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Home Court filings Plaid Privacy In re Plaid Inc. Privacy Litigation — N.D. Cal., No. 4:20-cv-03056-DMR Exhibit A — In re Plaid Inc. Privacy Litigation (Dkt. 139-1, N.D. Cal. No. 4:20-cv-03056)

Court filing

Exhibit A — In re Plaid Inc. Privacy Litigation (Dkt. 139-1, N.D. Cal. No. 4:20-cv-03056)

Filed August 6, 2021 in In re Plaid Inc. Privacy Litigation; one of 174 filings from this case.

Record facts

CourtU.S. District Court for the Northern District of California
Filed2021-08-06

U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 139-1 · 2021-08-06 · Docket on CourtListener

Full text

Exhibit A 
Case 4:20-cv-03056-DMR     Document 139-1     Filed 08/06/21     Page 1 of 15

 
 
Judicial Recognition 
©  Angeion Group, LLC    
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IN RE: APPLE INC. DEVICE PERFORMANCE LITIGATION 
Case No. 5:18-md-02827 
The Honorable Edward J. Davila, United States District Court, Northern District of California (March 
17, 2021):  Angeion undertook a comprehensive notice campaign…The notice program was well 
executed, far-reaching, and exceeded both Federal Rule of Civil Procedure 23(c)(2)(B)’s 
requirement to provide the “best notice that is practicable under the circumstances” and Rule 
23(e)(1)(B)’s requirement to provide “direct notice in a reasonable manner.” 
 
IN RE: GOOGLE PLUS PROFILE LITIGATION 
Case No. 5:18-cv-06164 
The Honorable Edward J. Davila, United States District Court, Northern District of California 
(January 25, 2021):  The Court further finds that the program for disseminating notice to 
Settlement Class Members provided for in the Settlement, and previously approved and directed 
by the Court (hereinafter, the “Notice Program”), has been implemented by the Settlement 
Administrator and the Parties, and such Notice Program, including the approved forms of notice, 
is reasonable and appropriate and satisfies all applicable due process and other requirements, 
and constitutes best notice reasonably calculated under the circumstances to apprise Settlement 
Class Members… 
 
NELSON ET AL. v. IDAHO CENTRAL CREDIT UNION 
Case No. CV03-20-00831, CV03-20-03221 
The Honorable Robert C. Naftz, Sixth Judicial District, State of Idaho, Bannock County (January 19, 
2021):  The Court finds that the Proposed Notice here is tailored to this Class and designed to 
ensure broad and effective reach to it…The Parties represent that the operative notice plan is the 
best notice practicable and is reasonably designed to reach the settlement class members. The 
Court agrees. 
 
IN RE: HANNA ANDERSSON AND SALESFORCE.COM DATA BREACH LITIGATION 
Case No. 3:20-cv-00812 
The Honorable Edward M. Chen, United States District Court, Northern District of California 
(December 29, 2020):  The Court finds that the Class Notice and Notice Program satisfy the 
requirements of due process and Rule 23 of the Federal Rules of Civil Procedure and provide the 
best notice practicable under the circumstances. 
 
IN RE: PEANUT FARMERS ANTITRUST LITIGATION 
Case No. 2:19-cv-00463 
The Honorable Raymond A. Jackson, United States District Court, Eastern District of Virginia 
(December 23, 2020):  The Court finds that the Notice Program…constitutes the best notice that 
is practicable under the circumstances and is valid, due and sufficient notice to all persons entitled 
thereto and complies fully with the requirements of Rule 23(c)(2) and the due process 
requirements of the Constitution of the United States. 
 
 
 
 
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BENTLEY ET AL. v. LG ELECTRONICS U.S.A., INC. 
Case No. 2:19-cv-13554 
The Honorable Madeline Cox Arleo, United States District Court, District of New Jersey (December 
18, 2020):  The Court finds that notice of this Settlement was given to Settlement Class Members 
in accordance with the Preliminary Approval Order and constituted the best notice practicable of 
the proceedings and matters set forth therein, including the Litigation, the Settlement, and the 
Settlement Class Members’ rights to object to the Settlement or opt out of the Settlement Class, 
to all Persons entitled to such notice, and that this notice satisfied the requirements of Federal 
Rule of Civil Procedure 23 and of due process. 
 
IN RE: ALLURA FIBER CEMENT SIDING PRODUCTS LIABILITY LITIGATION 
Case No. 2:19-mn-02886 
The Honorable David C. Norton, United States District Court, District of South Carolina (December 
18, 2020):  The proposed Notice provides the best notice practicable under the circumstances. It 
allows Settlement Class Members a full and fair opportunity to consider the proposed settlement. 
The proposed plan for distributing the Notice likewise is a reasonable method calculated to reach 
all members of the Settlement Class who would be bound by the settlement. There is no additional 
method of distribution that would be reasonably likely to notify Settlement Class Members who 
may not receive notice pursuant to the proposed distribution plan.  
 
ADKINS ET AL. v. FACEBOOK, INC. 
Case No. 3:18-cv-05982 
The Honorable William Alsup, United States District Court, Northern District of California 
(November 15, 2020):  Notice to the class is “reasonably calculated, under all the circumstances, 
to apprise interested parties of the pendency of the action and afford them an opportunity to 
present their objections.” Mullane v. Central Hanover Bank & Tr. Co., 399 U.S. 306, 314 (1650). 
 
