Declaration of John Pitts re Plaintiffs Motion for Preliminary Approval of Class Action… — Plaid Privacy (Dkt. 147)

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Declaration of John Pitts, filed October 7, 2021 as Doc. 147 in In re Plaid Inc. Privacy Litigation, No. 4:20-cv-03056-DMR (N.D. Cal., Oakland Division), in response to the Court's request (D146) regarding Plaintiffs' Motion for Preliminary Approval of Class Action Settlement. The declarant states that the declarant is the Head of Policy at Plaid Inc. and describes Plaid's technology as enabling consumers to connect bank and other financial accounts to fintech apps. The declaration states that, as outlined in Plaid's End User Privacy Policy, Plaid does not sell or rent the personal information it collects about consumers. It carries /s/ John Pitts and an attestation by Whitty Somvichian under Civil Local Rule 5-1(i)(3).

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DECLARATION OF JOHN PITTS IN RESPONSE 
TO THE COURT’S REQUEST (D146) 
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) 
3 Embarcadero Center, 20th floor 
San Francisco, CA 94111-4004 
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 
DECLARATION OF JOHN PITTS IN 
RESPONSE TO THE COURT’S REQUEST RE 
PLAINTIFFS’ MOTION FOR PRELIMINARY 
APPROVAL OF CLASS ACTION 
SETTLEMENT (D146) 
Dept: 
Courtroom 4 – 3rd Floor 
Judge:  
Donna M. Ryu 
 
Trial Date:  None Set 
 
 
 
 
 
 
Case 4:20-cv-03056-DMR   Document 147   Filed 10/07/21   Page 1 of 3

 
 
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DECLARATION OF JOHN PITTS IN RESPONSE 
TO THE COURT’S REQUEST (D146) 
NO. 4:20-CV-3056-DMR 
 
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COOLEY LLP 
ATTORNEYS AT LAW 
SAN FRANCISCO 
I, John Pitts, declare as follows: 
1. 
I am the Head of Policy at Plaid Inc. (“Plaid”) and have held this role since 
September 2018.  
2. 
My responsibilities as Plaid’s Head of Policy include representing Plaid in 
discussions with governments, policymakers, consumer groups, and trade associations; 
developing and executing Plaid’s policy engagement strategy; and understanding and articulating 
Plaid’s role in the larger Open Finance ecosystem. 
3. 
As the Head of Policy at Plaid, I regularly liaise with stakeholders across Plaid, 
including colleagues working in Engineering, Product, Legal, Risk, and Revenue, to stay 
informed and updated about Plaid’s business practices and operations.  
4. 
The following facts are within my personal knowledge, and if called and sworn as 
a witness, I could and would testify competently to these facts. 
Plaid’s Data Practices 
5. 
Plaid provides technology that enables consumers to connect their bank accounts 
and other financial accounts to fintech apps and services of their choosing. 
6. 
When a consumer chooses to connect their bank account to their chosen app or 
service through Plaid, they share certain information with Plaid and other authorized parties, such 
as the developer of the app or service they are using. 
7. 
Plaid’s collection, use, and disclosure of such consumer-permissioned data is 
described in its End User Privacy Policy, which is available on Plaid’s website at plaid.com/legal.  
8. 
As outlined in Plaid’s End User Privacy Policy, Plaid does not sell or rent the 
personal information it collects about consumers. 
I declare under penalty of perjury under the laws of the United States that the foregoing is true 
and correct.  Executed this 7th day of October 2021, in Washington D.C. 
 
By:  
/s/ John Pitts  
 
 
 
 
   
 
 
 
JOHN PITTS 
HEAD OF POLICY PLAID INC. 
 
 
Case 4:20-cv-03056-DMR   Document 147   Filed 10/07/21   Page 2 of 3

 
 
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DECLARATION OF JOHN PITTS IN RESPONSE 
TO THE COURT’S REQUEST (D146) 
NO. 4:20-CV-3056-DMR 
 
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COOLEY LLP 
ATTORNEYS AT LAW 
SAN FRANCISCO 
ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3) 
I, Whitty Somvichian, attest that concurrence in the filing of this document has been obtained 
from the signatory.  Executed on October 7, 2021, in Oakland, California. 
 
 
/s/ Whitty Somvichian  
 
 
Whitty Somvichian 
 
 
 257862058  
 
Case 4:20-cv-03056-DMR   Document 147   Filed 10/07/21   Page 3 of 3

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