Court filing
Supplemental Notice Compliance Declaration Of Steven Weisbrot On Behalf Of Angeion Group,… — Plaid Privacy (Dkt. 174.1)
Filed May 9, 2022 in Plaid Privacy; one of 174 filings from this case.
Record facts
| Court | U.S. District Court for the Northern District of California |
|---|---|
| Filed | 2022-05-09 |
U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 174-1 · 2022-05-09 · Docket on CourtListener
Full text
SUPPLEMENTAL 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
SUPPLEMENTAL 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) (“Notice
Plan Declaration”).
2.
The purpose of this Declaration is to provide the Court with an updated 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”) and
additionally in response to the Court’s May 4, 2022 Order to Submit Updated Evidence
Regarding Claim Submissions and Requests for Exclusion.
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).
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 1 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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SUMMARY OF THE NOTICE PROGRAM
4.
The Notice Plan approved by the Court provided individual direct notice to all reasonably
identifiable Class Members via email or mail, combined with a strategic media campaign. The
Notice Plan also included the implementation of a dedicated website and a toll-free telephone line
where Class Members could learn more about their rights and options pursuant to the terms of the
Settlement.
DIRECT NOTICE
Email Notice
5.
As described in the Notice Compliance Declaration of Steven Weisbrot on Behalf of
Angeion Group, LLC (ECF No. 156-1) (“Notice Compliance Declaration”), Angeion caused
email notice to be sent to 60,271,546 Settlement Class Members between January 7, 2022 and
January 28, 2022. As of February 3, 2022, approximately 1,484,447 email notices could not be
delivered. Of the emails sent, approximately 7,058,714 were opened.
6.
Regarding email noticing, Angeion institutes best practices in email dissemination to both
increase deliverability and to minimize the appearance of spam. However, there are certain things
that are out of Angeion’s control, such as individual user’s spam settings, which range from
virtually non-existent, to extremely strenuous, depending on personal preference. Likewise, many
times these settings are set at the Enterprise level, or even, at the ISP level. We do not have a way
to alter those settings to ensure direct inbox delivery, but we use a bevy of tools that comport with
industry best practices to maximize the likelihood of delivery such as ensuring there are no
attachments, including an unsubscribe link, using a summary notice rather than the full long form
notice, sending the notice from an actual, valid and operational email address, etc.
Custom Social Media Notice
7.
As described in my Notice Compliance Declaration, on or about January 28, 2022,
Angeion caused the custom social media campaign to commence to Class Members for which an
email address was provided by Plaid. The custom social media campaign concluded on March 14,
2022, delivering approximately 15,836,361 impressions.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 2 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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Mailed Notice
8.
As described in my Notice Compliance Declaration, Angeion caused a postcard notice to
be mailed to 650,669 Class Member records between January 21, 2022 and January 24, 2022. As
of April 28, 2022, a total of 62,232 postcards were returned by the USPS as undeliverable.
Postcards returned to Angeion by the USPS with a forwarding address were re-mailed to the new
address provided by the USPS. Postcards returned to Angeion by the USPS without a forwarding
address were subjected to address verification searches (“skip traces”) in an attempt to locate
updated address information. In total, 44,782 postcards were re-mailed because of the above-
described efforts.
MEDIA NOTICE
Digital and Social Media Notice
9.
As described in my Notice Compliance Declaration, 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. The programmatic digital banner ad
campaign concluded on February 27, 2022, delivering approximately 205,547,975 impressions.
10.
As described in my Notice Compliance Declaration, 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. The social media campaign
concluded on March 9, 2022, delivering approximately 164,089,656 impressions.
Paid Search Campaign
11.
As described in my Notice Compliance Declaration, on or about January 25, 2022,
Angeion implemented a paid search campaign to help drive Settlement Class Members who were
actively searching for information about the Settlement to the dedicated Settlement Website. The
paid search campaign concluded on March 17, 2022, delivering approximately 135,158
impressions.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 3 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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Conclusion
12.
According to my Notice Plan Declaration, the notice plan was designed to deliver
approximately 326 million impressions, with an approximate 80.40% reach and an average
frequency of 3.62. The Media Notice campaign concluded with approximately 369,772,789
impressions, which resulted in an approximate reach of 82.96% and an average frequency of 3.96.
REMINDER NOTICE
Email Notice
13.
Subsequent to the initial email notices being sent as described in my Notice Compliance
Declaration, Angeion analyzed the action of the Settlement Class Members. After identifying the
Settlement Class Members who submitted a claim, those who opted out of or objected to the
Settlement, those who requested to no longer be contacted, and additionally after determining the
records in which the initial email notice resulted in a hard bounce, Angeion identified 58,942,361
records remaining in which contact had not been made. Thus, between April 13, 2022, and April
27, 2022, at the request of Plaintiffs’ counsel, Angeion caused a reminder email notice to be sent
to these 58,942,361 Settlement Class Members. As of April 28, 2022, approximately 797,977 of
the 58,942,361 reminder email notices could not be delivered. Of the emails sent, approximately
4,675,116 were opened. A true and accurate copy of the reminder email notice is attached hereto
as Exhibit A.
Digital and Social Media Notice
14.
Although not required by the Preliminary Approval Order, on or about April 14, 2022, at
the request of Plaintiffs’ counsel, Angeion implemented an additional programmatic digital
banner ad campaign which was specifically designed to remind the Target Audience about the
upcoming claims filing deadline and to drive them to the Settlement Website. The reminder
programmatic digital banner ad campaign concluded on April 27, 2022, delivering approximately
31,665,017 impressions. True and accurate copies of the reminder digital banner ads are attached
hereto as Exhibit B.
15.
Additionally, although not required by the Preliminary Approval Order, on or about April
13, 2022, at the request of Plaintiffs’ counsel, Angeion implemented an additional social media
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 4 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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campaign utilizing the platforms Facebook and Instagram to remind Settlement Class Members
about the upcoming claims filing deadline and to drive them to the Settlement Website. The
reminder social media campaign concluded on April 27, 2022, delivering approximately
50,655,064 impressions. True and accurate copies of the reminder social media ads are attached
hereto as Exhibit C.
Paid Search Campaign
16.
On or about April 13, 2022, Angeion implemented a reminder paid search campaign to
help drive Settlement Class Members who were actively searching for information about the
Settlement to the Settlement Website. The reminder paid search campaign concluded on April 27,
2022, delivering approximately 21,587 impressions.
Summary
17.
Regarding both the initial and reminder media campaigns, Angeion delivered
approximately 452,114,457 impressions in total. These can be further broken down by media
tactic. Specifically, the programmatic digital banner ad campaigns served approximately
237,212,992 impressions, whereas the social media campaigns served approximately 214,744,720
impressions and the paid search campaigns served approximately 156,745 impressions.
SETTLEMENT WEBSITE, TOLL-FREE HOTLINE AND CLAIMANT CONTACT
18.
As described in my Notice Compliance Declaration, on or about January 6, 2022, Angeion
established the following website devoted to this Settlement: www.PlaidSettlement.com
(“Settlement Website”). As of May 4, 2022, the Settlement Website has had 8,122,385 page
views and 4,248,242 sessions, which represents the number of individual sessions initiated by all
users.
19.
As described in my Notice Compliance Declaration, on or about January 4, 2022, Angeion
established the following toll-free line dedicated to this case: 1-855-645-1115. As of May 4,
2022, the toll-free number has received approximately 19,928 calls, totaling 88,254 minutes.
Angeion also received 635 voicemail messages.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 5 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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20.
Angeion estimates approximately 1,000,000 claimants reached the Settlement website as a
result of a direct method such as clicking a link in the email notices or typing in the url
www.PlaidSettlement.com.
21.
Angeion also received over 15,000 email inquiries related to the Settlement.
CLAIM FORM SUBMISSIONS
22.
The deadline for members of the Settlement Class to submit a claim form was April 28,
2022. As of May 4, 2022, Angeion has received approximately 1,256,738 claim form
submissions. Further, Angeion was contacted by certain claimants who wished to file a claim
after the deadline. Angeion provided a paper claim form for those individuals and indicated they
could submit the form to us via email or by mail, and that all late received claim forms are subject
to the Court and the parties’ approval. As of the date of this declaration, Angeion has received
approximately 100 late claim forms. The claim form submissions received thus far are still
subject to final audits, including the full assessment of each claim’s validity and a review for
duplicate submissions.
23.
Considering the Settlement Class consists of approximately 98,000,000 Class Members,
the estimated claims rate is 1.28%.
REQUESTS FOR EXCLUSION AND OBJECTIONS TO THE SETTLEMENT
24.
The deadline for members of the Settlement Class to request exclusion from the
Settlement was March 4, 2022. As of May 4, 2022, Angeion has received 1,768 timely requests
for exclusion from the Settlement and 7 late requests for exclusion, some of which were recently
submitted. Lists containing the names of the individuals requesting exclusion are attached hereto
as Exhibit D and E, respectively.
25.
The deadline for members of the Settlement Class to object to the Settlement was March
4, 2022. As of May 4, 2022, Angeion was made aware of five timely objections to the Settlement,
which were filed with the Court as reflected on the docket (ECF Nos. 154, 155, 158, 161 and
162). The filed objections are attached hereto as Exhibit F, G, H, I, J, respectively. As previously
described in my Notice Compliance Declaration, Angeion reached out to the Class Member who
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 6 of 132
SUPPLEMENTAL NOTICE COMPLIANCE DECLARATION OF
STEVEN WEISBROT ON BEHALF OF ANGEION GROUP, LLC
MASTER DOCKET NO. 4:20-cv-03056-DMR
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submitted the second objection (ECF No. 155), to assist him in addressing the technical issues
identified in his letter.
26.
Angeion was made aware of one late objection to the Settlement, which was filed with the
Court as reflected on the docket (ECF No. 171 and also 173 by the same individual). The late
filed objection is attached hereto as Exhibit K.
CONCLUSION
27.
It remains my professional opinion that the Notice Plan provided full and proper notice to
members of the Settlement Class before the claims, opt-out, and objection deadlines. The
secondary email, programmatic banner ad, and search campaigns bolstered the previously
approved notice plan and resulted in additional claims. Moreover, it remains my opinion that the
Notice Plan was the best notice that was 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: May 9, 2022
_________________________________
STEVEN WEISBROT
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 7 of 132
Exhibit A
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 8 of 132
1
Notice ID: PL2233
Confirmation Code: 34334
Plaid Privacy Litigation Settlement – Last Chance to Claim Your Settlement Payment
This is a Legal Notice. This is not an advertisement.
You may be eligible to claim a payment in the class action Settlement titled In re Plaid, Inc.
Privacy Litigation.
You are receiving this courtesy email to remind you the deadline to submit a claim in this action
is April 28, 2022. If you have already filed a claim, you do not need to file one again. This
reminder notice has been sent to ensure you are aware of the approaching claims filing deadline.
If you are a Class Member and would like to be eligible for a payment, you must submit a valid
claim form online or mail a claim form postmarked NO LATER THAN April 28, 2022.
Claim forms may be submitted online by clicking here: www.PlaidSettlement.com.
You can also click the video link to file your claim or to hear instructions on how to submit a
claim.
From:
Settlement Administrator <donotreply@plaidsettlement.com>
Sent:
To:
Subject:
Reminder: File Your Claim by 4/28 in the Plaid Privacy Class Action Settlement
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 9 of 132
2
You may also print a claim form from the Settlement website and mail it to the address on the
claim form ensuring it is postmarked by no later than April 28, 2022.
More About the Class Action Settlement
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:
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 10 of 132
3
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 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
1-855-645-1115 or emailing Questions@PlaidSettlement.com.
This notice is only a summary.
For more information visit www.PlaidSettlement.com or call 1-855-645-1115.
Unsubscribe
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 11 of 132
Exhibit B
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 12 of 132
If you entered
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soon. The last
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class action
settlement claim
is April 28, 2022.
Learn More
Document 174-1 File
6-DMR Document 174-1 Filed 05/09/2
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 22 of 132
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 23 of 132
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 24 of 132
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settlement claim
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 32 of 132
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 33 of 132
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 34 of 132
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 35 of 132
Have you used
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api:f Did you
enter your
bank login
information?
If so, you must
act soon. iTlie
last day to file
your class
action
settlement
claim is
28, 2022.
Learn More
Document 174-1 File
If you entered
your bank login
information to
connect your
financial
account( s) to
a fmtech app,
you must act
soon. The last
day to file your
class action
settlement claim
is April 28, 2022.
Learn More
Document 174-1 File
6-DMR Document 174-1 Filed 05/09/2
If you entered your bank login information to comect
yoot financial accoont{s) to a fintech app, you must act
soon. The last day to file )'(lllr class action sefflement
claim is April 28, 2022.
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6-DMR Document 174-1 Filed 05/09/2
If you entered your
bank login
information to
connect your
financial account(s)
to a fintech app,
you must act soon.
The last day to file
your class action
settlement claim
is April 28, 2022.