IN RE: 21ST CENTURY ONCOLOGY CUSTOMER DATA SECURITY BREACH LITIGATION 
Case No. 8:16-md-02737 
The Honorable Mary S. Scriven, United States District Court, Middle District of Florida (November 
2, 2020):  The Court finds and determines that mailing the Summary Notice  and publication of  
the  Settlement  Agreement,  Long  Form  Notice, Summary Notice, and Claim Form on the 
Settlement Website, all pursuant to this Order, constitute the best notice practicable under the 
circumstances, constitute due and sufficient notice of the matters set forth in the notices to all 
persons entitled to receive such notices, and fully satisfies the of due process, Rule 23 of the 
Federal Rules of Civil Procedure, 28 U.S.C. § 1715, and all other applicable laws and rules. The 
Court further finds that all of the notices are written in plain language and are readily 
understandable by Class Members. 
 
MARINO ET AL. v. COACH INC. 
Case No. 1:16-cv-01122 
The Honorable Valerie Caproni, United States District Court, Southern District of New York (August 
24, 2020):  The Court finds that the form, content, and method of giving notice to the Settlement 
Class as described in paragraph 8 of this Order: (a) will constitute the best practicable notice; (b) 
are reasonably calculated, under the circumstances, to apprise the Settlement Class Members of 
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the pendency of the Action, the terms of the proposed Settlement, and their rights under the 
proposed Settlement, including but not limited to their rights to object to or exclude themselves 
from the proposed Settlement and other rights under the terms of the Settlement Agreement; (c) 
are reasonable and constitute due, adequate, and sufficient notice to all Settlement Class 
Members and other persons entitled to receive notice; and (d) meet all applicable requirements 
of law, including but not limited to 28 U.S.C. § 1715, Rule 23(c) and (e), and the Due Process 
Clause(s) of the United States Constitution.  The Court further finds that all of the notices are 
written in plain language, are readily understandable by Settlement Class Members, and are 
materially consistent with the Federal Judicial Center’s illustrative class action notices. 
 
BROWN v. DIRECTV, LLC 
Case No. 2:13-cv-01170 
The Honorable Dolly M. Gee, United States District Court, Central District of California (July 23, 
2020):  Given the nature and size of the class, the fact that the class has no geographical 
limitations, and the sheer number of calls at issue, the Court determines that these methods 
constitute the best and most reasonable form of notice under the circumstances. 
 
IN RE: SSA BONDS ANTITRUST LITIGATION 
Case No. 1:16-cv-03711 
The Honorable Edgardo Ramos, United States District Court, Southern District of New York (July 
15, 2020):  The Court finds that the mailing and distribution of the Notice and the publication of 
the Summary Notice substantially in the manner set forth below meet the requirements of Rule 
23 of the Federal Rules of Civil Procedure and due process and constitute the best notice 
practicable under the circumstances, and shall constitute due and sufficient notice to all Persons 
entitled to notice. 
 
KJESSLER ET AL. v. ZAAPPAAZ, INC. ET AL. 
Case No. 4:18-cv-00430 
The Honorable Nancy F. Atlas, United States District Court, Southern District of Texas (July 14, 
2020):  The Court also preliminarily approves the proposed manner of communicating the Notice 
and Summary Notice to the putative Settlement Class, as set out below, and finds it is the best 
notice practicable under the circumstances, constitutes due and sufficient notice to all persons 
and entities entitled to receive such notice, and fully satisfies the requirements of applicable laws, 
including due process and Federal Rule of Civil Procedure 23. 
 
HESTER ET AL. v. WALMART, INC. 
Case No. 5:18-cv-05225 
The Honorable Timothy L. Brooks, United States District Court, Western District of Arkansas (July 
9, 2020):  The Court finds that the Notice and Notice Plan substantially in the manner and form 
set forth in this Order and the Agreement meet the requirements of Federal Rule of Civil Procedure 
23 and due process, is the best notice practicable under the circumstances, and shall constitute 
due and sufficient notice to all Persons entitled thereto. 
 
 
 
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CLAY ET AL. v. CYTOSPORT INC. 
Case No. 3:15-cv-00165 
The Honorable M. James Lorenz, United States District Court, Southern District of California (June 
17, 2020):  The Court approves the proposed Notice Plan for giving notice to the Settlement Class 
through publication, both print and digital, and through the establishment of a Settlement 
Website, as more fully described in the Agreement and the Claims Administrator’s affidavits (docs. 
no. 222-9, 224, 224-1, and 232-3 through 232-6). The Notice Plan, in form, method, and content, 
complies with the requirements of Rule 23 and due process, and constitutes the best notice 
practicable under the circumstances. 
 
GROGAN v. AARON’S INC. 
Case No. 1:18-cv-02821 
The Honorable J.P. Boulee, United States District Court, Northern District of Georgia (May 1, 2020):  
The Court finds that the Notice Plan as set forth in the Settlement Agreement meets the 
requirements of Fed. R. Civ. P. 23 and constitutes the best notice practicable under the 
circumstances, including direct individual notice by mail and email to Settlement Class Members 
where feasible and a nationwide publication website-based notice program, as well as establishing 
a Settlement Website at the web address of www.AaronsTCPASettlement.com, and satisfies fully 
the requirements the Federal Rules of Civil Procedure, the U.S. Constitution, and any other 
applicable law, such that the Settlement Agreement and Final Order and Judgment will be binding 
on all Settlement Class Members. 
 
