NOTICE by Caroline Anderson, James Cottle, Rachel Curtis, David Evans, Logan Mitchell,… — Plaid Privacy (Dkt. 191)

Summary

Plaintiffs' Post-Distribution Accounting, Document 191 filed August 21, 2023 in In re Plaid Inc. Privacy Litigation, Master Docket No. 4:20-cv-03056-DMR, in the United States District Court for the Northern District of California. It is submitted with declarations of Denise Earle for Angeion Group, LLC, Melissa Gardner for Class Counsel, and Sheila Jambekar of Plaid Inc. The accounting reports a Total Settlement Fund of $58,000,000, 1,198,327 valid claims, 1,774 opt outs, and recovery per claimant of $35.97. It reports court-awarded attorneys' fees of $11,000,000 and $1,516,834.18 remaining in the Settlement Fund as of August 21, 2023. A section on non-monetary relief begins with data deletion from Plaid systems.

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2749446.7  
 
POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR  
 
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HERRERA KENNEDY LLP 
Shawn M. Kennedy (SBN 218472) 
skennedy@herrerakennedy.com 
Bret D. Hembd (SBN 272826) 
bhembd@herrerakennedy.com 
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
Tel: (949) 936-0900 
Fax: (855) 969-2050 
 
HERRERA KENNEDY LLP 
Nicomedes Sy Herrera (SBN 275332) 
nherrera@herrerakennedy.com 
Laura E. Seidl (SBN 269891) 
lseidl@herrerakennedy.com 
1300 Clay Street, Suite 600 
Oakland, CA 94612 
Tel: (510) 422-4700 
Fax: (855) 969-2050 
 
LIEFF CABRASER HEIMANN & 
BERNSTEIN, LLP 
Rachel Geman (Pro Hac Vice) 
rgeman@lchb.com 
250 Hudson Street, 8th Floor 
New York, NY 10013-1413 
Tel: (212) 355-9500 
Fax: (212) 355-9592 
Co-Lead Class Counsel 
LIEFF CABRASER HEIMANN &  
BERNSTEIN, LLP 
Michael W. Sobol (SBN 194857) 
msobol@lchb.com 
Melissa Gardner (SBN 289096) 
mgardner@lchb.com 
Michael K. Sheen (SBN 288284) 
msheen@lchb.com 
Nicholas R. Hartmann (SBN 301049) 
nhartmann@lchb.com 
275 Battery Street, 29th Floor 
San Francisco, CA 94111-3339 
Tel: (415) 956-1000 
Fax: (415) 956-1008 
BURNS CHAREST LLP 
Christopher J. Cormier (Pro Hac Vice) 
ccormier@burnscharest.com 
4725 Wisconsin Avenue, NW, Suite 200 
Washington, DC 20016 
Tel: (202) 577-3977 
Fax: (469) 444-5002 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
IN RE PLAID INC. PRIVACY  
LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
POST-DISTRIBUTION ACCOUNTING 
 
 
 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 1 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR  
 
Pursuant to the Court’s July 20, 2022 Order Granting Final Approval of Class Action 
Settlement (Dkt. 184 at 23), Class Counsel’s March 1, 2023 Status Report Regarding Settlement 
Fund Distribution (Dkt. 190), and this District’s Procedural Guidance for Class Action 
Settlements, Plaintiffs respectfully submit the following post-distribution accounting and 
supporting Declarations of Denise Earle on behalf of Angeion Group, LLC, the Court-appointed 
Settlement Administrator (“Angeion Decl.”); of Melissa Gardner on behalf of Class Counsel 
(“Gardner Decl.”); and of Sheila Jambekar, Chief Privacy Officer of Plaid Inc. (Gardner Decl. Ex. 
1, “Jambekar Decl.”).   
I. 
Post-Distribution Accounting 
The following is the post-distribution accounting for this matter, as set forth in the 
District’s Procedural Guidance for Class Action Settlements.   
Settlement Details 
Total Settlement Fund  
$58,000,000 
Approximate number of Class Members 
98,000,000 
 