Learn More
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Exhibit C
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 41 of 132
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Angeion Group
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03056-DMR Document 174-1 Filed 05/09/22 P
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Angeion Group
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4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 43 o
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4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 45 o
Exhibit D
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 46 of 132
First Name
Last Name
1 DAVID
BENDER
2 CATHERINE
HARKER
3 MARK
RUSSELL
4 AUSTIN
SUNDARA
5 CHELSEA MICHELLE
POLIZZI
6 NINA
AAMODT
7 JODIE ELENA
WEBB
8 TIFFANY
JIANG
9 JOSEPH RYAN
LOBOSCO
10 SHARON L
AKINS
11 TORI
DEHAVEN
12 DEANGELLO
BRYANT
13 MEHRDAD
NIKNAMI
14 RODNEIL AHMAD
MITCHELL
15 DAVID
WHITMAN
16 BRANDON
BELL
17 JOHN
SWEET
18 DAVID
OH
19 JONATHAN
SKOWRONSKI
20 JERILYN
PHIPPENY
21 JIMMY
SEIBERLING
22 JENNIFER M
LOPEZ
23 ALAN R
HARRIS JR
24 WILSON
ZHAO
25 CAROL L
WEINFELD
26 VATALII
TERTYCHNYI
27 ALEKSANDRA
TERTYCHNAIA
28 JASEN C
LONG
29 DEEPAK
KUMAR
30 ANGELA K
MILLER
31 JOEL
SAENZ
32 VIVEK
SHAH
33 CHRISTOPHER B
SMITH
34 JEFFREY A
WILLIAMS
35 THMOMAS MORGAN
CAPE JR
36 BRANDON
RINGE
37 ALLISON
DOUGHTY
38 WILLIAM GARRETT
REARDON
39 KAJAL
VARMA
40 MARKUS
HERNANDEZ
41 TRISTDEN JAMES
VLATKOVICK
In re Plaid, Inc. Privacy Litigation
Timely Opt Outs
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 47 of 132
42 MELISSA
SMIDT
43 BETTY
ALVENDIA
44 MICHAEL DONALD
DAIGLE JR
45 CHARLESA
FLATTEN
46 JOSEPH
AKINTOLAYO
47 HYUN JAN
PARK
48 A J
REYES
49 ALEXANDER
MORALES
50 ANGELA
BARAJAS
51 BEN
SIMSUANGCO
52 CAITLIN
O'HARE
53 CANELA
GARCIA GALINDO
54 CHARLES
HAEUSSINGER
55 CRISTINA
WISEMAN
56 CRISTINA
WOMACK
57 CRYSTAL
WIBIER
58 DANIEL
SHAY
59 DIANA
STARR
60 DMITRY
ZUEV
61 DONNA
SCULLY
62 DUC
NGUYEN
63 ELIZABETH
OFARRELL
64 EMIR
BALANZAR
65 ERIC
ALBERT
66 FLORENCE
MORRIS
67 GEKEL
GOSSETT
68 GUADALUPE
CASTRO
69 HOMAYOUN
SADIGHI
70 JACOB
SARTAIN
71 JACQUELINE
GOMEZ
72 JASMINE
JONES
73 JASON
SPRENGER
74 JENNIFER
SCHROEDER
75 JENNY
NGUYEN
76 JESSICA
VALDEZ
77 JOAN
WRIGHT
78 JOHN
AGANON
79 JOHN
PARSONS
80 JOHNNIE
BRANCH
81 JOSE
BALANZAR
82 JOSUE
GONZALEZ MARCHENA
83 JUSTIN
EVANS
84 KARLY
CAMBEROS
85 KATHLENE
GASIOR
86 KEISHA
NEWSOM
87 KELISSA
RONQUILLO
88 LINDA
ALVAREZ LAVADORES
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 48 of 132
89 MARIE
PATAK
90 MARQUIS
GRACE
91 MESSIAH
JOHNSON
92 MONIQUE
ARELLANO
93 NIEYSHA
WHITE
94 PEDRO
MAYORAL
95 RACHEL
ALTMANN
96 RAEANON
HARTIGAN
97 RICHARD
BULLEN
98 RICHARD
SOTELO
99 RUSSELL
SMITH
100 RYAN
CHILDERS
101 SARAH
HOESTENBACH
102 SEAN
HAEUSSINGER, II
103 STEPHEN
HAMILTON
104 TRACY
HORN
105 WALTER
KNUTZEN
106 YRASEMA
ORTIZ
107 CATHY A
CLAY
108 CHRISTINE
DIAZ
109 CHRISTOPHER
ELLIS
110 CURTIS
LEVINE
111 DANIEL
HARRISS
112 DON
GATES
113 FERNANDO
HERNANDEZ
114 GLENN
PATRICIO
115 JAMES
TAFLINGER
116 JEFFREY
LARKIN
117 JOHN
PORTER
118 KIMBERLY
JOHNSON
119 KIRK
WATERMAN
120 MARK
BEATTY
121 NYLE
MOLINA
122 ROBINA
CANALES
123 RONALD
GASCHLER
124 RUSSELL
KINDOM
125 RYAN
PACIANO
126 SALLY
LOPEZ
127 STEPHANIE
WEIFORD
128 VANESSA
PARENGIT
129 MICHAEL
MENDELL
130 ALAN
MURPHY
131 ALIC
MOHARERI
132 ANDREA
PETRUZZIELLO
133 ANTHONY
CARENZO
134 BLAKE
BIXEL
135 CHENITTA
JOINER
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 49 of 132
136 GUERSCHOM
FRANCOIS
137 JOE
GRIMALDI
138 MIGUEL
FRIAS
139 GERROD
BARRETT
140 MARIE
EDWARDS
141 JOEY
HEFFLE
142 JOBANIE
GONZALEZ
143 AQUINAS
ACTILLE
144 TYRON
THOMPSON
145 EDWARD
GARRISON
146 KEVIN
SLACK
147 STEPHANIE
QUIROS
148 STEWART
BLACK
149 RUDOLPH
ROMANO
150 TRAVIS
FANTAUZZI
151 GREG
LASSITER
152 JASON
BOSMANN
153 JOHN
DUMAS
154 JARROD
SILVA
155 CRISTINA
VAZQUEZ
156 TINA
COPELAND
157 SHANICE
FIGEROUX
158 SEAN
HILL
159 MICHELE
FAILLA
160 LEONARDO
ARIAS
161 KENNETH
DARBY
162 CRISTINA
VAZQUEZ
163 ROBERT
EAP
164 SHONTELL
MCCLAIN
165 CHRIS
KURPIEWSKI
166 MARQUIS
DIXON
167 ROBERT
LECKINGTON
168 STEVEN
SILVER
169 REGGIE
HOLDER
170 ANTHONY
CUNNINGHAM
171 DANIEL
MORRISON
172 STEPHEN
BRADSHAW
173 ANDREW
HENRY
174 MICHAEL
REEDER
175 GABRIELA
CALOGERO
176 AAYAAT
RAJPUT
177 CHRIS
STRANDER
178 JAMES
FILECCIA
179 GAGE T
PEARCE
180 LAUREN
GUNN
181 GERALD
OWENS
182 MARICE
SILER
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 50 of 132
183 JAMES
HILL
184 MATHEW
KREUZER
185 ALEXANDRA
CAPPUCCI
186 JOVAN
PANIAGUA
187 JONNIK
JENKINS
188 JASMINE
MENDEZ
189 JEANNETTE
MENDOZA
190 SHERYNNA
MURRAY
191 BENJAMIN MICHAEL
INSERRO
192 RON
TRIBUNELLA
193 LOUIE
LEAL
194 NEFTHALY
HERRERA
195 JASON
PHILLIPS
196 KEYONDRA
WRIGHT
197 CRAIG
JACKSON
198 DANIEL
VARDARO
199 SETH
NIX
200 WASIF
MUFTI
201 BRUCE
LEZAMA
202 MELAINE
RAMOS
203 SHAMECKA
WATSON
204 KYRAN
BARRETT
205 VINCENT
MAFFEA
206 DELON
MERRITT
207 ERIC
BLIVEN
208 ANDERSON
ERALTE
209 ANN
LAYMAN
210 ARLEIGH
BANNER
211 LAMAR
CLARY
212 TOMMY
LIBRETTI
213 TERREON DESHAWN
WILTZ
214 KERRY
SULLIVAN
215 MITCHELL
ZEMAN
216 MALCOLM
LEWIS
217 JAYNELL
DENNIS
218 JEFF
TOOLAN
219 RAYMON
DAVIS
220 JOE
LESTER
221 KEVIN
EDWARDS
222 JAMIERE
MITCHELL
223 TYLER J
COUNCIL
224 ANDREW
TAYLOR
225 KENNY
KOHN
226 DELENE
LEWIS
227 HEATHER
PENACHIO
228 JAKOB
BROWN
229 JASON
WILLIAMS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 51 of 132
230 TYRIEK
BOLTON
231 LASHAWN
WRIGHT
232 MARQUES
ELDER
233 ILSARI
MARTINEZ
234 ALLAN
WONG
235 DANIEL
MARRERO
236 LaTRICIA A
SKEETE
237 JUAN
ORTIZ
238 PEDRO
URENA
239 JUAN L
ROBLES
240 GIDGET
IRIZARRY
241 RICKEY
McDUFFIE
242 BENJAMIN
WANG
243 STEPHANIE
NICOLL
244 SENECA
GONZALEZ
245 JASON
B
246 DASHIEL
GABLES
247 NEIL
FRIAS
248 NATALIE
CONCEPCION
249 BRANDON
T
250 STEVAN
AUSTINO
251 MICHAEL
THOMPSON
252 LEOPOLDO
PINEDA
253 ANDRE
BRADFORD
254 KAYLEE
DARGERT
255 JESSE
LUTZ
256 YURGO
TASIOPOULOS
257 AMELIA
LEFTWICH
258 GREGORY
KING
259 MUHAMMAD
SARDAR
260 TYHESHA
GIBBS
261 MARTIN
MELENDEZ
262 SHANDELL
McCULLOUGH
263 SHANNON
HAYES
264 ADRIANE
RODRIQUEZ
265 TRACEY
HOWARD
266 ALYSIA
MOORE
267 ERICKA
RUSSELL
268 RICHARD
FERGUSON
269 PETER
WASSEF
270 MARK
WEISS
271 MANUEL
CINTRON
272 LEA-ANN
TERRANCE
273 JASON
GOLDMAN
274 LAMAR
COGMON
275 TARQUL
ISLAM
276 BRYAN
BALDWN
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 52 of 132
277 JONATHAN
SOSA
278 ALEX
GOMEZ
279 CHAZ
MEABON
280 JEFFERY
SWEET
281 FREAKB
BROWN
282 MICHAEL
KRASNANSKY
283 LENA
MA
284 CANDA
MORRIS
285 KEVIN
BRIAN
286 CHRISTOPHER
SZENTMIKLOSY
287 PHANTASIA
ARIAS
288 MICHAEL
MATHIE
289 LATOYA
JEMISON
290 SANTINO
GRAVIANO
291 JORGE
RAMIREZ
292 CHANTAL
BARRY
293 THOMAS
GEIGER
294 KYLE
CARNRIGHT
295 DARRYL
GIBSON
296 SEAN
MOONEY
297 MICHAEL
HENDERSON
298 RAYMOND
CHRISTIE JR
299 HEATHER
HORTON
300 DEANNA
SIANO
301 WALLY
KRAKE
302 BRIAN
GANELES
303 DERRIK
KELLISON
304 JOHN
LUCCI
305 CHRISTINE
MENDEZ
306 JOHN
GENNARO III
307 NEEL
SINGH
308 MARC
INKELES
309 TRACE
ARRINGTON
310 DARIQUE
WEEKES
311 JORDAN
SHULTZ
312 VINCENT
GAGLIONE
313 JIM
HILLEGUS
314 KEOSHA
ROGERS
315 MAX
PATTERSON
316 GENESIA
SMITH
317 FELIX
MEDINA
318 CHRISTIAN
OBREGON
319 DENZEL
JOHNSON
320 KAREN
ESPINOZA
321 JOE
SECOVNIE
322 TAYLOR
NINIVAGGI
323 CHRISTOPHER
PEREZ
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 53 of 132
324
HEATHER
KELLY
325
JOHN
SHEPHERD
326
JENNY
ZHENG
327
STEPHANIE
SCHOSSOW-SMITH
328
DEANDRA
PERKINS
329
ELI
RICE
330
CHRISTOPHER
BOYADJIAN
331
MARILEE
MORIN
332
DIANA
LUU
333
JONATHAN
GUSTAVSON
334
BRIANNA
DEIOTTE
335
MARIA
URROZ
336
JADEN
REVIS
337
SCOTT
WERNER
338
MORIAH
JONES
339
SAUL
MENCHACA
340
BRENTNEY
OLIVER
341
GANNEN
RINCK
342
BARRY
HINCH
343
JACKIE
WHITNEY
344
JEFF
MCDOWELL
345
JACOB
LEVINSON
346
MATTHEW
PETERSON
347
TODD
HOLBROOK
348
KESHIA
NEWMAN
349
YVONNE
ESCOBAR
350
ANTIONIO
STAPLETON
351
GORDON
RENAUD
352
JOHN
BIEDA
353
CIERRA
WALKER
354
JOSEPH
MAIN
355
JESSALYN
KA
356
KELAN
PRUITT
357
VON
ODERMATT
358
MARC DE
JESUS
359
TIFFINY
MOSS
360
MARGARET
VALLE
361
BRIAN
MAGTOTO
362
HILARY
VIERNES
363
AMANDA
CASCELLA
364
CHRISTIAN
LEMUS
365
RUDY
HERNANDEZ
366
SIERRA
MODER
367
SYREETA
HART
368
ALICIA
MITCHELL
369
MONTREAL
FISHER
370
KAREN
CRUZ
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 54 of 132
371
GARY
GOMEZ
372
ANGELICA
KINDER
373
ASHLEY
COLLINS
374
EVANGELINE
BENNETT
375
ADAM
MCAFEEE
376
EMMA
GREENBERG
377
TRITON-SKY
GUIMOND
378
CARMEN
MILLER
379
ETHAN
WILSON
380
JORDAN
BOLGER
381
KATHLEEN
GOMEZ
382
PETER
LYMBERTOS
383
ELIZABETH
PYLE
384
IVAN
SAMOZA
385
ISSAC
VILLALOBOS
386
EMILY
VIEWEG
387
SHANCELA
MYERS
388
SOVANN
DOWLING
389
MISTY
CARVEN
390
SONNY
TRINH
391
TONI
TUCKER
392
DANIELA
AVALOS
393
CHARLENE
RAMIREZ
394
AURORA
GUERRERO
395
BRANDT
BANDSTRA
396
KRIS
MOYES
397
TINA
MONTALVO
398
ANTHONY
MOLINA
399
FAITH
JONES
400
REBECCA
JOHNSTON
401
ALEXANDRA
SANTIESTEBAN
402
DAVID
CONCEPCION
403
MANI
AHMADI
404
IAN
LASKY
405
GABRIEL
VARGA
406
JEREMY
HUARD
407
TANISHA
NOLLEY
408
ZACK
SCHWARTZ
409
MICHA
CARR
410
DARIA
MILLER
411
CELINA
BACK
412
ALEX
GOELZER
413
TAM
DANG
414
FERNANDA
TRUPIANO
415
NOAH
MORNINGSTAR
416
HARVEY
SERAPHIN
417
DAVID
OCONNELL
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 55 of 132
418
LAUREN
RAZZANO
419
DEVIN
DAVY
420
CHRISTOPHER
LEYVA
421
CODY
HIGGINS
422
ANDREW
STAPLES
423
JIAMING
ZHOU
424
RUBY
BARRIOS
425
CARLA
HILL
426
RICHARD
SMITH
427
DANIEL
YEE
428
DAVID
DURAN
429
JULIA
ELLINGSWORTH
430
DE WAYNE
WILSON
431
SANTOS
LARA
432
ARAYIK
SHAHBAZIAN
433
RYAN
SPARKS
434
LESLIE
MITCHELL
435
JOHN
CAO
436
MICHAEL
HUANG
437
MICHELE
COUEVAS
438
AMIRA
WILSON
439
MICHELLE
WILKINSON
440
