Declaration of Steven Weisbrot in Support of 156 Motion for Settlement Notice — In re Plaid Inc. Privacy Litigation (Dkt. 159, N.D. Cal. No. 4:20-cv-03056)

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U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 159 · 2022-02-01 · Docket on CourtListener

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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
 
 
IN RE PLAID INC. PRIVACY  
LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
NOTICE COMPLIANCE 
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 were previously provided 
in my Declaration that was submitted to the Court on August 6, 2021 (ECF No. 139). 
2. 
The purpose of this Declaration is to provide the Court with a summary of the work 
performed by Angeion thus far to effectuate notice pursuant to the Court’s November 19, 2021 
Order on Motion for Preliminary Approval of a Class Action Settlement (“Order”). 
3. 
Angeion was retained to serve as the Settlement Administrator to, among other tasks, 
implement the Notice Program; receive and process Claim Forms and respond to Class Member 
inquiries; establish and maintain a dedicated Settlement Website and toll-free telephone number; 
and perform other duties as specified in the Class Action Settlement Agreement (“Agreement”) 
that this Court preliminarily approved on November 19, 2021 (ECF No. 153). 
SUMMARY OF THE NOTICE PROGRAM 
4. 
The Notice Program approved by the Court provides individual direct notice to all 
reasonably identifiable Class Members via email or mail, combined with a strategic media 
campaign comprised of state-of-the-art digital advertising, social media advertising, search engine 
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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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marketing, sponsored listings on two leading class action settlement websites, and engagement on 
social media. The Notice Program also includes the implementation of a dedicated website and a 
toll-free telephone line where Class Members can learn more about their rights and options 
pursuant to the terms of the Settlement. 
DISTRIBUTION OF CAFA NOTICE 
5. 
On August 13, 2021, pursuant to 28 U.S.C. §§ 1715(b), Angeion caused Notice regarding 
the Settlement to be sent to the Attorneys General of all states and territories and the Attorney 
General of the United States (“CAFA Notice”). The CAFA Notice mailings included copies of 
the documents listed in the CAFA Notice. A true and correct copy of the CAFA Notice is 
attached hereto as Exhibit A 
DIRECT NOTICE 
Email Notice 
6. 
On or about November 29, 2021, as ordered by the Court, Plaid provided Angeion with 
electronic files containing 62,028,348 records of class member email addresses and 654,304 
records of Class member Mailing addresses. After removing duplicative records, Angeion 
identified a total of 62,008,166 unique records with valid email addresses and a total of 651,153 
unique records with mailing addresses.  
7. 
Between January 7, 2022 and January 28, 2022, Angeion caused the email notice to be 
sent to the 60,271,546 Settlement Class Members with valid email addresses. The full 
deliverability of the emailed notices is not known as of the date of this declaration. Angeion can 
report as of January 25, 2022, approximately 647,109 notices could not be delivered, which only 
constitutes the information available at this time. Future declarations concerning the 
implementation of the notice program will include the total undeliverable email number. A true 
and accurate copy of the email notice is attached hereto as Exhibit B. 
Custom Social Media Notice 
8. 
On January 28, 2022, Angeion caused the custom social media campaign to commence to 
Class Members for which an email address was provided by Plaid, as ordered by the Court, and 
where those email addresses are used as the primary log-in for Facebook or Instagram, display 
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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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ads are delivered directly to Class Members via those social media platforms. A true and accurate 
copy of the advertisements is attached hereto as Exhibit C. 
Mailed Notice 
9. 
Between January 21, 2022 and January 24, 2022, Angeion caused the postcard notice to 
be mailed to the 650,669 Class Member records that did not have email addresses, but had 
mailing address information. A true and accurate copy of the postcard notice is attached hereto as 
Exhibit D. 
10. 
Prior to mailing, Angeion caused the mailing list to be updated utilizing the United States 
Postal Service’s (“USPS”) National Change of Address database, which provides updated address 
information for individuals or entities that have moved during the previous four years and filed a 
change of address with the USPS. Angeion will receive and process mailed notices returned by 
the USPS as undeliverable. 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 a forwarding address will be subjected to address verification searches (“skip 
traces”), and notices will be re-mailed to any updated addresses identified through the skip trace 
process. 
MEDIA NOTICE 
Digital and Social Media Notice 
11. 
On or about January 13, 2022, Angeion implemented the programmatic digital banner ad 
campaign designed to reach the Target Audience and drive them to the Settlement Website. True 
and correct copies of the banner ads are attached hereto as Exhibit E. 
12. 
On or about January 24, 2022, Angeion implemented a social media campaign utilizing 
the platforms Facebook and Instagram to notify and drive Settlement Class Members to the 
dedicated Settlement Website where they could find more information about the Settlement and 
submit a claim form. True and correct copies of the social media ads are attached hereto as 
Exhibit F. 
13. 
On or about January 25, 2022, Angeion also implemented a social media campaign with 
video incorporated utilizing the platforms Facebook and Instagram. A true and correct copy of a 
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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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depiction image of the social media adverting with a video component is attached hereto as 
Exhibit G. 
14. 
The media notice is scheduled to run for 45 days and is designed to deliver approximately 
326 million impressions, with an approximate 80.40% reach and an average frequency of 3.62. 
Angeion will provide the parties and the Court with an update after the media campaign has 
concluded. 
Paid Search Campaign 
15. 
On or about January 25, 2022, Angeion implemented a paid search campaign to help drive 
Settlement Class Members who are actively searching for information about the Settlement to the 
dedicated Settlement Website. 
Sponsored Class Action Website Listings 
16. 
On January 11, 2022, sponsored listings on Top Class Actions and ClassAction.org were 
implemented. True and correct copies of the listings are attached hereto as Exhibits H and I, 
respectively. 
Social Media Engagement 
17. 
Beginning on January 26, 2022, Angeion began monitoring public Twitter traffic for 
discussion of the Settlement, including historical discussions that preceded the monitoring date, in 
order to provide information or respond to questions via Twitter. 
SETTLEMENT WEBSITE AND TOLL-FREE HOTLINE 
 
 
18. 
On or about January 6, 2022, Angeion established the following website devoted to this 
Settlement: www.PlaidSettlement.com (“Settlement Website”). The Settlement Website contains 
general information about the Settlement, including answers to frequently asked questions, 
important dates and deadlines pertinent to this matter, and copies of important documents. 
Visitors to the Settlement Website can download (1) a Long Form Notice, (2) a Claim Form, (3) 
the Consolidated Amended Class Action Complaint, (4) the Order, and (5) the Agreement. The 
Settlement Website also has a “Contact Us” page whereby Class Members can submit questions 
regarding the Settlement to a dedicated email address: Questions@PlaidSettlement.com. The 
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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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Settlement Website address was set forth in the Long Form Notice and Claim Form. A true and 
correct copy of the Long Form Notice is attached hereto as Exhibit J. 
19. 
On or about January 6, 2022, Angeion established an online claim filing portal (on the 
Submit a Claim page of the Settlement Website) whereby Class Members can complete and 
submit their Claim Form via the Settlement Website, or where they can download a PDF of the 
Claim Form to complete and submit by mail.  
20. 
On or about January 20, 2022, Angeion implemented a customized video on the Submit a 
Claim page of the Settlement Website to provide instructions for Class Members on how to file a 
claim. A true and correct copy of a depiction image of this video is attached hereto as Exhibit K. 
21. 
As of January 27, 2022, the Settlement Website has had 4,140,671 page views and 
1,971,061 sessions, which represents the number of individual sessions initiated by all users. 
22. 
On or about January 4, 2022, Angeion established the following toll-free line dedicated to 
this case: 1-855-645-1115.  The toll-free line utilizes an interactive voice response (“IVR”) 
system to provide Class Members with responses to frequently asked questions, the ability to 
request a Claim Form, and includes information about filing a claim and important dates and 
deadlines. The toll-free line is accessible 24 hours a day, 7 days a week. 
23. 
As of January 27, 2022, the toll-free number has received approximately 8,770 calls, 
totaling 37,197 minutes. 
 