CUMMINGS v. BOARD OF REGENTS OF THE UNIVERSITY OF NEW MEXICO, ET AL. 
Case No. D-202-CV-2001-00579 
The Honorable Carl Butkus, Second Judicial District Court, County of Bernalillo, State of New 
Mexico (March 30, 2020): The Court has reviewed the Class Notice, the Plan of Allocation and 
Distribution and Claim Form, each of which it approves in form and substance. The Court finds 
that the form and methods of notice set forth in the Agreement: (i) are reasonable and the best 
practicable notice under the circumstances; (ii) are reasonably calculated to apprise Settlement 
Class Members of the pendency of the Lawsuit, of their rights to object to or opt-out of the 
Settlement, and of the Final Approval Hearing; (iii) constitute due, adequate, and sufficient notice 
to all persons entitled to receive notice; and (iv) meet the requirements of the New Mexico Rules 
of Civil Procedure, the requirements of due process under the New Mexico and United States 
Constitutions, and the requirements of any other applicable rules or laws. 
 
SCHNEIDER, ET AL. v. CHIPOTLE MEXICAN GRILL, INC. 
Case No. 4:16-cv-02200 
The Honorable Haywood S. Gilliam, Jr., United States District Court, Northern District of California 
(January 31, 2020):  Given that direct notice appears to be infeasible, the third-party settlement 
administrator will implement a digital media campaign and provide for publication notice in 
People magazine, a nationwide publication, and the East Bay Times. SA § IV.A, C; Dkt. No. 205-12 
at ¶¶ 13–23. The publication notices will run for four consecutive weeks. Dkt. No. 205 at ¶ 23. The 
digital media campaign includes an internet banner notice implemented using a 60-day desktop 
and mobile campaign. Dkt. No. 205-12 at ¶ 18. It will rely on “Programmatic Display Advertising” 
to reach the “Target Audience,” Dkt. No. 216-1 at ¶ 6, which is estimated to include 30,100,000 
people and identified using the target definition of “Fast Food & Drive-In Restaurants Total 
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Restaurants Last 6 Months [Chipotle Mexican Grill],” Dkt. No. 205-12 at ¶ 13. Programmatic display 
advertising utilizes “search targeting,” “category contextual targeting,” “keyword contextual 
targeting,” and “site targeting,” to place ads. Dkt. No. 216-1 at ¶¶ 9–12. And through “learning” 
technology, it continues placing ads on websites where the ad is performing well. Id. ¶ 7. Put 
simply, prospective Class Members will see a banner ad notifying them of the settlement when 
they search for terms or websites that are similar to or related to Chipotle, when they browse 
websites that are categorically relevant to Chipotle (for example, a website related to fast casual 
dining or Mexican food), and when they browse websites that include a relevant keyword (for 
example, a fitness website with ads comparing fast casual choices). Id. ¶¶ 9–12. By using this 
technology, the banner notice is “designed to result in serving approximately 59,598,000 
impressions.” Dkt. No. 205-12 at ¶ 18. 
 
The Court finds that the proposed notice process is “‘reasonably calculated, under all the 
circumstances,’ to apprise all class members of the proposed settlement.” Roes, 944 F.3d at 1045 
(citation omitted). 
 
HANLEY v. TAMPA BAY SPORTS AND ENTERTAINMENT LLC 
Case No. 8:19-cv-00550 
The Honorable Charlene Edwards Honeywell, United States District Court, Middle District of 
Florida (January 7, 2020):  The Court approves the form and content of the Class notices and claim 
forms substantially in the forms attached as Exhibits A-D to the Settlement. The Court further finds 
that the Class Notice program described in the Settlement is the best practicable under the 
circumstances. The Class Notice program is reasonably calculated under the circumstances to 
inform the Settlement Class of the pendency of the Action, certification of a Settlement Class, the 
terms of the Settlement, Class Counsel’s attorney’s fees application and the request for a service 
award for Plaintiff, and their rights to opt-out of the Settlement Class or object to the Settlement. 
The Class notices and Class Notice program constitute sufficient notice to all persons entitled to 
notice. The Class notices and Class Notice program satisfy all applicable requirements of law, 
including, but not limited to, Federal Rule of Civil Procedure 23 and the Constitutional requirement 
of Due Process. 
 
CORCORAN, ET AL. v. CVS HEALTH, ET AL. 
Case No. 4:15-cv-03504 
The Honorable Yvonne Gonzalez Rogers, United States District Court, Northern District of 
California (November 22, 2019):  Having reviewed the parties’ briefings, plaintiffs’ declarations 
regarding the selection process for a notice provider in this matter and regarding Angeion Group 
LLC’s experience and qualifications, and in light of defendants’ non-opposition, the Court 
APPROVES Angeion Group LLC as the notice provider. Thus, the Court GRANTS the motion for 
approval of class notice provider and class notice program on this basis. 
 