JONATHAN
LIUSUWAN
441
JESSE
MONTANO
442
ELIZABETH
WAGNER
443
GILBERT
GAW
444 RODOLFO HERNANDEZ
RAZO
445
PAIJE
TULLOS
446
SABRINA
LUNA
447
DEVIN
GARCIA
448
JASON
LEE
449
BRETT
EVERLING
450
WILLIAM
ROSENBERG
451
TARRANCE
LOCKHART
452
TIMOTHY
WRIGHT
453
FRANCIS
FLANNERY
454
ROBIN
MAYFIELD
455
EDWARD
KOWALKOWSKI
456
OLGA
NECHAYEVA
457
ELIZABETH
MENDOZA
458
ERIC
CARR
459
JAMES
NOVELLA
460
WILLIAM
DOHERTY
461
CHERYL
PENNISE
462
RICHARD
PEDROZA
463
JASON
FERREIRA
464
ITALO
TAPIA
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 56 of 132
465
RAYELL
CARSON
466
BOBBI
CARROLL
467
BREANNA
GONZALEZ
468
NATHANIEL
JOSEPH
469
ITAI
RODED
470
CARON
BERKLEY
471
JAMES
GONZALEZ
472
ROSE
HAILEY
473
RODOLFO
GARCIA
474
JUSTIN
FARQUHARSON
475
YELILE
MILLER
476
JOHN
WOODS
477
EVAN
TSUTSUMIDA
478
JOHNNY
LEE
479
RAMON
GUTIERREZ
480
MICHAEL
MATHISON
481
PETER
BENJAMIN JR
482
CHEYENNE
OGLE
483
KIMBERLY
JOHNSON
484
JANET
REISNER
485
LAUREN
PASCA
486
KAREN
ORLANDO
487
DANIEL
GREER
488
WALTER
GOBEL
489
GRANT
HOUSTON
490
JAMES
DEMASTRIE
491
KELLI
SEALS
492
DANIEL
ARREOLA
493
SEDRIC
WHITE
494
NATHAN
GOTTEN
495
ARIELLE
WHITE/MORRIS
496
LAQUESHA
MITCHELL
497
OMAR
HOURY
498
KADY
VAIL
499
CAROLLE
BRULEE-WILSON
500
DEVORA
RICE
501
ROLANDO
RAMIREZ
502
ALFREDO
MEDINA
503
ANDREA
ALLEN
504
NATHANIEL
SUCHY
505
JENNY
KNIPPSCHILD
506
NIGEL
GUIEB
507
KRISTEN
KUCERA
508
ANITA
BOURGEOIS
509
CANDICE
FOLMAR
510
RUDY
GRODZEN
511
LIZET
GONZALEZ
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 57 of 132
512
ERIC
FALVEY
513
AMANDA
KRUGER
514
PAMELA
FLEMING
515
ORLENA
ABSHIRE
516
ZAIN
CURTIS
517
MELANIE
RANGEL
518
AARON
CATZ-FISHER
519
MATTHEW
BEKE
520
STEPHANIE
HAUGTVEDT
521
ERIC
JOHNSON
522
RODERICK
SPIKES
523
LAUREN
EWING
524
NATHAN
LOBDELL
525
WARDA
HAQ
526
JENNIFER
HARRELL
527
RACHEL
PANCZENKO
528
ANNA
RINCON
529
AARON
ARCHER
530
MARK
GLINOGA
531
ASHLEY
LANDSBERG
532
SIERRA
RASMUSSEN
533
BRIAN
SKELTON
534
JESSICA
HURLEY
535
JOCELYN
FONG
536
KIM
BAKER
537
GRACIE
THOMPSON
538
WILLIAM
FOSS
539
JESUS
JIMENEZ
540
ELIZABETH
SIMMERS
541
RYAN
SENSENIG
542
GARY
GOMEZ
543
WILLIAM
OLIVER
544
ANDREW
CRANE
545
JESSICA
YOUNG
546
JASON
NERY
547
MARTIN
GRIFFIN
548
DAVID
SNOW
549
GANESH
SANKAR
550
AARON
DIEM
551
KAREN
SHORES
552
AMBER
RAMIREZ
553
CRYSTAL
BACKSHER
554
HUNTER
HELMAN
555
CHRISTIAN
CARRILLO
556
MARICRUZ
JIMENEZ
557
ANNE
SCHROEDER
558
FRANCES
VAUGHAN
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 58 of 132
559
DENNIS
BOYLE
560
KWATAVIOUS
MARTIN
561
PAMELA
BURDEN
562
WILLIAM
BATCHELOR
563
CHARLES
CONNELL
564
KATHERINE
THARIN
565
REBECCA
ZEITLIN
566
SCOTT
HASELTON
567
TAYLOR
MCELROY
568
JULIE
SUAREZ
569
NATHANIEL
HERNANDEZ
570
TOAN
MAC
571
EVAN
MOON
572
JASMINE
DAVIS
573
JASON
MANN
574
GREGORY
BARNES
575
JEFFREY
MOORE
576
ANDREW
LOPEZ
577
JADDAH
RODGERS
578
TRICIA
BERENS
579
JUSTIN
LOERA
580
TANYA
MORGAN
581
ADAM
MACEY
582
KATERINA
SCHREINER
583
MISTY
POINTER
584
CRISTINA
SOLIS
585
ASHNEEL
REDDY
586
JAMES
BRESSACK
587
KYLE
SIEMENS
588
GILES
KELLEY
589
BRAXTON
PARR
590
SABRINA
CANFIELD
591
MATTHEW
MABIE
592
DANIEL
NEWMAN
593
NICHOLAS PALM
SONG
594
NICOLE
VIGIL
595
MATTHEW
SALOVITZ
596
ROY
SHAULI
597
NATALIE
ARELLANO
598
SAMEH
EMAM
599
TAYRON
GIOVANI
600
MEGAN
YEE
601
KORI
WURANGIAN
602
ERIN
MCGEE
603
ALPHONSO
HUTTON
604
LAUREN
LUKE
605
ROBERT
AGAZARYAN
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 59 of 132
606
ALIZA
BURTON
607
FADI
ATTOULEH
608
MAX
PATTERSON
609
CLAIRE
COSTANZA
610
MARQUIS
BROWN
611
DANIEL
MARTIN
612
KRISTIN
FLAXMAN
613
ERIKA
LEFIELL
614
QUAZI
SAFIN
615
EFREN
RAMOS
616
TANISHQA
SINGH
617
SANJEEV
GUPTA
618
JOSSELYN
DIAZ
619
JAMIAL
BLACK
620
ANDREW
DENNETT
621
JOHN
NGUYEN
622
ALVIN
LIAW
623
ASHLIE
VIOLA
624
MASSIMO
LESTI
625
DEAN
VASQUEZ
626
DAVEON
SKANNAL
627
ALICIA
BUTTERFIELD
628
ASHLY
HAKIMBABA
629
SAMANTHA
VANNETTER
630
JEFFREY
ROBINSON
631
JEREMY
BARNES
632
CAMERON
WEIR
633
KAYLA
BRYAN
634
SOPHIA
ALLGOOD
635
BARBARA
SANDOVAL
636
LAUREN
MORGAN
637
ISAAC
SIMPKINS
638
JEAN
ALVAREZ
639
LEWIS
VIGIL
640
LARRY
JONES
641
LADAYVION
HEARD
642
BRIANNA
MEDINA
643
REBECCA
CASTANEDA
644
MICHAEL
MANFREDI
645
KATINA
HAMM
646
PETER
TRANG
647
AVINESH
PAL
648
RAESHAWN
BROWN
649
DANIEL
PASSIOS
650
JYMIE
RICHARDSON
651
NICOLE
KOLB
652
AARON
MILLER
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 60 of 132
653
ALAN
STARZINSKI
654
BRANDY
GOODSON
655
TIMARIE
VASQUEZ
656
LANCE
OGLE
657
STEFANIA
BURAGLIA
658
BARKLEE
SANDERS
659
STACEY
BROWN
660
ALAIN
BERREBI
661
LOGAN
ROLIN
662
BENJAMIN
WELLS
663
SHAWN
ARTSON
664
CASEY
JARRATT
665
BRENDA
ZAPARI
666
RONALD
GUERRERO
667
JEREMIS
RODRIGUEZ
668
LUIS
SERRANO
669
KATRINA
FRUHMANN
670
FRANCISCO
HEREDIA
671
CHELSEA
CROIL
672
IAN
AMENY-LUTHI
673
JIMMY
NGUYEN
674
DANNY
PHAM
675
RYAN
HENGEL
676
JULIANA
SOUZA
677
ALEX
SHINDEL
678
GABRIELLA
LORENZO
679
JEFFREY
WOOD
680
EMMA
GOLDSTEIN
681
KELLY
EVERLING
682
ERIC
NARAYAN
683
JOSEH
SCIBERRAS
684
LAURA
TENG
685
PATRICE
PINDER
686
DANIELLE
LABOSTRIE
687
MATTHEW
RUTLEDGE
688
JOSEPH
DIMICHELE
689
LYNN
ATKINS
690
CHRIS
LYMBERTOS
691
RICHARD
FREEZE
692
METE
TASIN
693
STEPHEN
JONES
694
JOHN
WAUDBY
695
JUN
ZHOU
696
ANDY
PLAHANG
697
BRIANA
BALTODANO
698
MICHAEL
SIZEMORE
699
MAYRA
MARTINEZ
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 61 of 132
700
DAWAN
BROWN
701
ROBERTA
SAUNDERS
702
NICHOLAS
ALEXANDER
703
MICHAEL-JAMES
MENIN
704
ANIL
PACHECO
705
GEOFFREY
TAYLOR
706
DUSTIN
SHIRLEY
707
ULANI
MCCLELLAN
708
STEPHANIE
HALL
709
STEFANIE
VILLALOBOS
710
JIM
PLOTNER
711
MAKAYLA
CAPSHAW
712
VICTOR
VALDEZ
713
ANDRIENNE
HUNTER
714
REX
RAVITA
715
DMYTRY
LEWIS
716
ANGELICA
HERNANDEZ
717
CHRISTOPHER
CASTLE
718
THOMAS
CAPUANO
719
RACHELE
GIUSIANA
720
JODI
GREENBERG
721
TONY
NGUYEN
722
MAIA
RUCKER
723
CONNOR
TORR
724
DAKOTAH
MASSIE
725
HEBAT
ELSAYED
726
SANDI
BENNETT
727
JOHN
ALFLEN
728
ALEXANDER
HARRISON
729
LATRICE
JONES
730
JOANA
CRUZ
731
CAROLINA
HOYOS
732
MATTHEW
LAM
733
JACQUELINE
FORAKER
734
JOHN
ZEPEDA
735
MICHAEL
CULLEN
736
MICHELLE
PEREZ
737
CHRISTOPHER
QUATTROCIOCCHE
738
ADINA
RINGLER
739
JENELLE
HAUGEN
740
WILLIAM
JEFFRIES
741
SARA
MCHERRON
742
TODD
ELKINS
743
DAMOGOJ
KOPRIVCIC
744
IRENE
PALADA
745
KIMBERLY
BUCK
746
KEVIN
NICKELSON
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 62 of 132
747
CLIFFORD
MARTIN
748
DAMIEN
PETTUS
749
ARMANDO
CERDA
750
PATRICK
MCFARLAND
751
KRISTEN
DOYAN
752
CHARLES
JOHNSON
753
JEFFREY
MATTHEWS
754
LEAANNE
ORTIZ
755
LORI
TROESTER
756
KEIYON
BRYANT
757
RACHELLE
BROWN
758
KRISTA
KETTERHAGEN
759
MICHELE
WILLIAMS
760
KRISTEN
FAHRINGER
761
PEGGY
DESRAVINES
762
LYNN
AUSTIN
763
ADAM
SALCIDO
764
JASON
LAI
765
BRIAN
ROBINSON
766
ZACHARY
WELDON
767
RAUL
ARAUJO
768
CASEY
DAGGETT
769
LUBNA
SALAH
770
JOSEPH
KRAUSE
771
JAY
BERMAN
772
TIMOTHY
JONES
773
BRETT
MCCABE
774
EDGAR
ZAVALA NAVARRETTE
775
ADRIANA
CHENAULT
776
VICTORIA
DALLAIRE
777
DILLON
BLAIN
778
BEVERLY
LO
779
ERICA
BOWIE
780
JESSICA
COOK
781
ARTESE
LOVE
782
JESSE
BRAVO
783
JEREMY
MUNZ
784
RAYMUNDO
TOVAR
785
MORGAN
DYKES
786
THOMAS
ADAMS
787
KAITLYN
JACQUETT
788
RYAN
EDMONDS
789
EDWARD
HAKOBJANYAN
790
HOWARD
HUGHES
791
RYAN
NEWCOMB
792
JENNIFER
ENGE
793
VENESSA
GRIJALVA
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 63 of 132
794
ASHLEY
AVERY
795
RALPH
MILAN
796
DANIELLE
MULTER
797
KEVIN
ABUSHI
798
WILLIAM
CRISCIONE
799
JENNIFER
HOLMBERG
800
CAT
GOGUEN
801
TYLER
PAYNE
802
KELLY
LUU
803
CHRISTINA
NEDREBO
804
TONI
GALL
805
BRIAN
PITA
806
AMY
CASE
807
KIM
ATKINSON
808
STEPHANIE
CAMPBELL
809
TUESDAY
THOMAS
810
JOHN
VALENTINE
811
ZACHARY
HEMINGWAY
812
DARIN
DAVIS
813
CHERYL
HOLLIER
814
VICTOR
VARGAS
815
ROCHUN
BAILEY
816
CHASITY
MIGUES
817
PETE
DIGUGLIELMO
818
NICHOLAS
KO
819
EROL
GULER
820
ANN
MICHELLE UMALI
821
DYLAN
PENCE
822
JASMINE
DIOGUARDI
823
JONATHAN
SNYDER
824
MELVA
ATAYDE
825
SHAIANNE
STARKS
826
NATE
DANIELS
827
SPENCER
PFEIFF
828
LOUIS
SAMANO
829
ALEJANDRO
MARROQUIN
830
JOSEPH
SINDELAR
831
MANUEL
NAVARRO-CABRERA
832
JOAQUIN
GOMEZ
833
VICTORIA
VIRAMONTES
834
MONIQUE
CAMACHO
835
CAROL
WILHELM
836
DANYELLE
WRIGHT
837
SUSANA
LUNA
838
AMANDA
KIRKMAN
839
VICTORIA
OKORAKPO
840
JOHN
DODDS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 64 of 132
841
STEPHANIE
WILLIAMS
842
JEFFORY
SCOTT
843
PATRICIA
AGUILAR
844
ROBERT
RIVERA
845
SYDNEY
SHAHIN
846
JULIANNE
SIMITZ
847
MIKE
PANNETON
848
ROBERT
SERNA
849
PAUL
LOEB
850
JAKOB
OUSLEY
851
JANELLE
WHITE
852
SHREEL
JACKSON
853
SHAWNA
HALBACH
854
ASHLEY
GREEN
855
NICK
LONESCU
856
FRANK
ORTEGA
857
BERNICE
ROMERO
858
JANNETTE
IMASA
859
KATHERINE
MILLER
860
WENDY
KWONG
861
EDWARD
RYAN 111
862
RICHARD
WANG
863
CHARLOTTE
CABAN
864
MICHAEL
PATAKY
865
MARK
CABUANG
866
MICHEL
MYARA
867
KAMILA
HARKAVY
868
KIA
VAARA
869
MICHAEL
LUCENA
870
VICTORYA
LAWRENCE
871
WILLIAM
BISIGNANO
872
STEVEN
WIRTZ
873
SOPHIE
TRAN
874
JESSICA
BUCHANAN
875
SADIE
KATZ
876
LOURDETTE
PADILLA
877
PAULETTE
DAKURAS
878
HAILEY
SANTOS
879
RICHARD
KASYOKI
880
ABHINAY
AERUVA
881
TIMOTHY
BROYLES
882
ELLENA
RUIZ-LINDSEY
883
DAVID
ASEM
884
MARC
PITTS
885
ALEN
MIRZA
886
AMY
LUU
887
ELVIRA
TREVINO
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 65 of 132
888
KATHLEEN
ERFURT
889
DANNAH
COLLINS
890
KEISHA
GRADY
891
ROBYN
BROCKMAN
892
STEPHANIE
KUMAR
893
STELLA
CISNEROS
894
KENDRA
PFALZGRAF
895
SASHA
FORD
896
DILLON
REEDE
897
MARFA
BURKOFF
898
BRANDI
STILES
899
KAYLA
NIX
900
JENISE
MCNEAL
901
SARA
STOCKWELL
902
AHMAND
RICHARDSON
903
SANTIAGO
SALGADO
904
WILLIE
GRAY
905
MACY
WEISER
906
VALENCIA
FISHER
907
JONATHAN
ALLEN
908
KIM-SA
MAC
909
ED
TAYLOR
910
SEBASTIAN
ROJAS
911
MICHAEL
RAPUANO
912
GHOUS
AGHA
913
LOGAN
ASKELSON
914
ADAM
ALZAIDI
915
LETEICIA
SPEIGHTS
916
BRAD
ELLISTON
917
STEPHEN