CLAIM FORM SUBMISSIONS 
24. 
The deadline for members of the Settlement Class to submit a claim form is April 28, 
2022. As of January 27, 2022, Angeion has received approximately 679,037 claim form 
submissions. These claim form submissions are still subject to final audits, including the full 
assessment of each claim’s validity and a review for duplicate submissions. Angeion will 
continue to keep the parties apprised of the number of claim form submissions received.  
REQUESTS FOR EXCLUSION AND OBJECTIONS TO THE SETTLEMENT 
25. 
The deadline for members of the Settlement Class to request exclusion from the 
Settlement or object to the Settlement is March 4, 2022. As of January 27, 2022, Angeion has not 
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NOTICE COMPLIANCE DECLARATION OF STEVEN 
WEISBROT ON BEHALF OF ANGEION GROUP, LLC 
MASTER DOCKET NO. 4:20-cv-03056-DMR 
 
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received any requests for exclusion from the Settlement. Angeion will inform the parties of any 
requests for exclusion it receives.  
26. 
Angeion has been made aware of two objections to the Settlement, which were filed with 
the Court as reflected on the docket (ECF Nos. 154, 155). The filed objections are attached hereto 
as Exhibits L and M.  Angeion has reached out to the Class Member who submitted the second 
objection (ECF No. 155), to assist him in addressing the technical issues identified in his letter. 
CONCLUSION 
27. 
The Notice Program described herein included direct notice to all reasonably identifiable 
members of the Settlement Class via email or mail where an email address was not provided, 
coupled with a robust digital campaign that included, programmatic display advertising, social 
media advertising, video advertising and the implementation of a dedicated Settlement Website 
and toll-free hotline to further inform members of the Settlement Class of their rights and options 
pursuant to the terms of the Settlement. 
28. 
It is my professional opinion that the Notice Program provided full and proper notice to 
members of the Settlement Class before the claims, opt-out, and objection deadlines.  Moreover, 
it is my opinion that the Notice Program was the best notice that is practicable under the 
circumstances and fully comported with due process and Federal Rule of Civil Procedure 23. 
I hereby declare under penalty of perjury under the laws of the United States that the 
foregoing is true and correct. 
Dated: January 28, 2022 
 
 
 
 
 
 
 
 
____________________ 
 
 
 
 
 
 
 
 
STEVEN WEISBROT 
 
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Exhibit A 
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1650 Arch Street, Suite 2210 
Philadelphia, PA 19103  
www.angeiongroup.com 
215.563.4116 (P) 
215.525.0209 (F) 
 
 
 
August 13, 2021 
VIA USPS PRIORITY MAIL 
United States Attorney General & 
Appropriate Officials 
  
Re:  
Notice of Class Action Settlement 
In re Plaid Inc. Privacy Litigation 
 
Dear Counsel or Official: 
Angeion Group, an independent claims administrator, on behalf of the defendant in the below-described action, 
hereby provides your office with this notice under the provisions of the Class Action Fairness Act (“CAFA”), 28 
U.S.C. § 1715, to advise you of the following proposed class action settlement: 
 
Case Name:  In re Plaid Inc. Privacy Litigation 
Index Number: 4:20-cv-03056 
Jurisdiction:  United States District Court, Northern District of California Oakland Division 
Date Settlement Filed with Court:  August 5, 2021 
 
In accordance with the requirements of 28 U.S.C. § 1715, please find copies of the following documents 
associated with this action on the enclosed CD-ROM: 
 
1. 28 U.S.C. § 1715(b)(1)-Complaint:  Complaint for Damages and Declaratory and Equitable Relief filed with 
the Court on May 4, 2020; Consolidated Amended Class Action Complaint for Damages and Declaratory and 
Equitable Relief filed with the Court on August 5, 2020. 
 
2. 28 U.S.C. § 1715(b)(2)-Notice of Any Scheduled Judicial Hearings:  A videoconference regarding Plaintiffs’ 
motion for preliminary approval is currently scheduled for September 30, 2021. There are no other judicial 
hearings currently scheduled. 
 
3. 28 U.S.C. § 1715(b)(3)-Notification to Class Members:  The Long Form Notice, Email Notice, Postcard Notice 
and Claim Forms filed with the Court on August 5, 2021. 
 
4. 28 U.S.C. § 1715(b)(4)-Class Action Settlement Agreement:  Class Action Settlement Agreement filed with 
the Court on August 5, 2021. Notice of Motion and Motion for Preliminary Approval of Class Action 
Settlement, Declaration of Shawn M. Kennedy in Support of Plaintiffs’ Motion for Preliminary Approval, as 
well as the Declaration of The Honorable Jay C. Gandhi (Ret.) filed with the Court on August 5, 2021, are also 
included on the enclosed CD-ROM. 
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2 
 
 
5. 28 U.S.C. § 1715(b)(5)-Any Settlement or Other Agreements:  Other than the Class Action Settlement 
Agreement, no other settlements or other agreements have been contemporaneously made between the 
Parties.  
 
6. 28 U.S.C. § 1715(b)(6)-Final Judgment:  The Court has not issued a Final Judgment or notice of dismissal as 
of the date of this CAFA Notice.   
 
7. 28 U.S.C. § 1715(b)(7)(B)-Estimate of Class Members:  The Settlement Class is estimated to potentially 
include approximately ninety-eight million Class Members located throughout the United States. The 
estimated proportional share of the Settlement benefits is not available at this time, as it is contingent on 
the Class Member submission of a claim form. 
 
8. 28 U.S.C. §1715(b)(8)-Judicial Opinions Related to the Settlement:  The Court has not issued a judicial 
opinion related to the Settlement at this time. The [Proposed] Order Granting Preliminary Approval of 
Settlement is included on the enclosed CD-ROM. 
 
If you have questions or concerns about this notice, the proposed settlement, or the enclosed materials, or if 
you did not receive any of the above-listed materials, please contact this office. 
 
 
Sincerely,  
Angeion Group   
1650 Arch Street, Suite 2210 
Philadelphia, PA  19103 
(p) 215-563-4116 
(f)  215-563-8839 
 
 
 
Enclosures 
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Exhibit B 
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Sender Email: DoNotReply@PlaidSettlement.com 
Sender Name: Settlement Administrator 
Subject Line: Notice of Class Action Settlement – In re Plaid Inc. Privacy Litigation 
Notice ID:  [Notice ID number] 
Confirmation Code:  [Confirmation code number] 
 
Notice of Class Action Settlement - In re Plaid Inc. Privacy Litigation 
 
If you connected your financial account(s) to a mobile or web-based app that 
has used Plaid between January 1, 2013 and November 19, 2021 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. 
 