Having considered the parties’ revised proposed notice program, the Court agrees that the 
parties’ proposed notice program is the “best notice that is practicable under the circumstances.” 
The Court is satisfied with the representations made regarding Angeion Group LLC’s methods for 
ascertaining email addresses from existing information in the possession of defendants. Rule 23 
further contemplates and permits electronic notice to class members in certain situations. See 
Fed. R. Civ. P. 23(c)(2)(B). The Court finds, in light of the representations made by the parties, that 
this is a situation that permits electronic notification via email, in addition to notice via United 
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States Postal Service. Thus, the Court APPROVES the parties’ revised proposed class notice 
program, and GRANTS the motion for approval of class notice provider and class notice program 
as to notification via email and United States Postal Service mail. 
 
PATORA v. TARTE, INC. 
Case No. 7:18-cv-11760 
The Honorable Kenneth M. Karas, United States District Court, Southern District of New York 
(October 2, 2019):  The Court finds that the form, content, and method of giving notice to the 
Class as described in Paragraph 9 of this Order: (a) will constitute the best practicable notice; (b) 
are reasonably calculated, under the circumstances, to apprise the Settlement Class Members of 
the pendency of the Action, the terms of the Proposed Settlement, and their rights under the 
Proposed Settlement, including but not limited to their rights to object to or exclude themselves 
from the Proposed Settlement and other rights under the terms of the Settlement Agreement; (c) 
are reasonable and constitute due, adequate, and sufficient notice to all Settlement Class 
Members and other persons entitled to receive notice; and (d) meet all applicable requirements 
of law, including but not limited to 28 U.S.C. § 1715, Rule 23(c) and (e), and the Due Process 
Clauses of the United States Constitution. The Court further finds that all of the notices are written 
in simple terminology, are readily understandable by Settlement Class Members, and are 
materially consistent with the Federal Judicial Center's illustrative class action notices. 
 
CARTER, ET AL. v. GENERAL NUTRITION CENTERS, INC., and GNC HOLDINGS, INC. 
Case No. 2:16-cv-00633 
The Honorable Mark R. Hornak, United States District Court, Western District of Pennsylvania 
(September 9, 2019):  The Court finds that the Class Notice and the manner of its dissemination 
described in Paragraph 7 above and Section VII of the Agreement constitutes the best practicable 
notice under the circumstances and is reasonably calculated, under all the circumstances, to 
apprise proposed Settlement Class Members of the pendency of this action, the terms of the 
Agreement, and their right to object to or exclude themselves from the proposed Settlement 
Class. The Court finds that the notice is reasonable, that it constitutes due, adequate and sufficient 
notice to all persons entitled to receive notice, and that it meets the requirements of due process, 
Rule 23 of the Federal Rules of Ci vii Procedure, and any other applicable laws. 
 
CORZINE v. MAYTAG CORPORATION, ET AL. 
Case No. 5:15-cv-05764 
The Honorable Beth L. Freeman, United States District Court, Northern District of California 
(August 21, 2019):  The Court, having reviewed the proposed Summary Notice, the proposed FAQ, 
the proposed Publication Notice, the proposed Claim Form, and the proposed plan for distributing 
and disseminating each of them, finds and concludes that the proposed plan will provide the best 
notice practicable under the circumstances and satisfies all requirements of federal and state laws 
and due process. 
 
MEDNICK v. PRECOR, INC. 
Case No. 1:14-cv-03624 
The Honorable Harry D. Leinenweber, United States District Court, Northern District of Illinois 
(June 12, 2019):  Notice provided to Class Members pursuant to the Preliminary Class Settlement 
Approval Order constitutes the best notice practicable under the circumstances, including 
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individual email and mail notice to all Class Members who could be identified through reasonable 
effort, including information provided by authorized third-party retailers of Precor. Said notice 
provided full and adequate notice of these proceedings and of the matter set forth therein, 
including the proposed Settlement set forth in the Agreement, to all persons entitled to such 
notice, and said notice fully satisfied the requirements of F.R.C.P. Rule 23 (e) and (h) and the 
requirements of due process under the United States and California Constitutions. 
 
GONZALEZ v. TCR SPORTS BROADCASTING HOLDING LLP, ET AL. 
Case No. 1:18-cv-20048 
The Honorable Darrin P. Gayles, United States District Court, Southern District of Florida (May 24, 
2019):  The Court finds that notice to the class was reasonable and the best notice practicable 
under the circumstances, consistent with Rule 23(e)(1) and Rule 23(c)(2)(B). 
 
ANDREWS ET AL. v. THE GAP, INC., ET AL. 
Case No. CGC-18-567237 
The Honorable Richard B. Ulmer Jr., Superior Court of the State of California, County of San 
Francisco (May 10, 2019):  The Court finds that (a) the Full Notice, Email Notice, and Publication 
constitute the best notice practicable under the circumstances, (b) they constitute valid, due, and 
sufficient notice to all members of the Class, and (c) they comply fully with the requirements of 
California Code of Civil Procedure section 382, California Rules of Court 3.766 and 3.769, the 
California and United States Constitutions, and other applicable law. 
 