REGAN
918
DAVID
CASADO
919
ABIGAIL
SANNY
920
THEODORE
INCH
921
KEVIN
O'BRIEN
922
LAREISHA
ELDERKIN
923
HERBERT
MORALES
924
GENARO
ALVARADO
925
SVETLANA
DUBKOVA
926
CLINT
SCRUGGS
927
BLAKE
HEIRBRANDT
928
STEVEN
OSWOOD
929
JOSE
ESTEVEZ
930
AARON
JACKSON
931
CHRISTOPHER
MORRIS
932
NATHAN
HEBERT
933
ANTHONY
AYALA
934
JUSTIN
SMITH
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 66 of 132
935
REJANAE
SMITH
936
PAMELA
SALINAS
937
ALISHA
WARREN
938
ANDREA
PELTON
939
BRITTNEY
SEWELL
940
RYAN
ANDERSEN
941
NATASHA
CHACEY
942
NICOLE
BROSSART
943
HENRY
PEREZ
944
RON
ABLANG
945
CHUNGYEN
CHANG
946
RUSSEL
CHIACCHIA
947
ALEC
GREENBERG
948
GARY
PORTER
949
SHEBA
SIMPSON
950
JOEL
TORRES
951
CAITLYN
ROSLONSKI
952
KRISTAL
MICHEAU
953
KIMBERLEY
DEEMS
954
THOMAS
RICHARDSON
955
DAVID
GASHLER
956
CHRISTOPHER
JOHNSON
957
MATTHEW
REILLY
958
TYLER
EBERSOLD
959
AARON
MARTINEZ
960
MANUEL
SAUCEDO
961
CHRISTOPHER
ARNOLD
962
BOBBY
CODRAY
963
MELISSA
LARA
964
NICOLE
DIIENNO
965
LISA
BASURTO
966
JACOB
LAU
967
KIP
ROLAND
968
JACKIE
JONES
969
CHRIS
OBI
970
RICHARD
DE LOS REYES
971
ALEX
RODRIGUEZ
972
KELLY
MONKS
973
MATTHEW
GILLIAN
974
ANGEL
VALERIANO
975
TERRELLE
JACKSON
976
ALLEN
WILLIAMSON
977
AARON
HARRIS
978
DOMINIQUE
STARR
979
ADRIAN
RODRIGUEZ
980
JASON
BYRD
981
QUIANA
SUTTLE
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 67 of 132
982
ANNA
TRENSHAW
983
TALMADGE
KEOWN
984
JONATHAN
OWENS
985
RUSSELL
SIMPSON
986
TIMOTHY
ROBERTS
987
ROSTON
KIEFER
988
NICOLAS
MORIN
989
CHRISTINE
IRISH
990
DARIUS
MOORE
991
JESSICA
HERNANDEZ
992
CHRISTOPH
BAILEY
993
DERRIK
BONNER
994
SHERRY
KING
995
CHRISTIAN
WYDAJEWSKI
996
TOM
DUONG
997
BENJAMIN
DE AYORA
998
J'MEYA
GICHURU
999
JEFFERY
DIX
1000
MICHAEL
GOLDSTEIN
1001
CELSO
RAMOS
1002
STACEY
LITTLEPAGE
1003
JAMES
BELLAMY
1004
THOMAS
BOUDRIE
1005
ANTONIO
MALDONADO
1006
MARIA
DUSEK
1007
KATRINA
TAAGEPERA
1008
ERICA
TAYLOR
1009
DEBORAH
GRIFFIN
1010
AMBER
TINNEY
1011
ASHLEY
FRANCIS
1012
GLORIA
BUTLER
1013
ANTHONY
HAWIL
1014
JENNIFER
RIOS
1015
JUDINE
HAYWARD
1016
ALBERTO
BALTAZAR
1017
RAFAEL
MONTANO
1018
MARCELO
LOPES
1019
BRODRICK
THOMPSON
1020
JARED
JARRETT
1021
MARIA
CASTELLANOS
1022
NORMAN
HAMPTON
1023
JACOB
ACTON
1024
CHRISTOPHER
WILSON-ALBRIGHT
1025
MOHAMED
REDA
1026
WHITNEY
GUERRERO
1027
KEVIN
CROSS
1028
SUSANNAH
WILLIAMS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 68 of 132
1029
MARISSA
SANDE
1030
CHRIS
DURHAM
1031
CHRIS
EANUZEL
1032
THOMAS
MANSFIELD
1033
RITA
CRANE
1034
MARQUITA
BOTHWELL
1035
WILLIAM
LAM
1036
EDWIN
MONTEALEGRE
1037
YURGO
TASIOPOULOS
1038
MICHAEL
PULIDO
1039
JEFFERY
GATLIN
1040
LISA
ANDERSON
1041
JENNIFER
JEFFRIES
1042
NATHAN
WARD
1043
KALEB
WILLOUGHBY
1044
ALEXIS
JONES
1045
HOPE
EGGERS
1046
STEPHANIE
GUNN
1047
LOGAN
SISCO
1048
SHANIQUA
WILLISTON
1049
MICHAEL
SWANSON
1050
SAMANTHA
MROZEK
1051
YANNICK
FERGUSON
1052
KINO
HERNANDEZ
1053
JOSEPH
BARBERA
1054
CHERYL
WEBB
1055
DONALD
FISHER
1056
CHRISTOPHER
SANDERS
1057
FRANCISCO
HERNANDEZ
1058
CHRISTOPHER
CAMERON
1059
ABEAL
MICHIAL
1060
SANTIAGO
BELTRAN
1061
AMBIKA
WILLIAMS
1062
ELIJAH
GROOMS
1063
CHELSEA
ASOME
1064
JESUS
PACHECO
1065
SISSI
REY
1066
ERIC
SOLIS
1067
MASON
LONG
1068
OSCAR
DELAO
1069
CHARLES
ODIZURU ABANGWU JR
1070
SAMANTHA
TAYLOR
1071
CRESHELL
EDGAR
1072
CARLOS
WILKES
1073
MARK
EVANS
1074
ANDREW
WILLIAMS
1075
BRIAN
BROOKS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 69 of 132
1076
BRIANNA
BLACKWOOD-MALLORY
1077
EDWARD
LI
1078
OLIVIA
BOYCE
1079
SAMANTHA
RIVERA
1080
NIKKI
ANNUNZIATA
1081
STEPHANIE
LOGGINS
1082
BRANDON
MCGUIRE
1083
AUDRA
OWENS
1084
MATT
TIDD
1085
ISIS
ARBOLEDA
1086
FRANCES
BURNETT
1087
CLINT
LUSK
1088
ERIC
COOK
1089
DAVID
MOWBRAY
1090
JOSHUA
GIBSON
1091
JASON
BELINSKY
1092
MARQUIS
WILLIAMS
1093
ANGELICA
HERNANDEZ-ALLEN
1094
MAXIM
KRAFT
1095
LEISA
BLAIR
1096
SHAWN
TEETER
1097
SUSAN
LEE
1098
HOWARD
HARRIS
1099
MICHAEL
ESCALANTE
1100
SAUL
GOMEZ GAXIOLA
1101
FRANCIS
CARREON
1102
JAMES
ROWLAND
1103
CARL
JAMES ICAZA
1104
DOMONIQUE
GOLDSMITH
1105
RAHEEM
ALI
1106
EDWARD
HERBST II
1107
DANIEL
GRACIE
1108
CURTIS
BROUSSEAU
1109
TIA
SEITZ
1110
EVAN
LEWIS
1111
AMANDA
JACE
1112
JACOB
ANDERSON
1113
MINAY
MATTHEWS
1114
SHANE
DEVEREAUX
1115
JOE
CHAPMAN
1116
DIONDRE
HARRIS
1117
MORGAN
GREENE-CARSON
1118
KIERAN
CONNOLLY
1119
RYAN
SMITH
1120
KHERI
RAINEY-STARK
1121
ELOISE
ROGERS
1122
MATTHEW
KESTEL
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 70 of 132
1123
KARAN
CHILKA
1124
GALE
GALLE-CARROLL
1125
CHERYL
CURTIN
1126
JOHNNA
KNOWLES
1127
MARCO
CHACON
1128
TAMARA
LAVIOLETTE
1129
ARCHIE
SWARTZENTRUBER
1130
PETE
GARCIA
1131
ANDREW
MANOR
1132
REBECCA
GARCIA
1133
ERIC
TEEL
1134
DEON
CARSON
1135
JASPER
USSERY
1136
ERICKA
ANDERS-CHAFIN
1137
DAVID
MARTINEZ
1138
MARISSA
HOESCH
1139
RICHARD
FISHER II
1140
ROBERT
PRICE
1141
JEFFREY
SMITH
1142
KELVIN
SMITH
1143
JOSEPH
KRAMER
1144
CANDACE
HUBBARD
1145
DAVID
BARANY
1146
SHANE
COOPER
1147
KORRINE
CRUZ
1148
DANIEL
KRALL
1149
KATIE
HUEBNER
1150
TONY
SCOTT
1151
GENE
SHIEH
1152
YESENIA
GONZALEZ
1153
MATTHEW
SOLON
1154
BENJAMIN
DE AYORA
1155
KEVIN
PORRAS
1156
LEONARD
MCCARTHY
1157
MARCK
CHARLES
1158
CHANNING
WINTERROSE
1159
JOE
YOON
1160
EDWARD
MINUS
1161
ERIK
NAKAMOTO
1162
LAURIE DUNAWAY
WILSON
1163
SHAMAR
SOTO
1164
ALEX
GUTIERREZ
1165
SIERRA
SOTO
1166
LUCIUS
MURPHY
1167
MIGUEL
ALVAREZ
1168
MARNI
MERENSTEIN
1169
KATY
HERN
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 71 of 132
1170
NAOMI
POLOCOSER
1171
MYLES
PARHAM
1172
JULIO
CARRANCO
1173
DIANNA
TAYLOR
1174
CATHERINE
SCHANNO
1175
ADAM
BROWN
1176
ERIN
LITTLEFIELD
1177
JAMES
WELLS
1178
TELOS
SALDANA
1179
MARGARET
GUZMAN
1180
JEREMY
SCOTT
1181
CHRISSY
BALDWIN
1182
TYSHEICA
DIXON
1183
BONNIE
WITT
1184
KANE
FENNICKS
1185
DUSHAWN
WOODSON
1186
JOSE IGNACIO
VALLS
1187
JOSEPH
KUNTZ
1188
RAYNE SANDERS
FLEMING
1189
JOEL
VARGAS
1190
SCOTT
CHAMBERS
1191
CIARA
MAYE
1192
JOHN
SPURGEON
1193
DAVID
BUTLER
1194
MOHAMMED SINGH
MULTANI
1195
SAUL
GARCIA
1196
MARCOS
TORRES
1197
ISRAEL
EZEODUM
1198
JASON
MONTEZ
1199
KELLI
LAWRENCE
1200
OJASWI
TAGORE
1201
JULIAN
DRUCKER
1202
CRISTIAN
FRANCO
1203
LYNDSEY
KAAN
1204
JEREMY
PLASTER
1205
MATTHEW
ISKANDER
1206
DENNING
CRENSHAW
1207
LUCKIESIA
BELTON
1208
ANDREW
SAMPSON
1209
LUIS
CABRERA
1210
ANIRUDH
KRISHNA
1211
KYLE
DICKISON
1212
JEANNIE
MOEWS
1213
JAIME
CALDERON
1214
VIRGINIA
JONES
1215
MATTHEW
BATES
1216
KWAME
FRANK
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 72 of 132
1217
WHITNEY
WIRE
1218
VICTORIA
PEERS
1219
MARIO
FEOLA
1220
JOHN
GONZALEZ
1221
MANI
JAVAHERIAN
1222
SCOTT
MARTELL
1223
JENNIFER
ACKLEY
1224
JOSHUA
SHARPS
1225
DAVID
MONEY
1226
QUADRELLA
FAGAN
1227
KATIE
GOLD
1228
FRED
LAND
1229
JASON
STERLING
1230
EDUARDO
MORA
1231
VICTOR
GRIFFIN
1232
SIDNEY
HARRIS JR
1233
JACIE
KIRBY
1234
ZAMUEL
SANCHEZ
1235
MARYAM
AL-SHABAZZ
1236
ADRIEL S
VALDEZ
1237
BRODY
STOUS
1238
ASHLEY
CAPPS
1239
FABIO
MACHADO
1240
ERNEST
TURMAN
1241
DHENNIS
TOLENTINO
1242
MICHAEL
LINDSEY
1243
DONALD
FORMAN III
1244
ANDREW
BROWN
1245
DAVID
GREENLEY
1246
KRISTINA
WONG
1247
JOEL
BANDI
1248
MIRANDA
GIBSON
1249
KEVIN
ALVAREZ
1250
MAZIAR
SAEDI
1251
LARONDA
JOHNSON
1252
NICHOLAS
RUBIO
1253
NATASHA
MASELLI
1254
ZACH
PLEVNIK
1255
ERIC
TALAMANTEZ
1256
JACK
BOTT
1257
CRAIG
TASWELL
1258
DORIS
BARWICK
1259
JASON
BUTLER
1260
ALEXANDRO
BETANCOURT
1261
JOSE
BECERRA
1262
JENNIFER
BROTHERS
1263
ELIZABETH
BRAVE
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 73 of 132
1264
JAKE
CAVANAUGH
1265
DAVE
HOLLOWAY
1266
DAVIS
DUNCAN
1267
JUSTIN
MCCORMICK
1268
SEAN
HUDSON
1269
JUSTIN
BURNS
1270
PHILIP
DYE
1271
KEN
HAYWARD
1272
CHRIS
TUSCHHOFF
1273
RACKEEM
TAYLOR
1274
LEONARDO
LEON
1275
JUNIQUA
DAWKINS
1276
JONTE
FIELDS
1277
SAM
STAATS
1278
RYAN
VAN DUSEN
1279
ROBERT
ALVARADO
1280
SUSANNE
BEAUDOIN
1281
WESLEY
COX
1282
DAVID
LUCAS
1283
MATTHEW
SCARBERRY
1284
JUSTIN
WITTWER
1285
CEDRIC
WELLS
1286
SEBESTAIN
OWENS
1287
JULIANNE
HUBER
1288
SCHAAD
WEGRZYN
1289
MATTHEW
DUBE
1290
JACKRIN
VIPATAPAT
1291
RICHARD
STRIANO
1292
JACOB
SMITH
1293
MARQUES
WILLIAMS
1294
ALAN
OLIVEROS
1295
TRAVIS
CAIN
1296
BRIGITTE
PAULI
1297
NOAH
CARPENTER
1298
STEPHEN
SULIMANI
1299
MALACHI
STEWARD
1300
GEORGIANNE
LEONG
1301
KAITLYN
BOWMAN
1302
DARIUS
BASKERVILLE
1303
SHERROD
PERCELL
1304
MICHAEL WILLIAMS
SMITH
1305
JESSICA
GORDY
1306
YASMINE
CAMPBELL
1307
ELIZABETH
SELLARS
1308
MIRANDA
FOLLEY
1309
PIERRE
STILL
1310
CHAMISE
BELL
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 74 of 132
1311
JASON
SERRANO
1312
ALAN
FOGELSANGER
1313
TERRY
BIESBOER
1314
JOSEPH
KENNEDY
1315
ERIC
SCHRAM
1316
SEAN
HUNTER
1317
JEFF
KLINSKY
1318
AUGUST
GAMBOA
1319
HALLIR
CAYWOOD
1320
JASON
HANSBROUGH
1321
WILLIAM
PARKER
1322
MELANIE
HERNANDEZ
1323
JNAI
ALEXANDER
1324
KYLE
OUBRE
1325
JONAS
DESIR
1326
JON KOMP
SHIN
1327
JEFFREY
BECKHAM
1328
KENNETH
LEBLANC
1329
WILL
DUNN
1330
ZACHARY
SMITH
1331
DUSTIN
FOSTER
1332
KARRIE
CARRASQUILLO
1333
ANTHONY
CARLO
1334
BARSHAR
FLENORY
1335
AMBER
DUNCAN
1336
GLENN
DONOGHUE
1337
NATHANIEL
KIM
1338
WILSON
PENG
1339
MARK
GASPAR
1340
LATASHA
WEST
1341
ASHLEY
RANDOLPH
1342
MATTHEW
VARGAS
1343
MARCUS
COLE
1344
BRIAN
BOOKER
1345
ANTHONY
BICKNESE
1346
JAMARI
CAMELL
1347
DUSTIN
HOEHN
1348
JOSEPH
SAMOZA
1349
MICHAEL
FURTNEY
1350
PATRICK
DOSSOU JR
1351
SALIFU
JATTA
1352
SHAUN
BRODEUR
1353
JAMES
BROCKMEYER
1354
RYAN
CAGNEY
1355
JOSEPH
GHABOUR
1356
JOSHUA
MCDONALD
1357
ERIK
GONZALEZ
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 75 of 132
1358
KEIRSTON
WILLIAMS
1359
JOSH
BORYS
1360
HALEY
WOFFORD
1361
TIMMOTHY
NEWELL
1362
TRISTAN
HUGHES
1363
CHERYCE
KNOX
1364
JONATHAN
MALLO
1365
JAMIN
WESTON
1366
AMANDA
TYSER
1367
SAMUEL
MASTROIANNI
1368
MARTEZ
BROWN
1369
MARK