A Settlement has been proposed in class action litigation against Plaid Inc. (“Plaid”).  Plaid enables 
connections between a user’s financial account(s) and approximately 5,000 mobile and web-based 
applications (“apps”).  This class action alleges Plaid took certain improper actions in connection 
with this process.  The allegations include that Plaid: (1) obtained more financial data than was 
needed by a user's app, and (2) obtained log-in credentials (username and password) through its 
interface, known as Plaid Link, which the litigation alleges had the look and feel of the user’s own 
bank account login screen, when users were actually providing their login credentials directly to 
Plaid.  Plaid denies these allegations and any wrongdoing and maintains that it adequately disclosed 
and maintained transparency about its practices to consumers.  
Who is Included?  You are a Class Member, and you are affected by this Settlement, if you own or 
owned one or more “Financial Accounts” between January 1, 2013 and November 19, 2021, and 
you were a United States resident at the time. A “Financial Account” 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. 
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 and Service Awards for the Class 
Representatives, and the costs of the Settlement administration, the Settlement Fund will be 
distributed to Class Members who submit valid claims, 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: 
• 
Delete certain data from Plaid systems; 
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• 
Inform Class Members of their ability to use Plaid Portal to manage the connections made 
between their financial accounts and chosen applications using Plaid and delete data stored 
in Plaid’s systems; 
• 
Continue to include certain disclosures and features in Plaid’s standard Link flow; 
• 
Enhance disclosures about Plaid’s data collection practices, how Plaid uses data, and privacy 
controls Plaid has made available to uses in Plaid’s End User Privacy Policy; 
• 
Minimize the data that Plaid stores; and 
• 
Continue to host a dedicated webpage with detailed information about Plaid’s security 
practices. 
How do I get a payment? You must submit a valid Claim Form online or postmarked by April 28, 
2022. Claim Forms may be submitted online at www.PlaidSettlement.com or printed from the 
website and mailed to the address on the Claim Form. Claim Forms are also available by calling 
855-645-1115 or emailing Questions@PlaidSettlement.com. 
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. 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 March 4, 2022. 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 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 March 4, 2022. More information 
about these options is available at www.PlaidSettlement.com. 
The Court’s hearing. The Court will hold the Final Approval Hearing at 1 p.m. on May 12, 2022 
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 for 
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.   
 
This notice is only a summary.  
 
For more information visit www.PlaidSettlement.com or call 855-645-1115. 
 
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Exhibit C 
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Exhibit D 
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Plaid Privacy Litigation
c/o Settlement Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA 19103
Notice ID: ‹‹Notice ID››
Confirmation Code: ‹‹Confirmation Code››
‹‹First Name›› ‹‹Last Name››
‹‹Address1››
‹‹Address2››
‹‹City››, ‹‹St›› ‹‹Zip››
‹‹Country››
PRESORTED
FIRST CLASS MAIL
US POSTAGE PAID
MAG
Electronic Service
Requested
Postal Service: Please Do Not Mark Barcode
 Notice of Class Action Settlement 
In re Plaid Inc. Privacy Litigation
If you connected your 
financial account(s) to a mobile or 
web-based app that has used Plaid 
between January 1, 2013 and 
November 19, 2021 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? 855-645-1115
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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 one or more financial accounts to 
an app between January 1, 2013 and November 19, 2021. More specifically, you are a Class Member if you own or owned one or more “Financial Accounts” between 
January 1, 2013 and November 19, 2021. “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 who submit valid claims, 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 nonmonetary 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 April 28, 2022. 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 March 4, 2022. 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 March 4, 2022. More information about these options is available at www.PlaidSettlement.com.
The Court’s hearing. The Court will hold the Final Approval Hearing at 1 p.m. on May 12, 2022 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. 
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Exhibit E 
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  Document 159     File

  Document 159     File

56-DMR     Document 159     Filed 02/01/22

56-DMR     Document 159     Filed 02/01/22

56-DMR     Document 159     Filed 02/01/22

56-DMR     Document 159     Filed 02/01/22

56-DMR     Document 159     Filed 02/01/22

56-DMR     Document 159     Filed 02/01/22

056-DMR     Document 159     Filed 02/01/22 

056-DMR     Document 159     Filed 02/01/22 

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Exhibit F 
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Case 4:20-cv-03056-DMR     Document 159     Filed 02/01/22     Page 36 of 76

 
 
 
 
 
 
 
 
 
Exhibit G 
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Case 4:20-cv-03056-DMR     Document 159     Filed 02/01/22     Page 38 of 76

 
 
 
 
 
 
 
 
 
Exhibit H 
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Exhibit I 
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Exhibit J
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United States District Court for the Northern District of California 
This Settlement affects your legal rights even if you do nothing.  
Questions?  Go to www.PlaidSettlement.com or call 855-645-1115. 
- 1 - 
Notice of Class Action Settlement  
In re Plaid Inc. Privacy Litigation 
Important Information – Read Carefully. 
This is a Court approved Legal Notice. This is not an advertisement.
A Settlement has been proposed in class action litigation against Plaid Inc. (“Plaid”).  
Approximately 5,000 mobile and web-based applications (“apps”) use Plaid to enable users to 
connect the app to the users' bank account(s).  This class action alleges Plaid took certain 
improper actions in connection with this process.  The allegations include that Plaid: (1) obtained 
more financial data than was needed by a user's app, and (2) obtained log-in credentials 
(username and password) through its user interface, known as “Plaid Link,” which had the look 
and feel of the user’s own bank account login screen, when users were actually providing their 
login credentials directly to Plaid.  Plaid denies these allegations and any wrongdoing and 
maintains that it adequately disclosed and maintained transparency about its practices to 
consumers. 
You may be a Class Member if you are a United States resident and you connected a financial 
account to an app between January 1, 2013 and November 19, 2021.  More specifically, you are 
a Class Member if you own or owned one or more “Financial Accounts” (defined in Question 7) 
that Plaid accessed using your login credentials and connected to a mobile or web-based app 
that enables payments or other money transfers; or for which you provided Financial Account 
login credentials to Plaid through Plaid Link; between January 1, 2013 and November 19, 2021. 
To search for and confirm whether specific apps or services that connected to your financial 
account(s) used Plaid for account connections, you can visit the Settlement website at 
www.PlaidSettlement.com.
Under the Settlement, Plaid has agreed to minimize the data it stores going forward, to delete 
certain previously retrieved data, and to improve and maintain certain already-implemented 
enhancements to Plaid Link.  Class Members are also able to view and manage the connections 
they’ve made between their financial accounts and chosen applications using Plaid, and delete 
data stored in Plaid’s systems by creating a Plaid Portal account, at my.plaid.com.   
In addition, the Settlement establishes a $58 million Settlement Fund, to be used for cash 
payments to Class Members who submit valid claims for compensation, after deducting the costs 
of the settlement administration, court-approved attorneys’ fees and expenses, and Service 
Awards for eleven Class Representatives.  The amount of monetary payments issued to Class 
Members will depend on the number of valid claims received.  In exchange for the benefits the 
Settlement provides, Class Members will release any and all claims they may have (whether 
known or unknown) regarding the allegations in the Complaint.  
Case 4:20-cv-03056-DMR     Document 159     Filed 02/01/22     Page 46 of 76

This Settlement affects your legal rights even if you do nothing.  
Questions?  Go to www.PlaidSettlement.com or call 855-645-1115. 
- 2 - 
The Court will decide whether to approve the proposed Settlement.  If approved, the Settlement 
will resolve the litigation entitled In re Plaid Inc. Privacy Litigation, Case No. 4:20-md-03056, which 
is pending before Judge Donna M. Ryu in the Northern District of California.   
The class action settlement approval process may take several months, or more, if there is an 
appeal.   
Please Read this Notice Carefully. 
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
FILE A CLAIM
FOR
COMPENSATION 
You may file a Claim in order to receive a 
monetary payment from the Settlement Fund.  
Filing a Claim is the only way to receive a 
payment from this settlement.   
For detailed information about how to file a 
Claim, see Question 16. 
Deadline: 
April 28, 
2022 
 