COLE, ET AL. v. NIBCO, INC. 
Case No. 3:13-cv-07871 
The Honorable Freda L. Wolfson, United States District Court, District of New Jersey (April 11, 
2019):  The record shows, and the Court finds, that the Notice Plan has been implemented in the 
manner approved by the Court in its Preliminary Approval Order. The Court finds that the Notice 
Plan constitutes: (i) the best notice practicable to the Settlement Class under the circumstances; 
(ii) was reasonably calculated, under the circumstances, to apprise the Settlement Class of the 
pendency of this…, (iii) due, adequate, and sufficient notice to all Persons entitled to receive notice; 
and (iv) notice that fully satisfies the requirements of the United States Constitution (including the 
Due Process Clause), Fed. R. Civ. P. 23, and any other applicable law. 
 
DIFRANCESCO, ET AL. v. UTZ QUALITY FOODS, INC. 
Case No. 1:14-cv-14744 
The Honorable Douglas P. Woodlock, United States District Court, District of Massachusetts 
(March 15, 2019):  The Court finds that the Notice plan and all forms of Notice to the Class as set 
forth in the Settlement Agreement and Exhibits 2 and 6 thereto, as amended (the "Notice 
Program"), is reasonably calculated to, under all circumstances, apprise the members of the 
Settlement Class of the pendency of this action, the certification of the Settlement Class, the terms 
of the Settlement Agreement, and the right of members to object to the settlement or to exclude 
themselves from the Class. The Notice Program is consistent with the requirements of Rule 23 and 
due process, and constitutes the best notice practicable under the circumstances. 
 
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IN RE: CHRYSLER-DODGE-JEEP ECODIESEL MARKETING, SALES PRACTICES, AND PRODUCTS 
LIABILITY LITIGATION 
Case No. 3:17-md-02777 
The Honorable Edward M. Chen, United States District Court, Northern District of California 
(February 11, 2019):  Also, the parties went through a sufficiently rigorous selection process to 
select a settlement administrator. See Proc. Guidance for Class Action Sett. ¶ 2; see also Cabraser 
Decl. ¶¶ 9-10. While the settlement administration costs are significant – an estimated $1.5 million 
– they are adequately justified given the size of the class and the relief being provided.  
 
In addition, the Court finds that the language of the class notices (short and long-form) is 
appropriate and that the means of notice – which includes mail notice, electronic notice, 
publication notice, and social media “marketing” – is the “best notice…practicable under the 
circumstances.” Fed. R. Civ. P. 23(c)(2)(B); see also Proc. Guidance for Class Action Sett. ¶¶ 3-5, 9 
(addressing class notice, opt-outs, and objections). The Court notes that the means of notice has 
changed somewhat, as explained in the Supplemental Weisbrot Declaration filed on February 8, 
2019, so that notice will be more targeted and effective. See generally Docket No. 525 (Supp. 
Weisbrot Decl.) (addressing, inter alia, press release to be distributed via national newswire service, 
digital and social media marketing designed to enhance notice, and “reminder” first-class mail 
notice when AEM becomes available).  
 
Finally, the parties have noted that the proposed settlement bears similarity to the settlement in 
the Volkswagen MDL. See Proc. Guidance for Class Action Sett. ¶ 11. 
 
RYSEWYK, ET AL. v. SEARS HOLDINGS CORPORATION and SEARS, ROEBUCK AND 
COMPANY  
Case No. 1:15-cv-04519 
The Honorable Manish S. Shah, United States District Court, Northern District of Illinois (January 
29, 2019):  The Court holds that the Notice and notice plan as carried out satisfy the requirements 
of Rule 23(e) and due process. This Court has previously held the Notice and notice plan to be 
reasonable and the best practicable under the circumstances in its Preliminary Approval Order 
dated August 6, 2018. (Dkt. 191) Based on the declaration of Steven Weisbrot, Esq. of Angeion 
Group (Dkt. No. 209-2), which sets forth compliance with the Notice Plan and related matters, the 
Court finds that the multi-pronged notice strategy as implemented has successfully reached the 
putative Settlement Class, thus constituting the best practicable notice and satisfying due process. 
 
MAYHEW, ET AL. v. KAS DIRECT, LLC, and S.C. JOHNSON & SON, INC. 
Case No. 7:16-cv-06981 
The Honorable Vincent J. Briccetti, United States District Court, Southern District of New York (June 
26, 2018):  In connection with their motion, plaintiffs provide the declaration of Steven Weisbrot, 
Esq., a principal at the firm Angeion Group, LLC, which will serve as the notice and settlement 
administrator in this case. (Doc. #101, Ex. F: Weisbrot Decl.) According to Mr. Weisbrot, he has 
been responsible for the design and implementation of hundreds of class action administration 
plans, has taught courses on class action claims administration, and has given testimony to the 
Judicial Conference Committee on Rules of Practice and Procedure on the role of direct mail, 
email, and digital media in due process notice. Mr. Weisbrot states that the internet banner 
advertisement campaign will be responsive to search terms relevant to “baby wipes, baby 
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products, baby care products, detergents, sanitizers, baby lotion, [and] diapers,” and will target 
users who are currently browsing or recently browsed categories “such as parenting, toddlers, 
baby care, [and] organic products.” (Weisbrot Decl. ¶ 18). According to Mr. Weisbrot, the internet 
banner advertising campaign will reach seventy percent of the proposed class members at least 
three times each. (Id. ¶ 9). Accordingly, the Court approves of the manner of notice proposed by 
the parties as it is reasonable and the best practicable option for confirming the class members 
receive notice. 
 