CHALLIS
1370
CHRISTINA
FABBRI
1371
CHARNESE
SHABAZZ
1372
BRITTANY
JONES
1373
PEDRO
ANTAR
1374
ERIC
BERNAL
1375
DRICKEY
JACKSON
1376
MARLIN
AGOUB
1377
TARIA
MICHALET
1378
STACY
SHEPHERD
1379
MICHELLE
VU
1380
MATEUSZ
BAJEK
1381
TEREASA
CANADA
1382
NICHOLAS
MILLER
1383
MELISSA
WARREN
1384
BRYAN
BIBEY
1385
OLIVER
SAVAGE
1386
RICHARD
BACKER
1387
MICHAEL
AZAR
1388
ZSATA
WILLIAMS-SPINKS
1389
DAN
D'ANGELO
1390
DACIA
THOMAS
1391
GIOVANNI
MODICA
1392
SAMANTHA
GUREWITZ
1393
HOLLY
HARRIS
1394
DAVID
PODESTA
1395
ALYSSA
MITCHELL
1396
BRITTNEY
BURDEN
1397
PAMELA
ROLLE
1398
JESSICA
DEBARBIERIS
1399
JOSE
ONTIVEROS
1400
KEVIN
LAU
1401
ANGELA
LUNT
1402
MIGUEL
MUNOZ
1403
MARKITA
RHYNE
1404
DAVID
MOYER
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 76 of 132
1405
PETER
TITTL
1406
OMAR
MARRUFO
1407
MARCO
APUN
1408
RYAN
TENG
1409
CARLOS
PLASCENCIA
1410
CHELSEA
ALDRICH
1411
ALVIN
GLASS
1412
BRAD
FISHER
1413
TANNER
COOK
1414
JOSHUA
SANTILLAN
1415
SABASTIAN
JONES
1416
SHANNOA
FARRIS
1417
JAMES
SANDERS
1418
CARL
SEABOLD
1419
HEATHER
LEMIEUX
1420
HOLLY
ROGERS
1421
COCO
GLICKMAN
1422
SCOTT
STINER
1423
ALEXYS
TAYLOR
1424
HANNAH
BRYANT
1425
KATELIN
HENNINGER
1426
COREY
SCHMIDT
1427
SHUNTALISHA
METCALF
1428
PAUL
ROBITAILLE
1429
KIMBERLY
NUNN
1430
TERRY
MCCLENNON
1431
JEWON
MATHEWS
1432
KRIS
FORDE
1433
TRACEY
BATES
1434
TYLER
SHILTZ
1435
FRANCISCO
FERNANDEZ
1436
ALEJANDRO
ESCARCEGA
1437
MARY
HICKS
1438
VINCENT
REESE
1439
KIMBERLY
TIGER
1440
MATTHEW
CANDOW
1441
SERRA
FARLEY
1442
NIKIA
LOVE
1443
AARON
KRAMER
1444
JACLYN
SANCHEZ
1445
MARCO
RASTELLI
1446
JAMEEL
HUSSAIN
1447
YUNIQUE
GRESHAM
1448
DAWN
HINER
1449
CHARLES
PAULSEN
1450
MARK
BLANK
1451
RICHARD
MAROUS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 77 of 132
1452
TRISTIAN
STORMS
1453
TREVIN
EMANUEL
1454
JEREMY
REID
1455
TIMOTHY
ALEXANDER
1456
CIRO
ESCOTO
1457
LONNIE
TRINIDAD
1458
CAROLYN
GOFORTH
1459
SAMANTHA
SANTANA
1460
DAVID
LEE
1461
NESTOR
GONZALES
1462
DANIELLE
FUENTES
1463
EDER
BERGANZA
1464
CORBIN
MILLER
1465
MONIQUE
SMITH
1466
BRANDON
PLAUFCAN
1467
BILL
CHRISTIAN
1468
RONNIE
MORGAN
1469
MICHAEL
ELLISON
1470
JARED
ZIMMERMAN
1471
CHERI
JONES
1472
LAMAR
JACKSON
1473
MICHAEL
SIANO
1474
TANYA
BRITTON
1475
SYDNEY
FORD
1476
NICHOLAS
RUSSETT
1477
LINDSEY
STEWART
1478
JODI
ASHLEY
1479
JOHN
CARPER
1480
DANIEL
MINICK
1481
HAIHAO
LIU
1482
CHRISTIAN
COOP
1483
PAVLO
GIDDENS
1484
STEVEN
STRONG
1485
CARLOS
MURPHY
1486
MICHELE
IVEY MONROE
1487
GREGORY
KNIGHT
1488
CHENOA
JONES
1489
CHARNELL
FREEMAN
1490
TAMMIE MONIQUE
HARRIS
1491
GRANT
ROGERS
1492
NATHANIEL
CONNIFF
1493
BENJAMIN
HOWARD
1494
DERRICK
HARRIS
1495
NICOLE
WONG
1496
TRACY
FORDHAM
1497
MASON
BATES
1498
TIMOTHY T
ANDERSON
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 78 of 132
1499
MAIGEN ANN
PRIAMI
1500
LADONNA
BARKSDALE
1501
DAVID
MAY
1502
NAKESHA
BLAIR
1503
BRENDAN DANIEL
GARVEY
1504
BRAD
JAFFE
1505
ANDREW M
PHIPPS
1506
ERIN
ZIMMERMANN
1507
TASO
TANGALIDIS
1508
SEAN
LYONS
1509
JOHNA
SHAFFER
1510
CHRISTOPHER
ARANA
1511
JARED ROBERT
JOHNSON
1512
ESTUARDO
LOPEZ
1513
DUANE B
HARRIS
1514
AMADOU
FALL
1515
MICHAEL
WARD
1516
JAMES
JONES
1517
PARRISH
KNIGHT
1518
ANDREA
RUGG
1519
WHITNEY
CAYCE
1520
ROKOSI
HUMPHREY
1521
AARON
DONHAM
1522
PATERSON
WOLFGRAM
1523
MIKE
STEWART
1524
ELIZABETH R
BRODNAX
1525
JUSTIN MATTHEW
SCHWARTZ
1526
ALLISON M
SAMMARCO
1527
NIKOLE MARIE
SPANN
1528
JOELY
KUHN
1529
DAYLEN
FOSTER
1530
TONYA
TAYLOR
1531
FRANCINE
JACKSON
1532
JOHN
LADALIA
1533
MICHAEL
MORALES
1534
SHAVON
THOMAS
1535
MICHAEL
FOWLER
1536
ROBIN
FOSTER
1537
CANDY
HUANG
1538
VANJALIC A
TOLBERT
1539
MARISOL
ALMANZA
1540
REBECCA LYNN
GIBSON
1541
JAMES
HILL
1542
JUSTIN
PETTWAY
1543
DANNY LYNN
TROXEL
1544
BRANDI
MAGANA
1545
JOSHUA STEVEN
NELSON
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 79 of 132
1546
ELIZABETH MARCELA
AYHENS
1547
BRYAN
JURECZKI
1548
JARED MATTHEW
COUCH
1549
RYAN
BOLANOWSKI
1550
RAUL
PEREZ
1551
WYNDI
AUSTIN
1552
PAUL
BOHANAN
1553
MARSHALL J
SELIGMANN
1554
JAMES
HILLS
1555
LFRAN
XION
1556
HIEN
BUI
1557
TRICE
HICKS
1558
JACORIA
PUGH
1559
JENNIFER
SANTIAGO
1560
JONATHAN
DUHON
1561
RILEY
GILMORE
1562
CHRISTOPHER
WYMAN
1563
PATSY EVERIDGE
OLIVO
1564
RUBEN
GIL
1565
MATTHEW C
AUBEL
1566
GREGARY ALLEN
JOHNSON
1567
CHANTELLE
BERKOH
1568
DONALD GARY
HELM
1569
DAMIANO
CALGARO
1570
JARON
GINN
1571
JAMES
HELLAMS
1572
JOHN MATTHEW
WAIT
1573
KERRY
SHAFER
1574
STEVEN
SOBOL
1575
TOMEKA L
ROBINSON
1576
STEPHEN WILLIAM
IVESON
1577
STEPHEN
GOFF
1578
ISAAC ELI
SHEPARD
1579
KAYLA
HERRICK
1580
RYAN D
LEMIRE
1581
TIERA
WRIGHT
1582
YISROEL
NEWMAN
1583
CYNTHIA
HO
1584
SHANNON
LAWSON
1585
WILLIAM MILAM
GRAY
1586
STEFANIE NAOMI
SMITH
1587
LUIS
MURILLO
1588
RYAN JOSEPH
VEINOTTE
1589
HASSEN
NASRALLAH
1590
DIANN
BONNER
1591
DOMINIQUE
Redman
1592
VICKI
ELDER
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 80 of 132
1593
JOHN
MCCLENDON
1594
FANTASIA MONIQUE
WALTON
1595
KIM
DAUGHERTY
1596
NATHANIEL J
DARLING
1597
NATHAN MICHAEL
GOSSETT
1598
GARRETT
MAURO
1599
STEPHEN E
PHILLIPS
1600
TIARA
BROWN
1601
STEPHANIE
STEWART
1602
PAUL
CRABBE
1603
ELIZABETH
VOSSELER
1604
RADHA
DASA
1605
DANIEL
MCDONALD
1606
SHAVON
MCFADDEN
1607
OLIVIA G
KELLY
1608
DANIEL
LIEBER
1609
LEEANN
MCCRAE
1610
COLIN
KOULPASIS
1611
JULIO DANIEL
GARCIA
1612
ANGIE
WAUTHION
1613
STEPHANIE DAWN
WISE
1614
ANGELA
TRIPP
1615
BRYAN
HERRERA
1616
BLAKE
BARON
1617
ROBERT
SCRUGGS
1618
CRISTIE M
ROSIER
1619
WILSON
RICHARDSON
1620
WILLIAM JOSUE
GAMEZ
1621
ALEJANDRO
VICTORES
1622
AMARILY
DIAZ
1623
JAMES DAVID
SIMONS
1624
MIKE
STANLEY
1625
ELLYN NIKKIA
MCNAMARA
1626
ANGELA
RENISON
1627
MEREDITH RYAN
SMITH
1628
CARTER T
KONZ
1629
CHERRY
CHEUNG
1630
SHELBY O
MARSH
1631
CLAUDIA YASMINDA
NIEPOKNY
1632
GEORDAN
EHLY
1633
RICHARD
CHING
1634
HOWARD
SANDERS
1635
AMY LYNN
ACKERMANN
1636
MYRISSA
HOLLOWAY
1637
ADRIENNE
BROOKS
1638
MONIQUE
ATKINSON
1639
SEAN
BROWN
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 81 of 132
1640
ANDREW
SATTERWHITE
1641
EDWARD
CRUZ
1642 THRINATH KUMAR RAJ
PANDUGA
1643
DAVID
MARTIN
1644
GARRETT
VIGNEAUX
1645
AMY
ROBINSON
1646
JONATHAN
LOGAN
1647
MATTHEW
SPENCE
1648
NICHOLAS
WETZEL
1649
AARON JAI
LAMB
1650
ADONNA
BRIGHT
1651
MCKENZI
NORRIS
1652
ROCHELLE HOPE
MORITZ-SEET
1653
SHANITA LANIA
ELLISON
1654
JENNIFER
ANGELL
1655
SEHRASH
NASEER
1656
PAUL
MIOLE
1657
JOSH
BOLLING
1658
VERONICA ROCHELLE
WILLIAMS
1659
KYLE
DIAZ
1660
GUSTAVO A MARIN
REGALADO
1661
KIARA
BROOKS
1662
BRANDON
SPIESS
1663
PAUL
GRIFFITHS
1664
JOHN
OWENS
1665
GREGORY
KNIGHT
1666
JESSICA
CARDENAS
1667
CHARNELL K
FREEMAN
1668
TIFFANI L
BUTLER
1669
GREGORY
EVANS
1670
TORY
JACKSON
1671
JASON
CASILLO
1672
DENISE
MARLIN
1673
LASHUNTA
BATTLE
1674
NANA
DARKO
1675
AVI
ECKSTEIN
1676
JEREMY
AQUINO
1677
JAMES BERNARD
BOWERS
1678
JESSICA JOHANNA
SUOTMAA
1679
JOSHUA
CROSS
1680
RYAN
KREISBERG
1681
ERICA
PEARSON
1682
SHARON
FARMER
1683
NANETTE
MCMAHON-WHITE
1684
CHRISTOPHER M
MATERA
1685
PAUL
ABBAZIA
1686
DAVID
ALZATE
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 82 of 132
1687
MICAHJOHN
SCOTT
1688
BECKY
HAASE
1689
CAMERON
COYNE
1690
CHARLES P
BILBERY
1691
JESSIE
GORE
1692
ANDREW
ZUTSHI
1693
MATTHEW
BRETHORST
1694
CALLIE LANAE
SMITH
1695
ALBERT FRANK
NURICK
1696
JAMILLAH A
HOWSE
1697
MARK
ARBEEN
1698
KRISTA-SIMONE
CLARK
1699
ANDREW L
POPE
1700
AMY
HAHN
1701
JOHNNIE K
HOLLIS
1702
ROLANDO GARCIA
ESQUIVEL
1703
STACI
BELONOS
1704
BRANDON
RAMOS
1705
NATHAN THOMAS
WALTON
1706
JOSHUA
SIMPSON
1707
CYNTHIA
MOSS
1708
JOSEPH BAKER
PHILLIPS
1709
TAMMIJO
COX
1710
CODEE
HALL
1711
DANIEL
SWEARINGEN
1712
GAYLE
FLICK
1713
TIMOTHY
AUSTIN
1714
TAVARES DESHUN
HOYLE
1715
LAURA
ZUKER
1716
FRANCISCO
TRINIDAD
1717
PAUL
POLLARD
1718
RACHAEL C
GURSKY
1719
FRANKY
HOPKINS
1720
SHARON A
MOTLEY
1721
RACHEL
HAMPTON
1722
DANA
MCCOY
1723
KENNETH
PEAGLER
1724 CRAIG JOHN CHARLES
SCOTT
1725
MICHAEL JOSEPH
EDWARDS
1726
CLARENCE TREVAN
SIMMONS
1727
BRANDI
LEMOI
1728
VENU MADHAV
SAYANI
1729
BOBBY RAY
COFIELD
1730
CHAD ANGELO
RODERICK
1731
CAROLINE ELAINE
VERMERRIS
1732
SUNNY J
HINDMAN
1733
CLINT
RICHARDS
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 83 of 132
1734
CHRISTOPHER
SELLE
1735
WILLIAM PAUL
BARTHOLOMEW
1736
TYSON ELMER
DEWSNUP
1737
CHRISTY ANN
GRAYSON
1738
COLIN
CHAPMAN
1739 CHRISTOPHER MAURICE
COBB
1740
AYSIA
PARKER
1741
BRANDALYN MARIE
MORRIS
1742
JOEL KELVIN
HODSON
1743
CHRISTOPHER M
SALLEY
1744
SOPHEAK
CHHOY
1745
DARIUS
BRUNER II
1746
APRIL
ELLIS
1747
DANNY
VULF
1748
MAXWELL
KRALL-RYSDON
1749
MATTHEW
STEENBERGH
1750
TIMOTHY
SPIELMAN JR
1751
KO
CHARAN
1752
CHAVIS
ALFARO-KIYOTSUKA
1753
TRE
GREEN
1754
KLINTEN BRADLEY
CRAIG
1755
JULIA
ATTOULEH
1756
JEFF
DAVIS
1757
JOSHUA
OLIVER
1758
HANNAH
BAILEY
1759
MICHAEL
KING
1760
LINDSAY
JETER
1761
JAMES
ROBERTS
1762
ASMIR
ZUNIC
1763
EDWIN XAVIER
CINTRON
1764
MOHAMMED
SESAY
1765
NICOLE
SHOBEL
1766
RYAN
GOODNIGHT
1767
SETH
THOMAS
1768
ISABELLE
KHUU
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 84 of 132
Exhibit E
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 85 of 132
1 ALICE M
BROWN
2 CARLOS SANCHE
RAMIREZ
3 PETER
RUDINSKAS
4 MARCOS A
MARTINEZ
5 MICHAEL
EARLE
6 CHRISTI M
PADILLA
7 MICHAEL
SMITH
In re Plaid, Inc. Privacy Litigation
Late Opt Out Requests
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 86 of 132
Exhibit F
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 87 of 132
Case 4:20-cv-03056-DMR Document 154 Filed 01/24/22 Page 1 of 1
Friday,January 14,2022
In re Plaid Inc. Privacy Litigation, the case number is 4:20-cv-03056 -
Notice ID: PLO I 007509370
Confirmation Code: 5040A53475
To Whom It May Concern,
I received a settlement email about the case against Plaid Inc.