EXCLUDE
YOURSELF
FROM THIS
SETTLEMENT 
You can exclude yourself from the Settlement by 
informing the Settlement Administrator that you 
want to “opt-out” of the Settlement.  If the 
Settlement becomes final, this is the only option 
that allows you to retain your rights to individually 
sue for claims relating to the allegations in the 
Complaint.  You will not receive a payment from 
the Settlement if you exclude yourself.   
Deadline: 
March 4, 
2022 
OBJECT TO OR
COMMENT ON
THE
SETTLEMENT 
You may object to the Settlement by writing to 
the Court about why you don’t think the 
Settlement should be approved.   
You can also write the Court to provide 
comments or reasons why you support the 
Settlement.   
For detailed information about how to object to or 
comment on the Settlement, see Question 23. 
Deadline: 
March 4, 
2022 
GO TO THE
FINAL
APPROVAL
HEARING 
You may, but are not required to, attend the Final 
Approval Hearing where the Court may hear 
arguments concerning the approval of the 
Settlement.  If you wish to speak at the Final 
Approval Hearing, you must state your intention 
to do so in your written objection or comment.  
Deadline: 
May 12, 
2022 
DO NOTHING 
If you do nothing before the deadline to 
comment, object, or exclude yourself, and if the 
Settlement becomes final, you will be part of the 
Settlement Class and bound by the Settlement 
and give up your rights to sue for claims relating 
to any or all allegations in the Plaintiffs’ complaint 
in this case.   
Deadline: 
N/A 
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What this Notice Contains
Page
This Settlement affects your legal rights even if you do nothing.  
Questions?  Go to www.PlaidSettlement.com or call 855-645-1115. 
- 3 - 
BACKGROUND INFORMATION ................................................................................ 1 
1. 
Why is there a notice? ........................................................................... 1 
2. 
What is this litigation about? .................................................................. 1 
3. 
Who is the defendant in the lawsuit? ..................................................... 1 
4. 
Why is this a class action? ..................................................................... 2 
5. 
Why is there a settlement? .................................................................... 2 
CLASS MEMBERSHIP ............................................................................................... 2 
6. 
Who is part of the Settlement? ............................................................... 2 
7. 
What does “Financial Account” mean in the Settlement? ...................... 3 
8. 
What is Plaid Link? ................................................................................ 3 
9. 
How do I know whether I am a member of the Class? ........................... 3 
THE LAWYERS FOR CLASS MEMBERS ................................................................. 4 
10. 
Do I have a lawyer in the case? ............................................................. 4 
11. 
How will Class Counsel be paid? ........................................................... 4 
BENEFITS FOR CLASS MEMBERS .......................................................................... 5 
12. 
What nonmonetary benefits does the Settlement provide? .................... 5 
13. 
What monetary benefits does the Settlement provide?.......................... 8 
14. 
Will all Class Members who file claims receive the same amount? ....... 8 
15. 
How do I control who has access to my data? ....................................... 9 
HOW TO FILE A CLAIM ............................................................................................. 9 
16. 
How do I file a claim for compensation? ................................................ 9 
17. 
Can I submit multiple claims if I have more than one Financial Account 
that I connected through Plaid? ............................................................. 9 
18. 
Can I submit multiple claims if I connected more than one app or 
service to my Financial Account? ........................................................ 10 
19. 
What happens if my claim is not accepted? ......................................... 10 
20. 
When and how will I receive the benefits I claim from the Settlement? 10 
21. 
What happens if my contact information changes after I submit a 
Claim?.................................................................................................. 10 
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What this Notice Contains
(continued) 
Page
This Settlement affects your legal rights even if you do nothing.  
Questions?  Go to www.PlaidSettlement.com or call 855-645-1115. 
- 4 - 
LEGAL RIGHTS RESOLVED THROUGH THE SETTLEMENT ............................... 10 
22. 
What am I giving up to stay in the Settlement Class? .......................... 10 
OBJECTING TO THE SETTLEMENT ...................................................................... 11 
23. 
If I don’t like the Settlement, how do I tell the Court? ........................... 11 
24. 
What is the difference between objecting and excluding myself? ........ 12 
25. 
Do I need to attend the Final Approval Hearing if I file an objection? .. 12 
FINAL APPROVAL HEARING ................................................................................. 12 
26. 
When and where will the Court decide whether to approve the 
Settlement? .......................................................................................... 12 
27. 
Do I have to come to the hearing? ....................................................... 13 
28. 
May I speak at the hearing? ................................................................. 13 
EXCLUDING YOURSELF FROM THE SETTLEMENT ............................................ 13 
29. 
How do I exclude myself from the Settlement? .................................... 13 
30. 
If I do not exclude myself, can I sue Plaid for the same thing later? .... 14 
31. 
If I exclude myself, am I still represented by Class Counsel? .............. 14 
DOING NOTHING ..................................................................................................... 14 
32. 
What happens if I do nothing? ............................................................. 14 
GETTING MORE INFORMATION ............................................................................ 14 
33. 
How do I get more information? ........................................................... 14 
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-1-
BACKGROUND INFORMATION 
1.
Why is there a notice? 
A Court authorized this notice because you have a right to know how the proposed Settlement 
may affect your rights.  This notice explains the nature of the litigation, the general terms of the 
proposed Settlement, and what it may mean to you. This notice also explains the ways you may 
participate in, or exclude yourself from, the Settlement. 
2.
What is this litigation about? 
The complaint in this case alleges that Plaid took certain improper actions by obtaining log-in 
credentials to user’s financial accounts through a user interface called Plaid Link that the 
complaint alleges was designed to have the look and feel of the user’s bank account login screen, 
when in fact the username and password were actually being provided to Plaid, and obtaining 
more financial and other data than was authorized or needed by a user's app.  The time period at 
issue is January 1, 2013 to November 19, 2021. 
Plaid enables connections between a user’s financial account and approximately 5,000 mobile 
and web-based apps that consumers use to make payments, transfer money, pay bills, manage 
their personal finances, make investments, and apply for loans, among other finance-related 
activities.  For examples of the types of apps that use Plaid, you can review Plaid’s website at 
www.plaid.com (including https://plaid.com/discover-apps/) or you can refer to Paras. 3 and 4 of 
the Plaintiffs’ Consolidated Amended Complaint, available at www.PlaidSettlement.com.
To confirm whether specific apps or services that connected to your financial account(s) used 
Plaid for the account connections, you can run a search on the Settlement website at 
www.PlaidSettlement.com.
The lawsuit was brought on behalf of the individuals who allegedly believed based on the design 
of Plaid Link that they were providing login credentials directly to their banks, and/or whose 
accounts at financial institutions Plaid accessed using the user’s login credentials and connected 
to a web-based or mobile payment or money transfer app.  Plaid denies any wrongdoing and all 
of the allegations in the lawsuit; no court or other entity has made any findings against Plaid nor 
any determination that the law has been violated.  
The current complaint filed in this litigation, which describes the specific legal claims alleged by 
the Plaintiffs and the relief sought, is available on the Settlement Website, at 
www.PlaidSettlement.com. You can also find a copy of the Court’s order on Plaid’s motion to 
dismiss the Plaintiffs’ legal claims, which sustained some claims and dismissed others, on the 
Settlement Website at www.PlaidSettlement.com.
3.
Who is the defendant in the lawsuit? 
The Defendant is Plaid Inc., a financial technology corporation.  Plaid is a Delaware corporation 
with its principal place of business in San Francisco, California.  You can learn more about Plaid 
at www.plaid.com.
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4.
Why is this a class action? 
In a class action, one or more people file a lawsuit to assert legal claims on behalf of themselves 
and other persons who have experienced the same or similar circumstances.  Here, eleven 
people who are proposed Class Members filed class action complaints and serve as named 
Plaintiffs and “Class Representatives” in the consolidated amended lawsuit.  In this capacity, they 
represent the interests of all the Class Members.   
Even if you have not filed your own lawsuit against Plaid regarding the allegations described in 
this notice, if you are a Class Member, this Settlement still affects you because the Settlement 
applies to all Class Members. 
5.
Why is there a settlement? 
The Court has not decided in favor of Plaintiffs or Plaid on the ultimate merits of Plaintiffs’ claims. 
Instead, both sides agreed to a Settlement.  Settlements avoid the costs and uncertainty of a trial 
and appeals, while providing benefits to Class Members when the Settlement becomes final.  
Class Representatives and the attorneys for the Class (“Class Counsel,” see Question 10) believe 
that the Settlement is in the best interests of the Class Members. 
CLASS MEMBERSHIP 
6.
Who is part of the Settlement? 
You are a Class Member, and you are affected by this Settlement, if you are a United States 
resident and:  
(1) own or owned one or more “Financial Accounts” (see definition 
in Question #7);  
(2) Plaid (a) accessed your Financial Account; or (b) obtained your 
Financial Account login credentials, between January 1, 2013 and 
November 19, 2021; and  
(3) You were a United States resident at the time (2)(a) or (b) 
occurred.  See Questions 7, 8, and 9 for more information about 
these terms. 
The following entities and individuals are not Class Members:  
 