IN RE: OUTER BANKS POWER OUTAGE LITIGATION 
Case No. 4:17-cv-00141 
The Honorable James C. Dever III, United States District Court, Eastern District of North Carolina 
(May 2, 2018):  The court has reviewed the proposed notice plan and finds that the notice plan 
provides the best practicable notice under the circumstances and, when completed, shall 
constitute fair, reasonable, and adequate notice of the settlement to all persons and entities 
affected by or entitled to participate in the settlement, in full compliance with the notice 
requirements of Fed. R. Civ. P. 23(c)(2)(B) and due process. Thus, the court approves the proposed 
notice plan. 
 
GOLDEMBERG, ET AL. v. JOHNSON & JOHNSON CONSUMER COMPANIES, INC. 
Case No. 7:13-cv-03073 
The Honorable Nelson S. Roman, United States District Court, Southern District of New York 
(November 1, 2017):  Notice of the pendency of the Action as a class action and of the proposed 
Settlement, as set forth in the Settlement Notices, was given to all Class Members who could be 
identified with reasonable effort, consistent with the terms of the Preliminary Approval Order. The 
form and method of notifying the Class of the pendency of the Action as a class action and of the 
terms and conditions of the proposed Settlement met the requirements of Rule 23 of the Federal 
Rules of Civil Procedure, due process, and any other applicable law in the United States. Such 
notice constituted the best notice practicable under the circumstances, and constituted due and 
sufficient notice to all persons and entities entitled thereto. 
 
HALVORSON v. TALENTBIN, INC. 
Case No. 3:15-cv-05166 
The Honorable Joseph C. Spero, United States District Court, Northern District of California (July 
25, 2017):  The Court finds that the Notice provided for in the Order of Preliminary Approval of 
Settlement has been provided to the Settlement Class, and the Notice provided to the Settlement    
Class constituted the best notice practicable under the circumstances, and was in full compliance 
with the notice requirements of Rule 23 of the Federal Rules of Civil Procedure, due process, the 
United States Constitution, and any other applicable law. The Notice apprised the members of the 
Settlement Class of the pendency of the litigation; of all material elements of the proposed 
settlement, including but not limited to the relief afforded the Settlement Class under the 
Settlement Agreement; of the res judicata effect on members of the Settlement Class and of their 
opportunity to object to, comment on, or opt-out of, the Settlement; of the identity of Settlement 
Class Counsel and of information necessary to contact Settlement Class Counsel; and of the right 
to appear at the Fairness Hearing. Full opportunity has been afforded to members of the 
Settlement Class to participate in the Fairness Hearing. Accordingly, the Court determines that all 
Final Settlement Class Members are bound by this Final Judgment in accordance with the terms 
provided herein. 
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IN RE: ASHLEY MADISON CUSTOMER DATA SECURITY BREACH LITIGATION 
MDL No. 2669/Case No. 4:15-md-02669 
The Honorable John A. Ross, United States District Court, Eastern District of Missouri (July 21, 
2017):  The Court further finds that the method of disseminating Notice, as set forth in the Motion, 
the Declaration of Steven Weisbrot, Esq. on Adequacy of Notice Program, dated July 13, 2017, 
and the Parties’ Stipulation—including an extensive and targeted publication campaign 
composed of both consumer magazine publications in People and Sports Illustrated, as well as 
serving 11,484,000 highly targeted digital banner ads to reach the prospective class members that 
will deliver approximately 75.3% reach with an average frequency of 3.04 —is the best method of 
notice practicable under the circumstances and satisfies all requirements provided in Rule 
23(c)(2)(B) and all Constitutional requirements including those of due process. 
 
The Court further finds that the Notice fully satisfies Rule 23 of the Federal Rules of Civil Procedure 
and the requirements of due process; provided, that the Parties, by agreement, may revise the 
Notice, the Claim Form, and other exhibits to the Stipulation, in ways that are not material or ways 
that are appropriate to update those documents for purposes of accuracy. 
 
TRAXLER, ET AL. v. PPG INDUSTRIES INC., ET AL. 
Case No. 1:15-cv-00912 
The Honorable Dan Aaron Polster, United States District Court, Northern District of Ohio (April 27, 
2017):  The Court hereby approves the form and procedure for disseminating notice of the 
proposed settlement to the Settlement Class as set forth in the Agreement. The Court finds that 
the proposed Notice Plan contemplated constitutes the best notice practicable under the 
circumstances and is reasonably calculated, under the circumstances, to apprise Settlement Class 
Members of the pendency of the Action and their right to object to the proposed settlement or 
opt out of the Settlement Class in full compliance with the requirements of applicable law, 
including the Due Process Clause of the United States Constitution and Rules 23(c) and (e). In 
addition, Class Notice clearly and concisely states in plain, easily understood language: (i) the 
nature of the action; (ii) the definition of the certified Settlement Class; (iii) the claims and issues 
of the Settlement Class; (iv) that a Settlement Class Member may enter an appearance through an 
attorney if the member so desires; (v) that the Court will exclude from the Settlement Class any 
member who requests exclusion; (vi) the time and manner for requesting exclusion; and (vii) the 
binding effect of a class judgment on members under Rule 23(c)(3). 
 