FU l ED
JAii 24 2022
CLERK, U.S. DISTRICT
NORTHERN DIST~ COURT
D
CALIFORNIA
I do not intend to appear in cou1t. I just want to make a comment on something that I 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 and feel of the user's own bank account
login screen, when users were actual~v 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.
s7;rel~
JI~~
Richard Laven
5874 Woodbriar Dr NE
Belmont, MI 49306
rick@laven.net
616-551-9554
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 88 of 132
Case 4:20-cv-03056-DMR Document 154-1 Filed 01/24/22 Page 1 of 1
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 89 of 132
Exhibit G
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 90 of 132
FILED
Mark B. Busby
CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND
Jan 26 2022
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 1 of 7
1968 S. Coast Hwy, No. 755
Laguna Beach, CA 92651
Phone: ( 415) 829-9060
Fax:
(415) 500-4060
January 25, 2022
CALIFORNIA JUDICIAL INVESTIGATIONS
BSIS LIC No. 24115
Via U.S. Mail and Electronic Mail dmrcrd@cand.uscourts.gov
Honorable Magistrate Judge Donna M. Ryu
United States District Court
Northern District of California
Oakland Courthouse, Courtroom 4 - 3rd Floor
1301 Clay Street, Oakland, CA 94612
RE:
Cottle v Plaid, Inc.
Case No. 20-cv-03056-DMR
Dear Honorable Magistrate Judge Donna M. Ryu,
Website: www.calji.com
Email: admin@calji.com
It is my understanding that a settlement has been reached in the above-reference matter.
Please accept this as a formal objection to the settlement until the following has been
addressed by this court.
The Plaintiff's counsel apparently subcontracted notice of settlement to a company operating
out of Pennsylvania. On or about January 12, 2022, an email was sent out to class members.
In part, the email provided limited information about the claim and how to obtain a payment.
First, the notice lacks any specific link that takes the claimant to a claims form. It requires that
the party cut/paste text from the email and open a new page to reach the claim form. It is my
belief that this is designed purposely to limit the number of claims that are filed. If the goal was
to promote a response, a link to submit a claim would have been included.
Second, the claim form itself is defective and does not work. Once I reached the correct website
and clicked on SUBMIT A CLAIM, I entered valid bank details. I was repeatedly presented with
an "error" code which stated the account information I provided was invalid - when in fact the
information is valid. That said, myself and others similarly situated would typically give up and
close the window - forgoing any payment due.
Third, and most importantly, the website claim form denies equal access of settlement funds to
all class members. Specifically, the online claim form offers only three methods to be paid.
The claimant must select only ONE of the following options: PayPal, Ven mo or Direct Deposit
to a bank account. This places a condition to be paid - the claimant must have an account with
a financial institution, or they cannot get paid. This denies payment to those without a bank
account (i.e. homeless, indigent, those who can't quality for a bank account, etc). The
"Balancing the Scales of Justice."
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 91 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 2 of 7
January 25, 2022
California Judicial Investigations
Page2 of2
convenience to the claims administrator of paying all claims electronically must take a back seat
to ensuring that all payments reach their intended class members.
For these reasons, I respectfully request this court to suspend final settlement of this case until
the Plaintiff can provide proof to the court that these concerns have been addressed.
Thank you for your consideration.
oseph P. Soldis
Investigator Pl24115
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 92 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 3 of 7
1/25/22, 3:08 PM
Yahoo Mail - Notice of Class Action Settlement - In re Plaid Inc. Privacy Litigation
Notice of Class Action Settlement - In re Plaid Inc. Privacy Litigation
From: Settlement Administrator (donotreply@plaidsettlement.com)
To:
Date: Wednesday, January 12, 2022, 02:41 AM PST
Notice ID: PLD1010341268
Confirmation Code: 798D68C581
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-aRRroved 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;
• 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
1/2
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 93 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 4 of 7
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 94 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 5 of 7
1/25/22, 3:09 PM
Yahoo Mail - Notice of Class Action Settlement - In re Plaid Inc. Privacy Litigation
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.
Unsubscribe
2/2
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 95 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 6 of 7
I
n1te
tates 1stnct ourt or t e ort ern 1stnct o
a I orn1a
HOlvl E
SUBMIT A CLAIM
IMPORTANT DOCUMENTS
SEARC
FOR A P/ SERVICE
F QS
CO TACT US
Your claim must be submitted online by April 28, 2022. You may only submit one Claim Form. If you have any questions, please contact
the Settlement Administrator by em,111 c1l Qucslions,&PlaidScttlcrncnt.corn or by mail at Piaf(/ Jnr. Prilacy Litigation, c/o Settlement
Administrator, 1650 Arch Street, Suite 2210, Philadelphia, PA 19103.
I. YOU R CONTACT INFORMATION AND MAILING ADDRESS
Provide your name and contact information below. You must notify the Settlement Administrator if your contact Information changes after you
submit this form.
First Name ·
Last Na, e'
Street Address ·
City ·
State ·
L
-- ~
Email Address · Required
Co firm Email Address ·
' Required Fields
II. PAYMENT SELECTION
Please select Q11g of tt1e following payment options:
Payment Options
PayPal
venmo
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III. ATTESTATION UNDER PENALTY OF PERJURY
Zip Code ·
10 • .
DEPOSl1
By signing below and submitting th15 Clann form, I hereby swear under penaltv of pequry tha the 111or111at1or provided 111 this Claim Form 1~
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 96 of 132
Case 4:20-cv-03056-DMR Document 155 Filed 01/26/22 Page 7 of 7
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 97 of 132
Exhibit H
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 98 of 132
Case 4:20-cv-03056-DMR Document 158 Filed 02/01/22 Page 1 of 3
Dear Sir/ Madam / Your Honor
RECEIVED
JAN 31 2022
CLERK, U.S. DISTRICT COURT
I object to the settlement for the following ca~RTHERN DISTRICT OF ~
IFORNIA
ILE D
JAN 31 2022
CLERK, U.S. DISTRICT COURT
NORTHERN DISTRl~T ~
FORNIA
In re Plaid Inc. Privacy Litigation, the case number is 4:20-cv-03056 - G 'M\e-
()
I believe I am a class member based on 3 things. 1) My receipt of information from the lawyers
in this case stating that I am a member of the class settlement (Notice ID: PLD1025387226
Confirmation Code: 6A 1586FOAA). 2) My own recollection of having used plaid repeatedly
between January 2013, and Novemember 2021 , and 3) The plaid dashboard (at my.plaid.com)
indicates that I have accounts and connections via the service.
My full name is Colin Larimer Rice, My mailing address is 155 Washington St, Apt 714, Jersey
City, NJ, 07302. M.y_email address_fmJbe pu[p_oses of this_ corresponde• c.ais
plaidsettlementobjection@daed rum. net.
My objection to this settlement is over the unethical behaviour of the attorneys involved.
My first objection is that the settlemenent website (https://www.plaidsettlement.com/), does not
enumerate the lawyers fees or the amount of potential claimants. As is typical in american
settlement cases - the lawyers fees per person amount to a usurious fraction, and the payouts
per person are trivial. In this case, with a 10 million number of claimants, and a 30% lawyer fee
(both of which I believe are conservate numbers and are undisclosed in the settlement website)
amounts to less than a 5$ payout. This is so small that suing in small claims court would be
better for the average american. Quite frankly, this amount of money is likely to be so small, that
I may lose money on the literal letter I could use to send the letter in to accept the settlement.
This has proven to be true in every single settlement claim I've been involved with, so I despair
that this claim will be different.
Additionally, I believe that the lawyers involved in this case are behaving unethically in their
settlement outreach + acceptence. In order to sign up for this settlement - one may go online to
https://www.plaidsettlement.com/ and electronically register your acceptance of the settlement.
Additionally, the lawyers reached out to me, a claimant, digitally via the email system. However,
to reject the settlement, one must fill out a paper letter and mail it in. This unequal treatment 1)
allows lawyers to increase their fees by making it harder for claimants to remove themselves
from the settlement, 2) shows the clear bias of the lawyers involved as to which action they
would prefer claimants take. It must be as simple for a claimant to reject a settlement as to
accept it. There must not be bias in the behaviour of lawyers attempting to represent unknown
claimants - particularly those who may not be familiar with the legal system.
I urge the court to reject this settlement and force a new one to be made which clearly discloses
the lawyers fees, the number of settlements, includes a reasonable amount of money (>100$
per potential claimant), and allows for claimants to join or exit the settlement via the same
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 99 of 132
Case 4:20-cv-03056-DMR Document 158 Filed 02/01/22 Page 2 of 3
methods in a non prejudicial manner. Additionally - I urge the court to refer the laywers in this
case to their respective ethics boards for unethical behaviour.
On a personal note - My largest loss via class action settlement was roughly 6 figures of wage
suppression, which provided a <5$ payout due to unclear settlement notices.
Thank you for your consideration
I will not be attending the Final Approval Hearing in person, or via an attorney representing me.
If my letter is insufficient to be presented to the court, please inform me via email as I would like
to 1) amend it to be sufficient for presentation to the court, and 2) attach additional unethical
actions by the lawyers, re: inability to correctly instruct claimints on how to object to the
settlement.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 100 of 132
Case 4:20-cv-03056-DMR Document 158 Filed 02/01/22 Page 3 of 3
505809-25-24-PRI
Colin Rice
155 Washington St
Apt 714
Jersey City, NJ 07302
1•••••••••••••••••••••••••• sNGLP 480
Clerk of Court, US District Court
for the Northern District of California
1301 Clay Street
Oakland, CA 94612
'
.
CERTIFIED MAIL
USPS CERTIFIED MAIL TM
111111 I II
111
9214 8901 3247 3400 1547 0807 50
SIGNATURE REQUIRED PER DMM 3.1.1
111••11••1••l111•1111••11l••h•l111•h1•1111 11 1111•11111l11111•1 1
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 101 of 132
Exhibit I
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 102 of 132
Case 4:20-cv-03056-DMR Document 161 Filed 03/01/22 Page 1 of 4
Your Honor,
FILED
MAR 01 2022
-fy'
CLERK, U.S. DISl'RICT COURT
NORTHERN DISTRICT OF CAL!F~R__NIA
John William Grosklaus
1845 E Northgate Dr #407
Irving, TX 75062
j ohngrosklaus@gmail.com
(773) 554-6291
2/22/2022
I write today to object to the Proposed Settlement of In re Plaid Inc. Privacy Litigation, Case #
4:20-cv-03056. I have substantial reason to believe that I am a member of the Class, as I was
notified of such by the Settlement Administrator on January 17111 by electronic mail (Notice ID:
PLD1036219428 and Confirmation Code: MAC2D01D2A), have strong personal recollection of
linking various accounts and apps via Plaid Link between January 1, 2013 and November 19, 2021,
and by using Plaid Portal, have identified 7 accounts connected using Plaid to 12 apps. As part of
verifying this through Plaid Portal, I had to re-share my account credentials, which did not happen
through what could visibly be identified as an external domain's OAuth Process, and the tendency
to receive emails after linking an account to Plaid at certain institutions saying "a new device has
been added" (rather than indicating a link to Plaid) makes me ( combined with the notification from
the Settlement Administrator) reasonably certain that not all of them are managed OAuth
processes. The nature of the reason many of the listed apps were linked via Plaid makes me certain
they occurred during the time period in question, such as one link that occurred during the process
of applying for a credit card back in Spring 2021 soon after I turned 18.
I am not an attorney, am not represented by any counsel in making this objection, have no
connection to Plaid Inc other than the aforementioned use of their services, and am not attempting
to object for my own personal gain by seeking payment to drop an objection. Rather, I am an 18
year old college student, who simply received notice of the Settlement and thought it didn't seem
fair. As such, if it is determined that I have made a technical error, I request that you contact me
so I can cure the issue rather than simply dismissing my objection altogether. At this time, I am
not intending to physically attend the Final Approval Hearing in-person due to the impracticality
of me travelling to Oakland, but should the hearing become remotely accessible via Zoom (or
similar audio/videoconferencing technology), I will vi1tually be in attendance and wish to speak
to the Court. Regardless of the format and/or my attendance, I will not be represented by any
counsel.