Plaid and any and all of its predecessors, successors, assigns, parents, 
subsidiaries, 
affiliates, 
directors, 
officers, 
employees, 
agents, 
representatives, and attorneys, and any and all of the parents’, subsidiaries’, 
and affiliates’ present and former predecessors, successors, assigns, 
directors, officers, employees, agents, representatives, and attorneys; 
 
Any judicial officer presiding over the Action, or any member of his or her 
immediate family or of his or her judicial staff; and 
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-3-
Any individual who meets the class definition and who timely and validly 
excludes themselves from the Settlement.
7.
What does “Financial Account” mean in the Settlement?  
“Financial Account” means 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 
financial technology 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. A Financial Account does not include an account that was connected, or for which 
credentials were provided, exclusively through an OAuth Process or Managed OAuth Process. 
“Managed OAuth Process” means a process through which Plaid obtains login credentials in order 
to secure an access token pursuant to a formal agreement with the applicable financial institution 
and does not store those login credentials.
“OAuth Process” means a process through which Plaid redirects an end user to the financial 
institution’s domain to enter their login credentials and does not obtain login credentials for the 
end user.
8.
What is Plaid Link?  
“Plaid Link” means a consumer-facing interface developed by Plaid, as incorporated in mobile or 
web-based applications or services, that guides an end user through the process of linking a 
financial institution account to the application or service via Plaid.  
The Complaint in this case alleges that Plaid authenticates app users’ bank accounts through 
methods that are different from other methods of authenticating bank accounts because it is 
“instant,” and does not require “micro-deposits” where the user returns to verify the amount of 
small deposits made to their accounts in order to verify that they own the account.  In a Plaid Link 
interface, the user is prompted to input their bank username and password in order to verify the 
account.
You can see examples of historical versions of Plaid Link on the Settlement website, at 
www.PlaidSettlement.com, and at pages 9-10 and 21-25 of the Complaint, available on the 
Settlement website, at www.PlaidSettlement.com.  You can also check whether apps or services 
that you connected to your financial account used Plaid for the connection by searching on the 
Settlement website, at www.PlaidSettlement.com.
9.
How do I know whether I am a member of the Class?  
If you received a Notice of this Settlement by mail or email, you have been identified by the 
Settlement Administrator as a Class Member. If you did not receive a Notice by mail or email, 
you may still be a Class Member.  
You can check whether apps or services that you connected to your financial account used Plaid 
for the connection by searching on the Settlement website, at www.PlaidSettlement.com.  You 
can see examples of historical versions of Plaid Link on the Settlement website, at 
www.PlaidSettlement.com, and at pages 9-10 and 21-25 of the Complaint, available on the 
Settlement website, at  www.PlaidSettlement.com.   
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-4- 
 
If you are still not sure whether you are a Class Member, you may visit the FAQs section of the 
Settlement website, at www.PlaidSettlement.com, or contact the Settlement Administrator by mail 
at In re Plaid, Inc. Privacy Litigation, c/o Settlement Administrator, 1650 Arch Street, Suite 2210, 
Philadelphia, PA 19103, or call the Settlement Administrator’s toll-free number at 855-645-1115 
for more information that may help you determine whether or not you are a Class Member.   
THE LAWYERS FOR CLASS MEMBERS 
10.
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.  If you want to be represented by your own 
lawyer, you may hire one at your own expense. 
You may contact Class Counsel using the following information:  
Rachel Geman 
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 
250 Hudson Street, 8th Floor  
New York, NY 10013-1413 
rgeman@lchb.com 
Shawn M. Kennedy 
HERRERA KENNEDY LLP 
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
skennedy@herrerakennedy.com 
Christopher J. Cormier 
BURNS CHAREST LLP 
4725 Wisconsin Avenue, NW, Suite 200 
Washington, DC 20016 
ccormier@burnscharest.com 
11.
How will Class Counsel be paid? 
Class Counsel will apply to the Court to be paid from the Settlement Fund, and any payment will 
be made only in the amount that is approved by the Court.  
Class Counsel will ask the Court to award up to $14.5 million for attorneys’ fees from the 
Settlement Fund (25% of the Settlement Fund).  Class Counsel will also ask the Court to approve 
Service Awards of up to $5,000 each for the eleven Class Representatives named in the complaint 
as an award for their service to the Settlement Class as Plaintiffs and Class Representatives 
($55,000 in total) out of the Settlement Fund.  In addition, Class Counsel will ask the Court to 
reimburse them out of the Settlement Fund for the expenses they reasonably incurred and will 
incur in litigating this case on behalf of Class Members (including amounts charged by the 
Settlement Administrator for settlement administration).  
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-5- 
 
The amount of the Settlement Fund that remains after the payment of all Court-approved 
attorneys’ fees, Service Awards, and reimbursement of expenses will be distributed to Class 
Members who have submitted valid claims for compensation and have not timely excluded 
themselves from the Settlement in a manner approved by the Court. 
Class Counsel and Plaid have not discussed the issue or amount of attorneys’ fees in their 
negotiations of this Settlement; Plaid has the right to oppose Class Counsel’s application for fees, 
reimbursement of expenses, and Service Awards to Class Representatives, and Class Members 
have the right to object.  The Court will decide the attorneys’ fees and expenses and Service 
Awards to be paid.  Any attorneys’ fees, expenses, or Service Awards approved by the Court will 
be paid from the $58 million Settlement Fund.   
Class Counsel’s application for attorneys’ fees, expenses, and Service Awards will be made 
available on the Settlement Website at www.PlaidSettlement.com before the deadline for you to 
comment on or object to the Settlement.  You can also request a copy of the application by 
contacting the Settlement Administrator at Questions@PlaidSettlement.com.
BENEFITS FOR CLASS MEMBERS 
12.
What nonmonetary benefits does the Settlement provide? 
The Settlement requires Plaid to: 
 
Delete certain data from Plaid systems; 
 
