Exhibit B — Plaid Privacy (Dkt. 138.2)

Summary

Exhibit B, Document 138-2, filed 08/06/21 in No. 4:20-cv-03056-DMR in the U.S. District Court for the Northern District of California. It is a three-page chart headed Selected Relevant Settlements and Distributions (Reverse Chronological), with columns for the nature of claims, class size and notice, class recovery and relief, and fees, costs and cy pres distributions. The rows cover Campbell, et al. v. Facebook, Matera et al. v. Google LLC, Ebarle et al. v. LifeLock Inc. and Perkins, et al. v. LinkedIn Corp., all in the Northern District of California. Entries include a $68 million settlement fund in Ebarle and a $13 million settlement fund in Perkins.

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EXHIBIT B 
Case 4:20-cv-03056-DMR   Document 138-2   Filed 08/06/21   Page 1 of 3

Selected Relevant Settlements and Distributions (Reverse Chronological)  
 
1
Case 
Nature of Claims / 
Alleged Conduct 
Class size and 
method(s) of notice 
Class recovery  
and relief 
Fees, costs, and cy 
pres distributions 
Campbell, et al. v. 
Facebook, 13-cv-
05996-PJH (N.D. 
Cal.) 
 
Final approval granted 
August 18, 2017;  
 
Affirmed on appeal 
via Case No. No. 17-
16873 (9th Cir.) 
March 3, 2020. 
Invasion of privacy 
and unlawful use 
personal data. 
Class size:  190 million  
 
Notice: Published on Class 
Counsel’s public websites. 
The settlement provided for 
confirmation of changes to 
Facebook’s business practices and 
implementation of changes to 
Facebook’s disclosures and Help 
Center materials regarding its 
scanning practices resulting in 
benefit to the certified litigation 
class of Facebook users who 
alleged that Facebook violated the 
Wiretap Act, and other laws, by 
intercepting the contents of 
messages that were sent over a 
Facebook messaging service. 
 
$3,236,304.69 
attorneys’ fees;  
$653,695.31 for 
reimbursement of 
expenses.  
 
Matera et al. v. 
Google LLC, No. 
5:15-cv-04062 (N.D. 
Cal.) 
 
Final approval granted 
February 9, 2018. 
Data privacy. 
Class size: 10 million 
 
Notice: Publication  
Three-year injunction barring 
Google from processing email 
content from non-Gmail users for 
advertising purposes. 
$2.2 million 
attorneys’ fees;  
$51,421.93 for 
expenses; and 
administrative costs 
of $123,500. 
Ebarle et al. v. 
LifeLock Inc., No. 
3:15-cv-00258 (N.D. 
Cal.) 
 
Final approval granted 
September 20, 2016.  
Data breach and 
failure to protect 
subscribers’ personal 
information. 
Class size:  Nationwide.  
Class was estimated 6.8 
million.  
 
A subclass based on time 
period was estimated to 3.4 
million. 
 
$68 million settlement fund. 
 
Approximately $20 for Settlement 
Class Members who make claims. 
$16 for Settlement Subclass 
Members who do not make claims, 
and $36 for Settlement Subclass 
Members who make claims pro 
rata.  
$10.2 million 
attorneys’ fees. 
$2,000 service award 
for each named 
plaintiff. 
$2.6 million in 
settlement notice and 
administrative costs. 
  
Case 4:20-cv-03056-DMR   Document 138-2   Filed 08/06/21   Page 2 of 3

Selected Relevant Settlements and Distributions (Reverse Chronological)  
 
2
Case 
Nature of Claims / 
Alleged Conduct 
Class size and 
method(s) of notice 
Class recovery  
and relief 
Fees, costs, and cy 
pres distributions 
Notice: Direct, individual 
notice via email or mail 
(utilizing Defendant’s internal 
records); Settlement website;  
publication in a 1/8th page 
advertisement in USA Today 
 
Defendant made changes to its  
advertisements and practices, 
consisting of technical 
improvements, and providing alerts 
during unplanned system outages. 
 
Over the course of 
two distribution 
rounds, class 
members received 
monetary relief 
totaling 
approximately the 
amount each paid for 
one month of 
enrollment in 
Defendant’s services. 
 
Perkins, et al. v. 
LinkedIn Corp., No. 
13-cv-04303 (N.D. 
Cal.) 
 
Final approval granted 
February 16, 2016. 
 
Unauthorized use of 
consumer names and 
likeness in spam / 
unsolicited 
advertisements. 
Class size:  20.8 million class 
members 
 
Notice: E-mail notice 
program and a dedicated 
settlement website. 
$13 million settlement fund. 
 
Changes to LinkedIn’s business 
practices to improve user control 
over invitation e-mails and changes 
to LinkedIn’s disclosures.  
 
Class members’ submission of 
441,161 valid claims resulted in 
pro rata compensation of $20.43 
payments to each claiming class 
member. 
$3.25 million 
attorneys’ fees and 
expenses;  
$716,750 
administrative costs;   
$1,041,996 in funds 
from uncashed checks 
distributed in equal 
parts to Access Now, 
Electronic Privacy 
Information Center, 
and Network for 
Teaching 
Entrepreneurship as 
cy pres recipients. 
 
Case 4:20-cv-03056-DMR   Document 138-2   Filed 08/06/21   Page 3 of 3

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