The Proposed Settlement is unfair and should be rejected because it does not account for the fact
that Class Members may have significant differences in the amount of data that was unknowingly
and/or unnecessarily provided to Plaid. Under the current arrangement of the Settlement, all Class
Members (except the Class Representatives) will receive the same monetary benefit. One of the
most common use cases for Plaid Link is for services like SoFi Relay (and many others) to combine
information from a variety of Financial Accounts into one dashboard, allowing for combined
visualization of assets, liabilities, spending, and income. This encourages users to connect every
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 103 of 132
Case 4:20-cv-03056-DMR Document 161 Filed 03/01/22 Page 2 of 4
Financial Account possible. Depending on the financial affairs of the user, this could mean linking
multiple Checking, Savings, Retirement, Investing, Credit Card, Mortgage, HELOC, Student
Loan, Auto Loan, and Personal Loan accounts- all at different institutions. This contrasts with the
other common use case for Plaid, which is simply verifying the ownership and details of one
Account for the purpose of making ACH transfers. I used Plaid for both cases, under the reasonable
impression (I would imagine similar to most of the Class) that my Plaid was simply verifying my
identity and serving as a "bridge" between the two institutions- not accessing the data itself. As
such, I unknowingly was providing Plaid an incredibly detailed picture of my financial affairs. It
just does not make sense that I should receive the same amount of compensation as someone who
simply linked one account (say to minimize fees related to a charitable donation), and possibly did
not even have transaction data shared.
In addition to these concerns, I ask that Your Honor give strong consideration to the objection
raised by my fellow Class Member Colin Rice. Mr. Rice's concerns regarding the amount of
compensation for Class Counsel relative to the expected compensation for Class Members, and
the disparity between the process for filing a claim vs. opting out of the settlement. All of these
issues combined give significant reason for the Settlement to be rejected by the Court. I thank Your
Honor for your time, and make a final prayer that you reject this proposal- maybe then Class
Counsel can negotiate a new proposed settlement that offers just and adequate compensation for
Plaid's actions.
Sincerely,
John William Grosklaus
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 104 of 132
Case 4:20-cv-03056-DMR Document 161 Filed 03/01/22 Page 3 of 4
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Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 105 of 132
Case 4:20-cv-03056-DMR Document 161 Filed 03/01/22 Page 4 of 4
L
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 106 of 132
Exhibit J
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 107 of 132
1
Steven Helfand, in pro se
410 SE 16th Court, Apartment 730
Fort Lauderdale, FL 33316
Steven.helfand1400@outlook.com
786.676.1018
Objector and absent class member
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
IN RE PLAID INC. PRIVACY LITIGATION:
Master Docket No.: 4:20-cv-03056 DMR
THIS DOCUMENT RELATES TO: ALL ACTIONS.
OBJECTION AND NOTICE OF
INTENTION TO APPEAR
Date: May 12, 2022
Time: 1:00 p.m.
Ctrm: Videoconference
Judge: The Hon. Donna M. Ryu
CLASS MEMBERSHIP
I am a class member in the above referenced case. My notice ID is PLD1036874260. My
confirmation code is 72089AF62D. I submitted a claim on January 30, 2022, at 6:01:46 AM. My
contact information is listed in the caption. This is sufficient evidence of class membership. I
intend to appear at the fairness hearing.
OBJECTIONS
STRUCTURAL PROBLEM WITH NOTICE AND JURISDICTION
The Notice is misleading and violates due process. This implicates jurisdictional
concerns. See, Molski v. Gleich, 318 F.3d 937 (9th Cir. 2002). Here, the notice implies,
erroneously, that the judge overseeing this case is an Article III judge, when she is not. See,
Notice, § 26 [“Please check www.PlaidSettlement.com, or Judge Donna M. Ryu’s Calendar
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 108 of 132
2
[website link for federal court omitted here] for any updates about the Settlement and Final
Approval Hearing”]. In fact, the Notice should have indicated “Magistrate Judge,” and not
“Judge.” There is a case out of the Seventh Circuit directly on point: Williams v. GE Capital 159
F.3d 266, 269-270 (7th Cir. 1997).
“Alternatively, the unnamed class member could try to show in a collateral attack that
the decision to proceed before a magistrate judge was a matter on which there was a potential
(or, in the light of the fully developed record, an actual) significant intra-class conflict and that
the notice the absentee received was inadequate to inform her of this conflict. [citations
omitted here]. “In this case, the ‘Notice of Pendency of Class Action, and Notice of Proposed
Settlement and Hearing Thereon’ that went to the unnamed Williams class members clearly
indicated that the lawsuit was before ‘Magistrate Judge Joan H. Lefkow.’ Due process requires
no more.”
Here, class members were not put on sufficient notice of the Court’s status within the
constitutional system; and suggested, wrongly, that it was an Article III court.
The issue is important. In 1968, Congress enacted the Federal Magistrates Act to
enhance judicial efficiency in the federal courts. Since then, some judicial functions delegated
to magistrate judges have been challenged on constitutional grounds: while federal district
judges, appointed pursuant to Article III of the United States Constitution, are protected with
life tenure and undiminishable salary, thereby enhancing judicial independence, federal
magistrate judges, appointed pursuant to Article I, have no such protection.
While a Magistrate Judge plainly has the authority to determine the fairness of a
proposed settlement with the consent of the named parties, one reason the district court
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 109 of 132
3
should consider voiding a reference to a magistrate sua sponte is where the rights of numerous
parties not present before the court might be affected by the decision. See, Pacemaker
Diagnostic Clinic of America v. Instromedix, Inc., 725 F.2d 537, 545 (9th Cir. 1984) (en
banc)(Kennedy, J.)(one reason district court should consider voiding a reference to a magistrate
sua sponte is where "rights of numerous parties not present before the court might be affected
by the decision"). Here, the reference should be voided due to the problem with the Notice
and because of the magnitude of the class. It is claimed that the Settlement Class includes
approximately 98 million consumers.
Parties consenting to allow a magistrate judge to hear a civil action deprive Article III
judges of the essential attributes of judicial power. In light of inaccurate notice, the case should
be referred to an Article III judge, precisely as the notice contemplates. Williams notes, “It may
also be open to the unnamed class members to present such an argument directly to an Article
III judge of the district court; because the record does not indicate that the plaintiffs made any
effort to do so here, we offer no definitive view on the matter.” Williams, at 270. As such, I
specifically request that this matter be referred back to an Article III judge for evaluation of
fairness under Rule 23.
THE PLAID PORTAL PROVIDES VALUABLE CONSIDERATION AND THE PROPOSED SETTLEMENT
SHOULD BE APPROVED
Given that individual recoveries are likely not going to be significant, the portal is one
aspect of the overall compensation to be provided the class that is most exciting. It is an
important aspect of the settlement but receives very little description in the Settlement
Agreement and minimal discussion in the briefs. The portal to some extent appears to be a
work in progress and is evolving. This is reasonable because the portal must be dynamic to
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 110 of 132
4
keep class members’ interest. If the Court overrules my initial objection, I support approval of
the proposed settlement.
In fact, the concept of the portal provides valuable consideration to the class. However,
the parties should continue to enhance the user experience and stipulate that the portal and
the primary features offered through it are always available free of charge to class members.
Plaid should also not be allowed to use the portal to, for example, bombard class members with
marketing materials from third parties or to sell services. Its primary purpose must be
informational. Apart from the availability of the portal free of charge, the Court and the
settling parties should resist the urge to place requirements on the portal as this might disrupt
what should be continual enhancements to the user experience. This would damage what
appears to be a genuine effort to provide meaningful information to class members.
HERRERA KENNEDY LLP HAS INFLATED RATES AND DUPLICATED THE WORK
The parties seek a benchmark award. But the lodestar cross check reveals a substantial
multiplier, well excess of 3. This excessive multiplier is based on already, very high hourly rates
and utilization of timekeepers in place of lower cost associates to handle much of the work.
Herrera Kennedy LLP’s fees are simply in outer space. Moreover, Herrera Kennedy LLP
duplicated the work of LCHB and Burns Charest. There was simply no underlying reason for
Herrera Kennedy LLP’s extensive involvement in this case when the class was already more than
adequately represented by LCHB and Burns Charest. This is underscored because Herrera
Kennedy LLP evidently retains no modest timekeepers who were capable of performing routine
litigation tasks not requiring billings at $825 per hour and greater.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 111 of 132
5
The lowest cost timekeeper at Herrera Kennedy LLP is $825 per hour. Meanwhile, at
LCHB, the firm appropriately used a mix of timekeepers, presumably based on the type of work
required. For example, there is a timekeeper listed at $370 per hour. Burns Charest is similar
to LCHB. While Burns Charest lists a $1,000+ hourly rate for Warren Burns, his billings, along
with other timekeepers, is, appropriately, modest. Burns Charest also had mixed timekeepers
with rates as low as $325 per hour. The captain(s) of the ship should have high rates; but not if
they are rowing.
Quite frankly, the class would have been better served by simply appointing LCHB and
Burns Charest as the class attorneys and firing everyone else from Herrera Kennedy LLP. There
is little question that LCHB could have handled this case on its own. LCHB is already more than
adequate and had Burns Charest further augmenting them. It is unclear what distinct services
were required to be performed by Herrera Kennedy LLP or why class members should be
compelled to pay its artificially high rates when they already had outstanding attorneys
representing them and charging reasonable fees.
I take no issue with the fees requested by LCHB and Burns Charest. However, I dispute
the rates used by Herrera Kennedy LLP and their failure to use lower cost timekeepers. What is
particularly untoward is that Herrera Kennedy LLP is using inflated rates that may result in class
attorneys at LCHB and Burnest Charest receiving less compensation. Had more modestly priced
timekeepers been properly utilized by Herrera Kennedy LLP, it is plain the true multiplier here is
upwards of 4 plus. This is too much.
March 3, 2022
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 112 of 132
6
___________________________
Steven Helfand
Objector and absent class member
PROOF OF SERVICE
A copy of this objection was furnished to the Court by One Legal on March 3, 2022. The
address for the Court is: Clerk of Court, United States District Court for the Northern District of
California, 1301 Clay Street, Oakland, CA 94612. This objection was sent electronically to the
aforementioned:
COOLEY LLP
Michael Rhodes
rhodesmg@cooley.com
HERRERA KENNEDY LLP
Shawn M. Kennedy
skennedy@herrerakennedy.com
LCHB
Rachel Geman
rgeman@lchb.com
BURNS CHAREST LLP
Christopher J. Cormier
ccormier@burnscharest.com
I declare that this declaration is executed under penalty of perjury under the laws of the
United States of America on March 3, 2022.
___________________________
Steven Helfand
Objector and absent class member
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 113 of 132
1
Steven Helfand, in pro se
410 SE 16th Court, Apartment 730
Fort Lauderdale, FL 33316
Steven.helfand1400@outlook.com
786.676.1018
Objector and absent class member
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
IN RE PLAID INC. PRIVACY LITIGATION:
Master Docket No.: 4:20-cv-03056 DMR
THIS DOCUMENT RELATES TO: ALL ACTIONS.
OBJECTION AND NOTICE OF
INTENTION TO APPEAR
Date: May 12, 2022
Time: 1:00 p.m.
Ctrm: Videoconference
Judge: The Hon. Donna M. Ryu
CLASS MEMBERSHIP
I am a class member in the above referenced case. My notice ID is PLD1036874260. My
confirmation code is 72089AF62D. I submitted a claim on January 30, 2022, at 6:01:46 AM. My
contact information is listed in the caption. This is sufficient evidence of class membership. I
intend to appear at the fairness hearing.
OBJECTIONS
STRUCTURAL PROBLEM WITH NOTICE AND JURISDICTION
The Notice is misleading and violates due process. This implicates jurisdictional
concerns. See, Molski v. Gleich, 318 F.3d 937 (9th Cir. 2002). Here, the notice implies,
erroneously, that the judge overseeing this case is an Article III judge, when she is not. See,
Notice, § 26 [“Please check www.PlaidSettlement.com, or Judge Donna M. Ryu’s Calendar
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 1 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 114 of 132
2
[website link for federal court omitted here] for any updates about the Settlement and Final
Approval Hearing”]. In fact, the Notice should have indicated “Magistrate Judge,” and not
“Judge.” There is a case out of the Seventh Circuit directly on point: Williams v. GE Capital 159
F.3d 266, 269-270 (7th Cir. 1997).
“Alternatively, the unnamed class member could try to show in a collateral attack that
the decision to proceed before a magistrate judge was a matter on which there was a potential
(or, in the light of the fully developed record, an actual) significant intra-class conflict and that
the notice the absentee received was inadequate to inform her of this conflict. [citations
omitted here]. “In this case, the ‘Notice of Pendency of Class Action, and Notice of Proposed
Settlement and Hearing Thereon’ that went to the unnamed Williams class members clearly
indicated that the lawsuit was before ‘Magistrate Judge Joan H. Lefkow.’ Due process requires
no more.”
Here, class members were not put on sufficient notice of the Court’s status within the
constitutional system; and suggested, wrongly, that it was an Article III court.
The issue is important. In 1968, Congress enacted the Federal Magistrates Act to
enhance judicial efficiency in the federal courts. Since then, some judicial functions delegated
to magistrate judges have been challenged on constitutional grounds: while federal district
judges, appointed pursuant to Article III of the United States Constitution, are protected with
life tenure and undiminishable salary, thereby enhancing judicial independence, federal
magistrate judges, appointed pursuant to Article I, have no such protection.
While a Magistrate Judge plainly has the authority to determine the fairness of a
proposed settlement with the consent of the named parties, one reason the district court
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 2 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 115 of 132
3
should consider voiding a reference to a magistrate sua sponte is where the rights of numerous
parties not present before the court might be affected by the decision. See, Pacemaker
Diagnostic Clinic of America v. Instromedix, Inc., 725 F.2d 537, 545 (9th Cir. 1984) (en
banc)(Kennedy, J.)(one reason district court should consider voiding a reference to a magistrate
sua sponte is where "rights of numerous parties not present before the court might be affected
by the decision"). Here, the reference should be voided due to the problem with the Notice
and because of the magnitude of the class. It is claimed that the Settlement Class includes
approximately 98 million consumers.
Parties consenting to allow a magistrate judge to hear a civil action deprive Article III
judges of the essential attributes of judicial power. In light of inaccurate notice, the case should
be referred to an Article III judge, precisely as the notice contemplates. Williams notes, “It may
also be open to the unnamed class members to present such an argument directly to an Article
III judge of the district court; because the record does not indicate that the plaintiffs made any
effort to do so here, we offer no definitive view on the matter.” Williams, at 270. As such, I
specifically request that this matter be referred back to an Article III judge for evaluation of
fairness under Rule 23.
THE PLAID PORTAL PROVIDES VALUABLE CONSIDERATION AND THE PROPOSED SETTLEMENT
SHOULD BE APPROVED
Given that individual recoveries are likely not going to be significant, the portal is one
aspect of the overall compensation to be provided the class that is most exciting. It is an
important aspect of the settlement but receives very little description in the Settlement
Agreement and minimal discussion in the briefs. The portal to some extent appears to be a
work in progress and is evolving. This is reasonable because the portal must be dynamic to
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 3 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 116 of 132
4
keep class members’ interest. If the Court overrules my initial objection, I support approval of
the proposed settlement.