Inform Class Members of their ability to use Plaid Portal to manage the 
connections made between their financial accounts and chosen applications 
using Plaid and delete data stored in Plaid’s systems;
Continue to include certain disclosures and features in Plaid’s standard Link 
flow; 
 
Enhance disclosures about Plaid’s data collection practices, how Plaid uses 
data, and privacy controls Plaid has made available to users in Plaid’s End 
User Privacy Policy; 
 
Minimize the data that Plaid stores; and 
 
Continue to host a dedicated webpage with detailed information about Plaid’s 
security practices.  
Most of these requirements will be implemented no more than 180 days after the Court has 
entered a final judgment that has come into effect (i.e., the final judgment can no longer be 
appealed and has not been modified or reversed on appeal), and will apply for three years in the 
United States.  For a full list of non-monetary benefits, including those that were implemented or 
finalized, in part, after this lawsuit was initially filed, see paragraphs 52-70 of the Settlement 
Agreement, at www.PlaidSettlement.com.  A summary of these nonmonetary benefits of the 
settlement is provided below.  
Data Deletion from Plaid Systems
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-6- 
 
As part of the Settlement, Plaid will, to the extent not already deleted, delete the following data:  
Data retrieved as part of Plaid’s Transactions product, including information 
about account transactions, such as transaction date, amount, category, 
merchant, and location, for users that Plaid can reasonably determine did not 
connect an account to an application that requested Transactions data.  This 
means, for example, if you used an application that did not ask Plaid to collect 
data about transactions you made, but Plaid accessed that data anyway, 
then Plaid will delete that data from its systems. 
 
In accordance with its internal data deletion policies, data for users that Plaid 
is aware it no longer has valid means that can be used to authenticate with 
the bank.  This means, for example, if Plaid determines that the password it 
obtained for a particular bank account has changed, or that the account has 
been closed, Plaid will delete the data associated with that account from its 
systems. 
 
It is important to understand that Plaid is not required to delete data retrieved 
as part of another Plaid product for which you currently have an active 
connection.  For example, if you connect an app that requests data from a 
particular Plaid product and Plaid collects that requested data for that app, 
such data will not be deleted even if it overlaps with other data that would 
otherwise be covered by this section. 
Plaid Portal 
By creating a Plaid Portal account, users, including Class Members, can view and manage the 
connections between financial accounts and chosen applications made using Plaid, and delete 
data stored in Plaid’s systems.  Currently, the website for Plaid Portal is my.plaid.com (see 
Question 15). 
As part of the Settlement, Plaid will provide a prominent reference to Plaid Portal on its website 
homepage (www.plaid.com), along with a link to Plaid Portal and a plain-language description of 
the user controls available through Plaid Portal.  Plaid will also take reasonable commercial efforts 
to send periodic email reminders to Plaid Portal account holders generally describing the user 
controls available in Plaid Portal, including the ability to disconnect applications from their financial 
accounts and delete data stored in Plaid’s systems.
Clear Disclosures at the Time of Account Connection  
As part of the Settlement, Plaid has committed to ensuring that Plaid’s standard Link flow includes 
the following:   
 
The credentials pane, meaning the page where users enter their financial 
account username and password, will continue to explain that the credentials 
are being “provided to Plaid.”  
 
The background color of the credentials pane will not utilize the color scheme 
associated with a specific financial institution for that financial institution. 
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A separate pane will continue to a) refer expressly to Plaid and explain that 
Plaid is used to link the user’s accounts, b) include a conspicuous link to 
Plaid’s End User Privacy Policy, and c) require the user to agree to Plaid’s 
End User Privacy Policy by taking clear affirmative action (e.g., by clicking 
“Continue”).
In addition, Plaid has made the following changes that were implemented or finalized, in part, 
after the filing of the initial class action complaint in this litigation: 
The addition of the following language to the credentials pane of Plaid’s 
standard Link flow for relevant products: “By providing your [financial 
institution name] credentials to Plaid, you’re enabling Plaid to retrieve your 
financial data.”
The addition of a link entitled “Why is Plaid involved?” to the institution 
selection pane of Plaid’s standard Link flow, which opens to the following 
text: “Plaid lets you connect your financial accounts to apps and services.  
This is a service provided by Plaid.  The connection Plaid provides to your 
financial account(s) does not imply affiliation with any financial institution.”
Minimizing the Data Plaid Stores
As part of the Settlement, Plaid will minimize the amount of information that it stores from users’ 
financial accounts. 
With respect to data retrieved from users’ financial accounts, subject to 
certain limitations such as for compliance with applicable law, Plaid will only 
store the categories of data for the Plaid product(s) that the user’s application 
specifically requests from Plaid or that are necessary for Plaid to offer its 
services, unless the user has expressly consented to the retrieval of 
additional data. 
 
Plaid will use its best efforts to continue to inform the applications that use 
Plaid about its /item/remove endpoint, which is a means for those 
applications to inform Plaid that a user has terminated their account with the 
application, which then terminates the application’s access to data from 
Plaid, and may lead to data deletion from Plaid’s systems (if such data is not 
actively used by another application). 
Enhancing Disclosures about What Plaid is and Does 
As part of the Settlement, in addition to the disclosures and controls discussed above, Plaid will 
enhance its End User Privacy Policy (EUPP) to provide more detailed information about Plaid’s 
data collection, storage, use, sharing, and deletion practices.  For all Plaid products, including 
newly launched products, the EUPP will: 
 
Provide more detail about the categories of personal information Plaid 
collects from users’ financial accounts for each Plaid product, including a 
plain-language list of the categories of personal information Plaid collects 
and a plain-language statement of the general reasons the categories are 
collected. 
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Provide more detail about how Plaid uses data, including by providing, for 
each category of personal information that Plaid collects about users, the 
categories of sources of the personal information, the categories of uses for 
which Plaid collects the information, and the categories of parties, if any, with 
whom Plaid shares the information (for example, the developer of the user’s 
application). 
 
Provide a plain-language explanation of Plaid’s deletion and retention 
practices related to personal information. 
 
