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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 C — In re Plaid Inc. Privacy Litigation (Dkt. 139-3, N.D. Cal. No. 4:20-cv-03056)

Court filing

Exhibit C — In re Plaid Inc. Privacy Litigation (Dkt. 139-3, 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. 139-3 · 2021-08-06 · Docket on CourtListener

Full text

Exhibit C 
Case 4:20-cv-03056-DMR     Document 139-3     Filed 08/06/21     Page 1 of 3

 
 Notice of Class Action 
Settlement 
In re Plaid Inc. Privacy 
Litigation 
 
If you connected your 
financial account to a mobile  
or web-based app that has 
used Plaid between  
January 1, 2013 and [ ] in 
the United States,  
you may be eligible for a 
payment from a class action 
settlement. 
 
This is a Court-approved Legal Notice. 
This is not an advertisement. 
 
This notice is only a summary. It 
contains information about a class 
action 
settlement. 
More 
detailed 
information can be found at: 
 
www.PlaidSettlement.com 
Questions? XXX-XXX-XXXX 
 
Forwarding Service Requested 
[BARCODE] 
Postal Service: Please do not mark barcode 
 
Notice ID: XXXXXX 
Confirmation Code: XXXXXX 
 
FIRST NAME LAST NAME 
ADDRESS 1 
ADDRESS 2 
CITY, ST ZIP 
 
 
 
Plaid Privacy Litigation 
c/o Settlement Administrator 
1650 Arch Street, Suite 2210 
Philadelphia, PA 19103 
Case 4:20-cv-03056-DMR     Document 139-3     Filed 08/06/21     Page 2 of 3

 
 
 
A Settlement has been proposed in this class action litigation against Plaid Inc. (“Plaid”). Plaid enables connections between a user’s financial account and approximately 
5,000 mobile and web-based applications (“apps”). This class action alleges Plaid took certain improper actions by (1) obtaining log-in credentials to user’s financial accounts 
through an interface (“Plaid Link”) that allegedly had the look and feel of a bank account login screen, when in fact it was Plaid itself; and (2) obtaining more financial and 
other data than was authorized or needed by a user's app. Plaid denies these allegations and any wrongdoing and maintains that it adequately disclosed and maintained 
transparency about its practices. 
 
Who is Included? You may be a Class Member, and affected by this Settlement, if you are a United States resident who connected a financial account to an app between 
January 1, 2013 and [[_]]. More specifically, you are a Class Member if you own or owned one or more “Financial Accounts” between January 1, 2013 and [[_]]. “Financial 
Accounts” is any checking, savings, loan, or other account at a financial institution (1) that Plaid 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. You are receiving this notice because records indicate you may be a Class Member. For additional information on how to confirm whether you 
are a Class Member, please visit www.PlaidSettlement.com. 
 
What does the settlement provide? Under the Settlement, Plaid will pay $58 million to establish a Settlement Fund. After deducting any court-approved attorneys’ fees 
and expenses, Service Awards for the Class Representatives, and the costs of the settlement administration, the Settlement Fund will be distributed to Class Members on a 
pro rata basis. The amount of the payments to individual Class Members will depend on the number of valid claims that are filed. The Settlement also requires Plaid to 
provide other non-monetary benefits. Please visit www.PlaidSettlement.com for more information. 
 
How do I get a payment? You must submit a valid Claim Form submitted online or postmarked by [DATE]. Claim Forms may be submitted online at 
www.PlaidSettlement.com or by completing and returning a Claim Form to the Settlement Administrator. Please visit www.PlaidSettlement.com for more information. 
 
Do I have a lawyer in the case? If you are a Class Member, you have a lawyer in this case. The Court appointed as “Class Counsel” the law firms Burns Charest LLP; 
Herrera Kennedy LLP; and Lieff Cabraser Heimann & Bernstein LLP to represent the Class Members. Their contact information is available at www.PlaidSettlement.com. If 
you want to be represented by your own lawyer, you may hire one at your own expense. 
 
Your other options. If you are included in the settlement and do nothing, your rights will be affected and you won’t get a payment. If you don’t want to be legally bound by 
the settlement, you must exclude yourself from it by [DATE]. Unless you exclude yourself, you won’t be able to sue or continue to sue Plaid for any claim made in this lawsuit 
or released by the Settlement Agreement. If you exclude yourself, you won’t receive a payment. If you stay in the settlement (i.e., don’t exclude yourself), you may object to 
it or ask for permission for you or your lawyer to appear and speak at the Final Approval Hearing – at your own cost – but you don’t have to. Objections and requests to 
appear are due by [DATE]. More information about these options is available at www.PlaidSettlement.com. 
 
The Court’s hearing. The Court will hold the Final Approval Hearing at [__] on [Month] [Day], 2021 in Courtroom 4 (3rd Floor) of the United States Courthouse, 1301 Clay 
Street, Oakland, CA 94612. At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. If there are objections, the Court 
will consider them. The Court may listen to people who appear at the hearing and who have provided notice of their intent to appear at the hearing. The Court may also 
consider Class Counsel’s application for attorneys’ fees, expenses, and Service Awards. At or after the hearing, the Court will decide whether to approve the Settlement and 
to approve Class Counsel’s application for attorneys’ fees, expenses, and Service Awards. The date of the Final Approval Hearing may change without further notice, and 
Class Members should check www.PlaidSettlement.com to confirm that the date has not been changed.  
 
Case 4:20-cv-03056-DMR     Document 139-3     Filed 08/06/21     Page 3 of 3

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