In fact, the concept of the portal provides valuable consideration to the class. However,
the parties should continue to enhance the user experience and stipulate that the portal and
the primary features offered through it are always available free of charge to class members.
Plaid should also not be allowed to use the portal to, for example, bombard class members with
marketing materials from third parties or to sell services. Its primary purpose must be
informational. Apart from the availability of the portal free of charge, the Court and the
settling parties should resist the urge to place requirements on the portal as this might disrupt
what should be continual enhancements to the user experience. This would damage what
appears to be a genuine effort to provide meaningful information to class members.
HERRERA KENNEDY LLP HAS INFLATED RATES AND DUPLICATED THE WORK
The parties seek a benchmark award. But the lodestar cross check reveals a substantial
multiplier, well excess of 3. This excessive multiplier is based on already, very high hourly rates
and utilization of timekeepers in place of lower cost associates to handle much of the work.
Herrera Kennedy LLP’s fees are simply in outer space. Moreover, Herrera Kennedy LLP
duplicated the work of LCHB and Burns Charest. There was simply no underlying reason for
Herrera Kennedy LLP’s extensive involvement in this case when the class was already more than
adequately represented by LCHB and Burns Charest. This is underscored because Herrera
Kennedy LLP evidently retains no modest timekeepers who were capable of performing routine
litigation tasks not requiring billings at $825 per hour and greater.
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 4 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 117 of 132
5
The lowest cost timekeeper at Herrera Kennedy LLP is $825 per hour. Meanwhile, at
LCHB, the firm appropriately used a mix of timekeepers, presumably based on the type of work
required. For example, there is a timekeeper listed at $370 per hour. Burns Charest is similar
to LCHB. While Burns Charest lists a $1,000+ hourly rate for Warren Burns, his billings, along
with other timekeepers, is, appropriately, modest. Burns Charest also had mixed timekeepers
with rates as low as $325 per hour. The captain(s) of the ship should have high rates; but not if
they are rowing.
Quite frankly, the class would have been better served by simply appointing LCHB and
Burns Charest as the class attorneys and firing everyone else from Herrera Kennedy LLP. There
is little question that LCHB could have handled this case on its own. LCHB is already more than
adequate and had Burns Charest further augmenting them. It is unclear what distinct services
were required to be performed by Herrera Kennedy LLP or why class members should be
compelled to pay its artificially high rates when they already had outstanding attorneys
representing them and charging reasonable fees.
I take no issue with the fees requested by LCHB and Burns Charest. However, I dispute
the rates used by Herrera Kennedy LLP and their failure to use lower cost timekeepers. What is
particularly untoward is that Herrera Kennedy LLP is using inflated rates that may result in class
attorneys at LCHB and Burnest Charest receiving less compensation. Had more modestly priced
timekeepers been properly utilized by Herrera Kennedy LLP, it is plain the true multiplier here is
upwards of 4 plus. This is too much.
March 3, 2022
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 5 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 118 of 132
6
___________________________
Steven Helfand
Objector and absent class member
PROOF OF SERVICE
A copy of this objection was furnished to the Court by One Legal on March 3, 2022. The
address for the Court is: Clerk of Court, United States District Court for the Northern District of
California, 1301 Clay Street, Oakland, CA 94612. This objection was sent electronically to the
aforementioned:
COOLEY LLP
Michael Rhodes
rhodesmg@cooley.com
HERRERA KENNEDY LLP
Shawn M. Kennedy
skennedy@herrerakennedy.com
LCHB
Rachel Geman
rgeman@lchb.com
BURNS CHAREST LLP
Christopher J. Cormier
ccormier@burnscharest.com
I declare that this declaration is executed under penalty of perjury under the laws of the
United States of America on March 3, 2022.
___________________________
Steven Helfand
Objector and absent class member
Case 4:20-cv-03056-DMR Document 162 Filed 03/03/22 Page 6 of 6
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 119 of 132
Case 4:20-cv-03056-DMR Document 162-1 Filed 03/03/22 Page 1 of 1
Steven Helfand, in prose
410 SE 16th Court, Apartment 730
Fort Lauderdale, FL 33316
Steven. helfand 1400@outlook.com
786.676.1018
Objector and absent class member
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
IN RE PLAID INC. PRIVACY LITIGATION:
THIS DOCUMENT RELATES TO: ALL ACTIONS.
Master Docket No.: 4:20-cv-03056 DMR
OBJECTION AND NOTICE OF
INTENTION TO APPEAR
Date:
Time:
Ctrm:
Judge:
CLASS MEMBERSHIP
May 12, 2022
1:00 p.m.
Videoconference
The Hon. Donna M. Ryu
I am a class member in the above referenced case. My notice ID is PLD1036874260. My
confirmation code is 72089AF62D. I submitted a claim on January 30, 2022, at 6:01:46 AM. My
contact information is listed in the caption. This is sufficient evidence of class membership. I
intend to appear at the fairness hearing.
OBJECTIONS
STRUCTURAL PROBLEM WITH NOTICE AND JURISDICTION
The Notice is misleading and violates due process. This implicates jurisdictional
concerns. See, Molski v. Gleich, 318 F.3d 937 (9th Cir. 2002). Here, the notice implies,
erroneously, that the judge overseeing this case is an Article Ill judge, when she is not. See,
Notice,§ 26 ["Please check www.PlaidSettlement.com, or Judge Donna M. Ryu's Calendar
1
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 120 of 132
Exhibit K
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 121 of 132
Case 4:20-cv-03056-DMR Document 171 Filed 05/03/22 Page 1 of 4
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
FILED
Mi,Y O 3 2022 ~
CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
Cottle et al. v. Plaid Inc
Plaintiffs,
Case No. : 4:20-cv-03056-DMR
Honorable Hon. Donna M. Ryu
v.
Plaid Inc.
Defendants.
REQUEST OF CLASS MEMBER TO SPEAK AT FINAL APPROVAL OF CLASS
ACTION SETTLEMENT
NOW COMES, RANDAL KRUEGER in pro personam and Objects to the Final
Judgment Granting Approval of Class Action Settlement based on the following:
1. Randal Krueger, hereinafter "Objecting Party", is an interested party in the Class
Action because he has suffered consequential damages through the use of Plaid.
2. Objecting Party moves the Court, pursuant to Fed. R. Civ. P. 60(bX6), for relief from
the Final Judgment Order .
.....,_ ___ -::---------· --~-- ----
-
--
----
3. Objecting Party used Plaid services.
4. Objecting Party was not properly notified of the Class Action until Claimant looked his
his junk email and seen a claim was due on April 28, 2022 on April 28, 2022
and cannot be held to the terms of the class order.
5. Objecting Party received no other notice of this Class Claim.
6. Object party objects to Class Counsel's request for reimbursement of reasonable
litigation expenses, attorney costs and the Objecting Party has filed a timely objection to the
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 122 of 132
Case 4:20-cv-03056-DMR Document 171 Filed 05/03/22 Page 2 of 4
Final Judgment. The motive behind the Objection is that Objecting Party's damages exceed the
current class settlement would only pay slight damages and the majority go to a Class
Administer who allegedly did not send proper notice to Claimant.
WHEREFORE Objecting Party does hereby objects to the proposed Class Settlement and
wishes to speak against the fees charged is this case for both legal expenses and Class
Administer .
April 291'\ 2022
Objecting Party (Randal Krueger)
Isl Randal Krueger
1098 Ann Arbor Rd W #114
Plymouth, MI 48170
contact@randalkrueger.com
734 249 8131
CERTIFICATE OF SERVICE
I, Randal C. Krueger hereby certify that on April 2911\ 2022, I electronically filed this request with
all class counsel on record and with the Clerk of the Court using the USPS FIRST CLASS MAIL
of such filing was sent to all counsel of record via electronic means only and via US Mail upon:
- 'Io:
Magistrate Judge Do1ma M. Ryu
Oakland Courthouse, Courtroom 4 - 3rd Floor
1301 Clay Street, Oakland, CA 94612
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 123 of 132
Case 4:20-cv-03056-DMR Document 171 Filed 05/03/22 Page 3 of 4
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 124 of 132
Case 4:20-cv-03056-DMR Document 171 Filed 05/03/22 Page 4 of 4
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 125 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 1 of 6
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
F l ED
MAY O 5 2022 -J,&
CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
Cottle et al. v. Plaid Inc
Plaintiffs,
Case No. : 4:20-cv-03056-DMR
Honorable Hon. Donna M. Ryu
V.
Plaid Inc.
Defendants.
NOTICE OF OBJECTION TO FINAL JUDGMENT GRANTING APPROVAL
OF CLASS ACTION SETTLEMENT
NOW COMES, RANDAL KREUGER in pro personam and Objects to the Final
Judgment Granting Approval of Class Action Settlement based on the following:
1. Randal Kreuger, hereinafter "Objecting Party", is an interested party in the Class
Action because he has suffered consequential damages through the use of Plaid.
2. Objecting Party moves the Comi, pursuant to Fed. R. Civ. P. 60(bX6), for relief from
the Final Judgment Order.
3. Objecting Party used Plaid services.
4. Objecting Party was not properly notified of the Class Action until Claimant looked his
his junk email and seen a claim was due on April 28, 2022 on April 28, 2022
and cannot be held to the terms of the class order. EXHBIT A
5. Objecting Pmiy received no other notice of this Class Claim.
6. Object pmiy objects to Class Counsel's request for reimbursement ofreasonable
litigation expenses.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 126 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 2 of 6
WHEREFORE Objecting Party does hereby object
April 28, 2022
Obj
BRIEF IN SUPPORT OF
NOTICE OF OBJECTION TO FINAL JUDGMENT GRANTING APPROVAL
OF CLASS ACTION SETTLMENT
NOW COMES, RANDAL KRUEGER in pro personam and submits this Brief in
Support of Objection to the Final Judgment Granting Approval of Class Action Settlement.
Facts
Legal Discussion and Argument
L FRCP 23(e)(5)(A). federal Rule of Civil Procedure 23(e)(5)(A) provides, in pertinent
part, that " [ a ]ny class member may object to the [ settlement] proposal if it requires comi approval
under" Rule 23(e). Notably, the Seventh Circuit has recognized that, under Rule 23(e), good-faith
objectors play a vital role in helping a district court shape a fair and equitable settlement of a class
action. Specifically, the Seventh Circuit has noted that "[w]hen defendants and class counsel seek
to settle a class action, the clash of adversaries on which our system depends is lost." Pearson v.
Target Corp., 968 F.3d 827,838 (7th Cir. 2020) (quotation marks omitted). As a result, the Seventh
Circuit has noted, "[t]he district judge must act as a fiduciary of the class in deciding whether to
approve a proposed settlement," and "must still rely on the now-allied adversaries to generate the
information that the judge needs to decide the case faithfully." Id. (quotation marks omitted).
Consequently, "[g]enuine adversary presentation is supplied, if at all, only by objecting class
members."
As a threshold matter, Objecting Paiiy, notes as required by Rule 23(e)(5)(A), that this
Objection applies to them and, potentially, to a similarly-situated subset of the plaintiff class, i.e.,
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 127 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 3 of 6
those class members who did not receive direct notice of this lawsuit, did not learn of the lawsuit
by way of the published notices, but in his spam email and was not alerted by employees about the
pendency of this action and their right to file a claim for damages.
In terms of the specific Objection to the Settlement Agreement, Objecting Party notes that
Section of the Settlement Agreement provides that "Class Notice shall be accomplished through a
combination of Mailed Notice, Publication Notice, a Settlement Website, and other applicable
forms of notice .. . . " The Settlement Agreement goes on to describe in detail the type of "Mailed
Notice" and "Publication Notice" to be utilized by the Class Action Settlement Administrator, and
also requires the Class Action Settlement Administrator to "establish a Settlement Website that
will inform members of the Class of the terms of th[ e] Agreement, their rights, dates, and deadlines,
and related information."
The Objecting Paiiy submits that the Settlement Agreement and the forms of notice outlined
therein overlooked and omitted an obvious yet important avenue of notice: Local Newspaper.
Similarly, the Eleventh Circuit recently noted that "[ o ]ften times objectors play a 'beneficial role
in opening a proposed settlement to scrutiny ai1d identifying areas that need improvement."'
II. FRCP 60(b)(6). Federal Rule of Civil Procedure 60(b)(6) provides, in pertinent part,
that " [ o ]n motion and just terms, the court may relieve a party . .. from a final judgment, order, or
proceeding" on the basis of "any other reason that justifies relief." Motions for relief under Rule
60(bX6) are not subject to a specific time limit. Instead, Rule 60(c)(l) requires them to "be made
within a reasonable time." Relief under Rule 60(bX6) is considered an "extraordinary remedy"
that should be granted only under "exceptional circumstances." Banks v. Chicago Bd. of
Educ.,750
F .3 d 663, 668 (7th Cir. 2014).
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 128 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 4 of 6
The Objecting Paiiy's motion for relief from judgment is unquestionably timely. As
noted, the Objecting Party first learned about the pendency of this action on April 28, 2022. The
Objecting Party submits that the circumstances that they have outlined are, in fact, exceptional
and justify the Court ordering the extraordinary remedy available under Rule 60(b )(6). As
discussed, Objectors timely and repeatedly filed this Objection the same day he learned of the
pendency, and complained to Angeion Employees about the problem.
Conclusion
The Objecting Party has filed a timely objection to the Final Judgment. The motive behind
the Objection is that Objecting Paiiy's damages exceed the cmTent class settlement would only pay
slight damages and the majority go to a Class Administer who allegedly did not send proper notice
to Claimant and Com1sel
The Objecting Paiiy seeks Objection granting finally approval from the class action as it
stands.
April 28th, 2022
/s/ Randal Krueger
1098 Ann Arbor Rd W #114
Plymouth, MI 481 70
contact@randalkrueger.com
734 249 8131
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 129 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 5 of 6
EXHIBIT A
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 130 of 132
Case 4:20-cv-03056-DMR Document 173 Filed 05/05/22 Page 6 of 6
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Reminder: File Your Claim by 4/28 in the Plaid Privacy Class Action
Settlement
Settlement Administrator <donotreply@plaidsettlement.com >
Thu 4/28/2022 7:49 AM
T o : -
Notice ID: PLD1054306735
Confirmation Code: D534DMA033
Plaid Privacy Litigation Settlement - Last Chance to Claim Your Settlement Payment
This is a Legal Notice. This is not an advertisement.
You may be eligible to claim a payment in the class action Settlement titled In re Plaid, Inc.
Privacy Litigation.
You are receiving this courtesy email to remind you the deadline to submit a claim in this action is
ARril 28, 2022. If you have already filed a claim, you do not need to file one again. This reminder
notice has been sent to ensure you are aware of the approaching claims filing deadline.
If you are a Class Member and would like to be eligible for a payment, you must submit a valid
claim form online or mail a claim form postmarked NO LATER THAN !Jwil 28, 2022.
Claim forms may be submitted online by clicking here: www.PlaidSettlement.com.
You can also click the video link to file your claim or to hear instructions on how to submit a claim.
You may also print a claim form from the Settlement website and mail it to the address on the
claim form ensuring it is postmarked by no later than ARril 28, 2022.
More About the Class Action Settlement
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 "Financia l 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.
Case 4:20-cv-03056-DMR Document 174-1 Filed 05/09/22 Page 131 of 132
Case 4:20-cv-03056-DMR Document 173-1 Filed 05/05/22 Page 1 of 1
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