Provide a dedicated section explaining in plain-language terms the privacy 
controls Plaid has made available to users (e.g., “Privacy Control Section”).
In addition, Plaid launched certain consumer education pages after this litigation was filed, which 
describe 
Plaid’s 
data 
practices, 
such 
as 
https://plaid.com/how-we-handle-data/;
https://plaid.com/why-is-plaid-involved/; and https://plaid.com/discover-apps/.
More details about the changes that Plaid has made or agreed to make as a result of the 
Settlement are available in Paragraphs 52-70 of the Settlement Agreement, which is available on 
the Settlement Website, at www.PlaidSettlement.com.   
13.
What monetary benefits 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 and 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.  Class Members will be 
able to choose whether to receive their payment via PayPal, Venmo, ACH Transfer, or paper 
check.  Because the final payment amount cannot be calculated before all claims for 
compensation are received and verified, it will not be possible to provide an estimate of the 
payment amount before the deadline to file claims.   
In the event that any PayPal, Venmo, or ACH Transfer transfers fail or any paper checks are 
uncashed, the Settlement Administrator will make a second pro rata payment based on the non-
transferred funds to Class Members who filed valid claims and provided valid electronic payment 
information.  In the event that the number of Class Members who file valid claims would result in 
either an initial or secondary pro rata payment amount that the Parties, in consultation with the 
Settlement Administrator and a neutral mediator, determine is too small to economically distribute 
to Class Members, Class Counsel will seek Court approval to distribute the funds through a next-
best alternative, to one or more non-profit organizations that have a track record of addressing 
consumer financial privacy and internet technology concerns, who will commit to use any funds 
they receive for activities intended to benefit all Class Members.  The proposed non-profit 
organizations, also known as the proposed “Cy Pres Recipients,” are Privacy Rights 
Clearinghouse and Consumer Reports.  
14.
Will all Class Members who file claims receive the same amount? 
Yes.  Each Class Member who submits a valid claim for compensation will be paid one equal pro 
rata share from the Net Settlement Fund (the $58 million Settlement Fund minus any award of 
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attorneys’ fees and expenses, settlement administration costs, and Service Awards for the Class 
Representatives).  Each Class Member is entitled to submit only one claim for compensation from 
the Net Settlement Fund regardless of the number of applications they have connected to financial 
accounts via Plaid, or the number of their financial accounts that have been connected to apps.  
Because the final payment amount cannot be calculated before all claims for compensation are 
received and verified, it is not possible to provide an estimate of the payment amount before the 
deadline to file claims.   
15.
How do I control who has access to my data? 
You can create a Plaid Portal account to view and manage the connections you’ve made using 
Plaid and delete data stored in Plaid’s systems.  Currently, Plaid Portal is available at 
my.plaid.com.  Pursuant to the Settlement, Plaid will also post a link to the Plaid Portal on its 
website, www.plaid.com, where you can create or access your Plaid Portal account.   
After creating a Plaid Portal account, you can use the Portal to securely manage the connections 
between your financial accounts and chosen applications made using Plaid.  Plaid Portal allows 
you to see the types of data shared with each app, disconnect apps from your financial accounts 
any time, and delete your data stored in Plaid’s systems.
HOW TO FILE A CLAIM 
16.
How do I file a claim for compensation? 
To claim a cash payment, you need to file a claim form.  There are two options to file your claim: 
(1) File Online: You may fill out and submit the claim form online at 
www.PlaidSettlement.com.  This is the quickest way to file a claim. 
(2) File by Mail: Alternatively, you can download a hard copy of the 
claim form (available at www.PlaidSettlement.com/important-
documents), or ask the Settlement Administrator to mail a claim 
form to you by calling 855-645-1115. Fill out your claim form, and 
mail it (including postage) to: In re Plaid, Inc. Privacy Litigation, c/o 
Settlement Administrator, 1650 Arch 
Street, 
Suite 
2210, 
Philadelphia, PA 19103. 
The deadline to file a claim is April 28, 2022 (this is the last day to file online and postmark 
deadline for mailed claims).   
17.
Can I submit multiple claims if I have more than one Financial 
Account that I connected through Plaid? 
 
No.  Each Class Member may submit only one claim, even if they own multiple Financial Accounts 
that they connected through Plaid.   
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18.
Can I submit multiple claims if I connected more than one app or 
service to my Financial Account? 
No.  Each Class Member may submit only one claim, even if their Financial Account(s) were 
connected to multiple apps or services through Plaid.   
19.
What happens if my claim is not accepted? 
The Settlement Administrator may reject Claim Forms that are duplicates of another claim, are 
reasonably suspected to be fraudulent, or are submitted after the deadline.  The Settlement 
Administrator may also reject Claim Forms submitted by individuals it reasonably determines are 
not members of the Class.  Before rejecting a claim, the Settlement Administrator will notify the 
claimant and give the claimant two weeks from the date of notice to correct any deficiency.  
20.
 When and how will I receive the benefits I claim from the 
Settlement? 
Payments for valid claims will be made after the Settlement becomes final by the means 
designated on your claim form.  You may select payment via PayPal, Venmo, ACH Transfer, or 
paper check.  The Settlement will become final only if, and after, Final Approval is granted by the 
Court and any appeals to Final Approval of the Settlement are resolved.  This process may take 
longer than one year.  Please be patient. 
21.
What happens if my contact information changes after I submit a 
Claim? 
If, after you submit a claim form, you change your mailing address, email address, or the PayPal, 
Venmo, or ACH Transfer information provided on your claim form, it is your responsibility to inform 
the Settlement Administrator of your updated information.  You may do so by contacting the 
Settlement Administrator using the contact information in Question 33. 
LEGAL RIGHTS RESOLVED THROUGH THE SETTLEMENT 
22.
What am I giving up to stay in the Settlement Class?
If you do not exclude yourself from the Settlement Class, you will be releasing all of your legal 
claims relating to the allegations in the Plaintiffs’ complaint.  You may view the complaint on the 
Settlement Website at www.PlaidSettlement.com. 
The claims you are giving up are called “Released Claims,” and they are defined in paragraph 45 
of the Settlement Agreement.  You will be releasing the Released Claims against Plaid and any 
and all of its present or former predecessors, successors, assigns, parents, subsidiaries, affiliates, 
directors, officers, employees, agents, representatives, and attorneys, and any and all of the 
parents’, subsidiaries’, and affiliates’ present and former predecessors, successors, assigns, 
directors, officers, employees, agents, representatives, and attorneys, in connection with the 
Released Claims, when the Settlement becomes final.   
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By releasing your legal claims, you are giving up the right to file any type of legal action against, 
or seek further compensation from, Plaid and the other released individuals and entities listed 
above based on those claims.  If you are a Class Member, all of the decisions by the Court will 
bind you unless you exclude yourself from the Settlement (see Questions 29-31).  That means 
you will be bound to the terms of the Settlement and accompanying Court order, and cannot bring 
any type of legal action, or be part of another legal action against Plaid or the other entities listed 
in the paragraph above regarding the allegations in Plaintiffs’ complaint.  
Paragraph 45 of the Settlement Agreement defines the claims that will be released by Class 
Members who do not exclude themselves from the Settlement.  You can access the Settlement 
Agreement and read the details of the legal claims being released at www.PlaidSettlement.com.  
If you have any questions about what this means, you can contact Class Counsel or the 
Settlement Administrator (see Question 10). 
OBJECTING TO THE SETTLEMENT 
23.
If I don’t like the Settlement, how do I tell the Court?
If you do not exclude yourself from the Settlement, you can ask the Court to deny approval by 
filing an objection.  You can object to any aspect of the Settlement, to Class Counsel’s request 
for attorneys’ fees and expenses, or to the request for Service Awards.  
Objecting to the Settlement means asking the Court to deny approval to the Settlement.  You 
can’t ask the Court to order a larger monetary payment from Plaid as part of the Settlement, or to 
change the commitments Plaid has agreed to make under the Settlement.  The Court can only 
approve or reject the Settlement the parties have proposed.  If the Court denies approval of the 
Settlement, Plaid will not be required to comply with the terms of the Settlement Agreement, no 
Settlement payments will be sent out, and the lawsuit will continue.  If that is what you want to 
happen, you must object. 
If you chose to make an objection, it must be in writing and contain the following: 
a.
The name and case number of this lawsuit (In re Plaid Inc. Privacy 
Litigation, the case number is 4:20-cv-03056); 
b.
The basis for believing that you are a Class Member;  
c.
Your full name and mailing address, and email address or telephone 
number; 
d.
All reasons for your objection; 
e.
Whether you intend to appear at the Final Approval Hearing, either in 
person or through an attorney representing you, and, if through an 
attorney, the attorney’s name, address, and phone number;
f.
Your handwritten or electronically imaged written (e.g., “DocuSign”) 
signature.  An attorney’s signature, or a typed signature, is not sufficient.
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To be considered by the Court, your objection must be either (1) filed at any location of the United 
States District Court for the Northern District of California on or before March 4, 2022, or (2) 
mailed, postmarked no later than March 4, 2022, to the following recipient: 
Clerk of Court 
United States District Court for the Northern District of California 
1301 Clay Street 
Oakland, CA 94612
24.
What is the difference between objecting and excluding myself?
You object to the Settlement when you disagree with some aspect of the Settlement and think the 
Court should not give Final Approval to the Settlement.  An objection, like a comment, allows your 
views to be heard in Court. 
Excluding yourself from the Settlement means that you are no longer a Class Member and don’t 
want the Settlement (including monetary payments) to apply to you.  Once you are excluded, you 
lose any right to object to any aspect of the Settlement because the case no longer affects you. 
25.
Do I need to attend the Final Approval Hearing if I file an 
objection? 
If you file a timely written objection, you may, but are not required to, appear at the Final Approval 
Hearing, either in person or through your own attorney.  If you appear through your own attorney, 
you are responsible for hiring and paying that attorney. 
FINAL APPROVAL HEARING 
26.
When and where will the Court decide whether to approve the 
Settlement? 
The Court will hold the Final Approval Hearing at 1 p.m. on May 12, 2022 in Courtroom 4 (3rd 
Floor) of the United States Courthouse, 1301 Clay Street, Oakland, CA 94612.  The hearing may 
be postponed to a different date or time or location without notice.  The hearing may be scheduled 
to occur telephonically or by videoconference.  Please check www.PlaidSettlement.com, or Judge 
Donna M. Ryu’s Calendar (available at https://apps.cand.uscourts.gov/CEO/cfd.aspx?71BQ) for 
any updates about the Settlement or the Final Approval Hearing.  If the date or time, or the format, 
of the Final Approval Hearing changes, an update to the Settlement Website or the Court’s 
Calendar is the only way you will be informed of the change. 
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 (see Question 23).  The Court may also consider Class Counsel’s application for 
attorneys’ fees, expenses and for 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.   
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-13- 
 