IN RE: THE HOME DEPOT, INC., CUSTOMER DATA SECURITY BREACH LITIGATION 
Case No. 1:14-md-02583 
The Honorable Thomas W. Thrash Jr., United States District Court, Northern District of Georgia 
(March 10, 2017):  The Court finds that the form, content, and method of giving notice to the 
settlement class as described in the settlement agreement and exhibits: (a) constitute the best 
practicable notice to the settlement class; (b) are reasonably calculated, under the circumstances, 
to apprise settlement class members of the pendency of the action, the terms of the proposed 
settlement, and their rights under the proposed settlement; (c) are reasonable and constitute due, 
adequate, and sufficient notice to those persons entitled to receive notice; and (d) satisfy the 
requirements of Federal Rule of Civil Procedure 23, the constitutional requirement of due process, 
and any other legal requirements. The Court further finds that the notice is written in plain 
language, uses simple terminology, and is designed to be readily understandable by settlement 
class members. 
Case 4:20-cv-03056-DMR     Document 139-1     Filed 08/06/21     Page 12 of 15

 
 
 
ROY v. TITEFLEX CORPORATION t/a GASTITE and WARD MANUFACTURING, LLC 
Case No. 384003V 
The Honorable Ronald B. Rubin, Circuit Court for Montgomery County, Maryland (February 24, 
2017):  What is impressive to me about this settlement is in addition to all the usual recitation of 
road racing litanies is that there is going to be a) public notice of a real nature and b) about a 
matter concerning not just money but public safety and then folks will have the knowledge to 
decide for themselves whether to take steps to protect themselves or not. And that’s probably the 
best thing a government can do is to arm their citizens with knowledge and then the citizens can 
make decision. To me that is a key piece of this deal. I think the notice provisions are exquisite 
[emphasis added]. 
 
IN RE: LG FRONT LOADING WASHING MACHINE CLASS ACTION LITIGATION 
Case No. 2:08-cv-00051 
The Honorable Madeline Cox Arleo, United States District Court, District of New Jersey (June 17, 
2016):  This Court further approves the proposed methods for giving notice of the Settlement to 
the Members of the Settlement Class, as reflected in the Settlement Agreement and the joint 
motion for preliminary approval. The Court has reviewed the notices attached as exhibits to the 
Settlement, the plan for distributing the Summary Notices to the Settlement Class, and the plan 
for the Publication Notice's publication in print periodicals and on the internet, and finds that the 
Members of the Settlement Class will receive the best notice practicable under the circumstances. 
The Court specifically approves the Parties' proposal to use reasonable diligence to identify 
potential class members and an associated mailing and/or email address in the Company's 
records, and their proposal to direct the ICA to use this information to send absent class members 
notice both via first class   mail and email. The Court further approves the plan for the Publication 
Notice's publication in two national print magazines and on the internet. The Court also approves 
payment of notice costs as provided in the Settlement. The Court finds that these procedures, 
carried out with reasonable diligence, will constitute the best notice practicable under the 
circumstances and will satisfy. 
 
FENLEY v. APPLIED CONSULTANTS, INC. 
Case No. 2:15-cv-00259 
The Honorable Mark R. Hornak, United States District Court, Western District of Pennsylvania (June 
16, 2016):  The Court would note that it approved notice provisions of the settlement agreement 
in the proceedings today. That was all handled by the settlement and administrator Angeion. The 
notices were sent. The class list utilized the Postal Service's national change of address database 
along with using certain proprietary and other public resources to verify addresses. the 
requirements of Fed.R.Civ.P. 23(c)(2), Fed.R.Civ.P. 23(e) (l), and Due Process.... 
 
The Court finds and concludes that the mechanisms and methods of notice to the class as 
identified were reasonably calculated to provide all notice required by the due process clause, the 
applicable rules and statutory provisions, and that the results of the efforts of Angeion were 
highly successful and fulfilled all of those requirements [emphasis added]. 
 
 
 
Case 4:20-cv-03056-DMR     Document 139-1     Filed 08/06/21     Page 13 of 15

 
 
FUENTES, ET AL. v. UNIRUSH, LLC d/b/a UNIRUSH FINANCIAL SERVICES, ET AL. 
Case No. 1:15-cv-08372 
The Honorable J. Paul Oetken, United States District Court, Southern District of New York (May 
16, 2016):  The Court approves, as to form, content, and distribution, the Claim Form attached to 
the Settlement Agreement as Exhibit A, the Notice Plan, and all forms of Notice to the Settlement 
Class as set forth in the Settlement Agreement and Exhibits B-D, thereto, and finds that such 
Notice is the best notice practicable under the circumstances, and that the Notice complies fully 
with the requirements of the Federal Rules of Civil Procedure. The Court also finds that the Notice 
constitutes valid, due and sufficient notice to all persons entitled thereto, and meets the 
requirements of Due Process. The Court further finds that the Notice is reasonably calculated to, 
under all circumstances, reasonably apprise members of the Settlement Class of the pendency of 
the Actions, the terms of the Settlement Agreement, and the right to object to the settlement and 
to exclude themselves from the Settlement Class. The Parties, by agreement, may revise the 
Notices and Claim Form in ways that are not material, or in ways that are appropriate to update 
those documents for purposes of accuracy or formatting for publication. 
 
