 
Notice Methods 
1 
200,273 
13,215 
6.60% 
Email 
2 
224,666 
6,601 
2.94% 
Email 
3 
161,000,000 
1,820,549 
1.13% 
Email 
4 
31,754,175 
337,049 
1.06% 
Email 
5 
1,500,000 
11,729 
0.78% 
Email 
Case No. 
# Class Members 
# Claims 
Claims Rate 
Notice Methods 
1 
643,211 
38,822 
6.04% 
Mail 
2 
28,554 
971 
3.40% 
Mail 
3 
6,931,531 
154,503 
2.23% 
Mail 
4 
249,981 
7,112 
2.85% 
Mail 
5 
2,157,574 
54,759 
2.54% 
Mail 
 
13. 
As illustrated above, the claims rates varied across the different scenarios of email notice 
and mailed notice. The above charts reflect results from a variety of different cases and different 
underlying causes of action, including different complexities of the claim form, different class 
characteristics, etc., and are not necessarily indicative or predictive of the claims rate for the instant 
Settlement based solely on the direct notice method(s).  Below is a summary of the factors Angeion 
reviewed to arrive at the estimated claims rate for this Settlement. 
FACTUAL BASIS FOR CLAIMS RATE ASSUMPTIONS 
14. 
Angeion draws on the experience it has garnered from administering similar settlements 
when approximating anticipated claims rates by evaluating a variety of factors, which are discussed 
in greater detail below. 
Litigation Subject Matter 
15. 
As a starting point, Angeion reviews the subject matter of the litigation to identify past or 
current administrations that are similar in background. Here, the Class Action Settlement 
Agreement defines the Class as:  All United States residents who own or owned one or more 
“Financial Accounts” from January 1, 2013 to the date preliminary approval of the Settlement is 
granted. “Financial Account” is defined to mean a financial institution account (1) that Plaid 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 5 of 8

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6 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
accessed using the user’s login credentials and connected to a mobile or web-based fintech 
application that enables payments (including ACH payments) or other money transfers or (2) for 
which a user provided financial account login credentials to Plaid through Plaid Link. See Kennedy 
Decl., Ex. A, ¶ 19. 
16. 
As this is a privacy matter, Angeion evaluated Settlements it has administered that dealt 
with underlying privacy concerns. Specifically, Angeion evaluated ten (10) of its recent Settlement 
administrations where the claim filing period has expired. The below chart demonstrates the claims 
rate for these 10 Settlements.  
 
Case No. 
Class Size 
# Claims 
Claims Rate 
1 
37,000,000 
4,236 
0.01% 
2 
1,500,000 
11,729 
0.78% 
3 
161,000,000 
1,820,549 
1.13% 
4 
2,157,574 
54,759 
2.54% 
5 
1,144,827 
31,052 
2.71% 
6 
17,815 
766 
4.30% 
7 
312 
17 
5.45% 
8 
1,856 
108 
5.82% 
9 
200,273 
13,215 
6.60% 
10 
3,374 
317 
9.40% 
17. 
As illustrated above, the claims rate ranged from 0.01% to 9.40%, with an average claims 
rate of 3.87% and a median claims rate of 3.51%. 
Size of the Class 
18. 
Class Counsel has estimated that the Settlement Class reflected in the Settlement Agreement 
includes approximately 98 million individuals. See Kennedy Decl., ¶ 24. Given the voluminous 
size of the Class, Angeion evaluated several administrations5 where their respective class sizes 
were in the tens of millions. The chart below demonstrates the claims rate for those matters. 
 
 
 
5 Angeion did not evaluate consumer marketing/mislabeling cases in this evaluation. Although those matters often 
involve tens of millions of class members, the actual class size is often unknown, making a claims rate difficult to 
determine.  
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7 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
19. 
As illustrated above, the claims rate ranged from 0.01% to 2.53%, with an average claims 
rate of 1.41% and a median claims rate of 2.31%. 
The Proposed Notice Plan 
20. 
The proposed Notice Plan described in greater detail in my prior Declaration is extremely 
comprehensive, combining direct notice with a state-of-the-art media campaign designed to reach 
80.40% of the Target Audience (independent from the direct notice) and utilizing modern day 
notice techniques such as search engine marketing and sponsored listings on leading class action 
settlement websites.  
21. 
While Notice Plans are specifically tailored for each settlement, there are several 
administrations that utilized comparable noticing efforts which Angeion was able to evaluate and 
are most relevant to instant Settlement. The notice plan descriptions and claims rates for those 
administrations are detailed below. 
Case No. 
Class Size 
# Claims 
Claims Rate 
Noticing Efforts 
1 
41,456,000* 
100,787 
0.24% 
Mail, Email, Media, Publication 
2 
39,340,000* 
289,727 
0.74% 
Media, Publication, Press Release, Sponsored 
Listings 
3 
2,229,825 
50,331 
2.26% 
Mail, Email, Sponsored Listings, Social 
Media, Press Release 
4 
2,998,000* 
167,405 
5.58% 
Media, Publication, Sponsored Listings 
5 
5,077,000* 
332,818 
6.56% 
Media, Publication, Sponsored Listings, Press 
Release, Social Media 
6 
1,550,000 
108,412 
6.99% 
Mail, Email, Media, Publication, SEM, 
Sponsored Listings, Industry-Specific Notice 
Efforts 
*Indicates that an exact class size was unknown and that a proxy target audience was used to 
identify the number of potential Class Members. 
 
Case No. 
Class Size 
# Claims 
Claims Rate 
1 
161,000,000 
1,820,549 
1.13% 
2 
129,836,502 
3,284,985 
2.53% 
3 
37,000,000 
4,236 
0.01% 
4 
31,754,175 
337,049 
1.06% 
5 
11,391,016 
263,261 
2.31% 
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8 
SUPPLEMENTAL DECLARATION OF STEVEN WEISBROT  
 
 
 
22. 
As illustrated in the above chart, the sampling of administrations with comparable notice 
efforts resulted in an approximate claims rate that ranged from 0.24% to 6.99%, with an average 
claims rate of 3.73% and a median claims rate of 3.92%. 
Potential Relief Available to Class Members 
23. 
  Claims rates always have the ability to deviate from estimates for a variety of reasons (i.e., 
unanticipated earned media garnered due to the nature of the Settlement, including whether news 
organizations/sites mention the Settlement; the individual class member reaction to the underlying 
cause of action and allegations, etc.) that are not easily predictable. However, based on the totality 
of the above analyses and its overall experience in administering class action settlements, Angeion 
estimates that the anticipated claims rate in this Settlement will likely fall in the range of 1% - 4%. 
 
I hereby declare under penalty of perjury under the laws of the United States that the 
foregoing is true and correct. 
Dated: October 7, 2021 
 
 
 
 
 
 
 
 
____________________ 
 
 
 
 
 
 
 
 
STEVEN WEISBROT  
 
Case 4:20-cv-03056-DMR   Document 149   Filed 10/07/21   Page 8 of 8

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