27.
Do I have to come to the hearing?
No.  Class Counsel will answer any questions the Court may have.  You may attend at your own 
expense if you wish.  If you submit a written objection, you may, but you do not have to, come to 
Court to talk about it.  As long as you submitted your written objection on time, the Court will 
consider it.  You may also pay your own lawyer to attend, but it is not required. 
28.
May I speak at the hearing? 
At that hearing, the Court will at its discretion hear any objections and arguments concerning the 
fairness of the Settlement. 
You may attend the hearing, but you do not have to.  As described above in response to Question 
23, you may speak at the Final Approval Hearing if (a) you have mailed your written comment or 
objection to the Court on or before the postmark deadline, and (b) you identified in your comment 
or objection whether you intend to appear at the Final Approval Hearing. 
You cannot speak at the hearing if you exclude yourself from the Settlement Class. 
EXCLUDING YOURSELF FROM THE SETTLEMENT 
29.
How do I exclude myself from the Settlement?
If you want to keep the right to sue or continue to sue Plaid or the other released entities (see 
Question 22) based on claims this Settlement resolves, you must exclude yourself from the Class 
(sometimes called “opting out”).
To exclude yourself from the Settlement, you must send a letter by mail to the Settlement 
Administrator saying that you wish to do so.  Your exclusion letter must include: 
a.
The name and case number of this lawsuit (In re Plaid Inc. Privacy 
Litigation, case number is 4:20-cv-03056); 
b.
Your full name and mailing address, email address, or telephone number; 
c.
The words “Notification of Exclusion” or a statement that you want to be 
excluded from the Settlement; and 
d.
Your handwritten or electronically imaged written (e.g., “DocuSign”) 
signature.  An attorney’s signature, or a typed signature, is not sufficient.
You must mail your exclusion letter, postmarked no later than March 4, 2022, to: 
In re Plaid Inc. Privacy Litigation
Attn: Exclusion 
P.O. Box 58220 
Philadelphia, PA 19102 
You cannot exclude yourself by mailing a notification to any other location or after the deadline of 
March 4, 2022.  You cannot exclude yourself by telephone or by email.  Your exclusion letter 
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must be signed by you, personally, and not your lawyer or anyone else acting on your behalf.  
“Mass” or “class” opt-outs made on behalf of multiple persons or classes of persons will be 
deemed invalid. 
30.
If I do not exclude myself, can I sue Plaid for the same thing later?
No.  Unless you exclude yourself, you give up the right to sue Plaid for the claims that this 
Settlement resolves. 
31.
If I exclude myself, am I still represented by Class Counsel? 
No.  Class Counsel represents the members of the Settlement Class.  If you exclude yourself 
from the Settlement Class, you are not represented by Class Counsel. 
DOING NOTHING 
32.
What happens if I do nothing?
If you do nothing, and if the Settlement becomes final, you will be part of the Settlement Class 
and will receive the payment(s) described above in Question 13.  You will give up your rights to 
sue Plaid (or continue to sue) or related entities (see Question 22) for claims arising out of or 
related to the allegations in the Plaintiffs’ complaint.
GETTING MORE INFORMATION 
33.
How do I get more information? 
This notice summarizes the proposed Settlement.  More details are in the Settlement Agreement 
itself.  You can get a copy of the Settlement Agreement, view other case documents, and get 
additional information, updates, and answers to Frequently asked Questions, by visiting 
www.PlaidSettlement.com.   
All of the case documents that have been filed publicly in this case are also available online 
through the Court’s Public Access to Court Electronic Records (PACER) system at 
https://ecf.cand.uscourts.gov.  This case is called In re Plaid Inc. Privacy Litigation, and the case 
number is 4:20-cv-03056.  You may obtain case documents by visiting the office of the Clerk of 
the Court for the United States District Court for the Northern District of California, San Francisco 
Division, between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.  
You can also get additional information or request a copy of the Settlement Agreement by calling 
toll-free 
855-645-1115 
or 
writing 
to 
the 
Settlement 
Administrator 
via 
email 
to 
Questions@PlaidSettlement.com or by mail to In re Plaid, Inc. Privacy Litigation, c/o Settlement 
Administrator, 1650 Arch Street, Suite 2210, Philadelphia, PA 19103. 
PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE 
ABOUT THIS SETTLEMENT.
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Exhibit K 
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Exhibit L 
Case 4:20-cv-03056-DMR     Document 159     Filed 02/01/22     Page 66 of 76

t'\
Friday, January 14,2022
T)m|[2^
In re Plaid Inc. Privacy Litigation, the cavSe number is 4:20-cv-03056 
^
Notice ID: PLD1007509370 
filed
Confirmation Code: 5040A53475 
,.MN 24 2022
To Whom It May Concern, 
CLPRk, U5 nicTD./v» ^
I received a settlement email about the case against Plaid Inc.
I do not intend to appear in court. I just want to make a comment on something that 1 object to in
the case.
In the case it states "....obtained log-in credentials (username and password) through its user
^
 interface, known as "Plaid Link," which had the look andfeel of the user's own bank account
login screen, when users were actually providing their login credentials directly to Plaid."
Plaid's interface did not mimic or did not have the look and feel of my bank's account login
screen. The interface had Plaid's colors and logo and did not have any information or colors
related to my bank's login page. Phishing scams purposefully mimic a bank's login page, but
Plaid's interface did not do this.
Sin^rely,
Richard Laven
5874 Woodbriar Or NE
Belmont, MI 49306
rick@laven.net
616-551-9554
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Exhibit M 
Case 4:20-cv-03056-DMR     Document 159     Filed 02/01/22     Page 69 of 76

FILED 
Mark B. Busby
CLERK, U.S. DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND
Jan 26 2022
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