IN RE: WHIRLPOOL CORP. FRONTLOADING WASHER PRODUCTS LIABILITY LITIGATION   
MDL No. 2001/Case No. 1:08-wp-65000 
The Honorable Christopher A. Boyko, United States District Court, Northern District of Ohio (May 
12, 2016):  The Court, having reviewed the proposed Summary Notices, the proposed FAQ, the 
proposed Publication Notice, the proposed Claim Form, and the proposed plan for distributing 
and disseminating each of them, finds and concludes that the proposed plan for distributing and 
disseminating each of them will provide the best notice practicable under the circumstances and 
satisfies all requirements of federal and state laws and due process. 
 
SATERIALE, ET AL. v. R.J. REYNOLDS TOBACCO CO. 
Case No. 2:09-cv-08394 
The Honorable Christina A. Snyder, United States District Court, Central District of California (May 
3, 2016):  The Court finds that the Notice provided to the Settlement Class pursuant to the 
Settlement Agreement and the Preliminary Approval Order has been successful, was the best 
notice practicable under the circumstances and (1) constituted notice that was reasonably 
calculated, under the circumstances, to apprise members of the Settlement Class of the pendency 
of the Action, their right to object to the Settlement, and their right to appear at the Final Approval 
Hearing; (2) was reasonable and constituted due, adequate, and sufficient notice to all persons 
entitled to receive notice; and (3) met all applicable requirements of the Federal Rules of Civil 
Procedure, Due Process, and the rules of the Court. 
 
FERRERA, ET AL. v. SNYDER’S-LANCE, INC. 
Case No. 0:13-cv-62496 
The Honorable Joan A. Lenard, United States District Court, Southern District of Florida (February 
12, 2016):  The Court approves, as to form and content, the Long-Form Notice and Short- Form 
Publication Notice attached to the Memorandum in Support of Motion for Preliminary Approval 
of Class Action Settlement as Exhibits 1 and 2 to the Stipulation of Settlement. The Court also 
approves the procedure for disseminating notice of the proposed settlement to the Settlement 
Class and the Claim Form, as set forth in the Notice and Media Plan attached to the Memorandum 
in Support of Motion for Preliminary Approval of Class Action Settlement as Exhibits G. The Court 
Case 4:20-cv-03056-DMR     Document 139-1     Filed 08/06/21     Page 14 of 15

 
 
finds that the notice to be given constitutes the best notice practicable under the circumstances, 
and constitutes valid, due, and sufficient notice to the Settlement Class in full compliance with the 
requirements of applicable law, including the Due Process Clause of the United States 
Constitution. 
 
IN RE: POOL PRODUCTS DISTRIBUTION MARKET ANTITRUST LITIGATION 
MDL No. 2328/Case No. 2:12-md-02328 
The Honorable Sarah S. Vance, United States District Court, Eastern District of Louisiana 
(December 31, 2014):  To make up for the lack of individual notice to the remainder of the class, 
the parties propose a print and web-based plan for publicizing notice. The Court welcomes the 
inclusion of web- based forms of communication in the plan. The Court finds that the proposed 
method of notice satisfies the requirements of Rule 23(c)(2)(B) and due process. The direct 
emailing of notice to those potential class members for whom Hayward and Zodiac have a valid 
email address, along with publication of notice in print and on the web, is reasonably calculated 
to apprise class members of the settlement. Moreover, the plan to combine notice for the Zodiac 
and Hayward settlements should streamline the process and avoid confusion that might otherwise 
be caused by a proliferation of notices for different settlements. Therefore, the Court approves 
the proposed notice forms and the plan of notice. 
 
SOTO, ET AL. v. THE GALLUP ORGANIZATION, INC. 
Case No. 0:13-cv-61747 
The Honorable Marcia G. Cooke, United States District Court, Southern District of Florida (June 16, 
2015):  The Court approves the form and substance of the notice of class action settlement 
described in ¶ 8 of the Agreement and attached to the Agreement as Exhibits A, C and D. The 
proposed form and method for notifying the Settlement Class Members of the settlement and its 
terms and conditions meet the requirements of Fed. R. Civ. P. 23(c)(2)(B) and due process, 
constitute the best notice practicable under the circumstances, and shall constitute due and 
sufficient notice to all persons and entities entitled to the notice. The Court finds that the proposed 
notice is clearly designed to advise the Settlement Class Members of their rights. 
 
OTT v. MORTGAGE INVESTORS CORPORATION OF OHIO, INC. 
Case No. 3:14-cv-00645 
The Honorable Janice M. Stewart, United States District Court, District of Oregon (July 20, 2015): 
The Notice Plan, in form, method, and content, fully complies with the requirements of Rule 23 
and due process, constitutes the best notice practicable under the circumstances, and is due and 
sufficient notice to all persons entitled thereto. The Court finds that the Notice Plan is reasonably 
calculated to, under all circumstances, reasonably apprise the persons in the Settlement Class of 
the pendency of this action, the terms of the Settlement Agreement, and the right to object to 
the Settlement and to exclude themselves from the Settlement Class. 
Case 4:20-cv-03056-DMR     Document 139-1     Filed 08/06/21     Page 15 of 15

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