Notice Details 
Methods of notice to Class Members 
E-mail, post card, custom social 
media, digital and social media, paid 
search campaign, sponsored class 
action website listings 
Number of Class Members to whom e-mail notice 
was sent 
60,271,546 
Number of Class Members to whom e-mail notice 
was sent and not returned as undeliverable 
58,787,099 
Number of Class Members to whom post card notice 
was sent 
650,669 
Number of post cards re-mailed to forwarding address  44,749 
Number of Class Members to whom post card notice 
was sent and not returned as undeliverable 
633,219 
Number of clicks-through on all digital noticing ads 
in initial campaign + reminder campaign 
334,516 
 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 2 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
Claim Forms, Exclusions, and Objections 
Number and Percentage of Valid Claims  
#: 1,198,327 
%: 1.22 
Number and Percentage of Opt Outs 
#: 1,774 
%: 0.0018 
Number and Percentage of Objections 
#: 5 
%: 0.000005 
 
Settlement Payment Details 
Recovery per claimant (pro rata share of Net 
Settlement Fund) 
$35.97 
Methods of payment to Class Members  
Direct deposit, PayPal, Venmo, and 
Mailed Check via USPS 
Number of successful digital payments distributed 
965,863 
Value of successful digital payments 
$34,742,092.11  
Number of physical checks distributed 
232,363 
Number of checks cashed 
187,744 
Value of cashed checks 
$6,753,151.68  
Number of checks uncashed 
44,619 
Value of checks uncashed 
$1,604,945.43 
Maximum court-approved administrative costs  
$5,500,000.00 
Total administrative costs 
$3,935,528.56 
Total court-approved service awards to Class 
Representatives 
$55,000 ($5,000 per Class 
Representative) 
Court-awarded costs and expenses 
$115,920.21 
Court-awarded attorneys’ fees 
$11,000,000 
Court-awarded attorneys’ fees as a percentage of the 
Settlement Fund 
19% 
Counsel’s adjusted lodestar at Final Approval 
$4,127,531.00 
Counsel’s updated adjusted lodestar total (through 
Aug. 4, 2023) 
$4,564,688.00 
Lodestar multiplier at Final Approval 
2.66 
Updated lodestar multiplier 
2.41 
Amount remaining in Settlement Fund (as of August 
21, 2023) 
$1,516,834.18 
See Angeion Decl. ¶¶ 3–4; Gardner Decl. ¶¶ 3–4; Dkt. No. 184 at 20–21.  
II. 
Non-Monetary Relief 
In addition to the monetary relief set forth in the above accounting, the Settlement 
includes injunctive relief that the Court rightly described as “significant” (Dkt. 184 at 15), 
“robust” (id. at 20), and “a meaningful benefit to Class Members and consumers going forward” 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 3 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
(id. at 16). That relief has conferred, and will continue to confer, the following benefits to Class 
Members.   
A. 
Data Deletion from Plaid Systems 
Plaid has deleted the data it retrieved by its “Transactions” product—which can include 
information about financial account activity, such as the amount, time, and place of deposits, 
withdrawals, transfers, or purchases—for users that connected their financial account(s) to an 
application (or applications) that did not ask Plaid to collect Transactions data. Settlement 
¶¶ 63(a); Jambekar Decl. ¶ 10.  
Separately, Plaid has deleted data from its systems for users that Plaid is aware it has no 
valid means to authenticate with the bank. Settlement ¶ 63(b); Jambekar Decl. ¶ 10. This means, 
for example, that if the password Plaid obtained for a particular bank account has changed or the 
account is closed, Plaid has deleted the associated account data from its systems.  
Plaid will maintain these data deletion practices for at least the next three years. 
Settlement ¶¶ 64–66; Jambekar Decl. ¶¶ 10–11.   
B. 
User Control Over Data Through Plaid Portal 
Plaid’s website (plaid.com) now includes prominent references and links to Plaid Portal 
(my.plaid.com) on its website homepage along with a plain-language description of the user 
controls available through the Plaid Portal. Settlement ¶ 54(a); Jambekar Decl. ¶ 3. By creating a 
Plaid Portal account, users (including Class Members) can view and manage the connections that 
have been made between apps and their financial accounts using Plaid. Class Members can also 
delete their financial data stored in Plaid’s systems. Settlement ¶ 58.   
Plaid makes reasonable commercial efforts to send periodic e-mail reminders to Plaid 
Portal account holders generally describing the user controls available in Plaid Portal, including, 
to the extent technically feasible, the ability to disconnect applications from financial accounts, 
and delete financial data stored in Plaid’s systems. Settlement ¶ 59; Jambekar Decl. ¶ 7. 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 4 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
C. 
Clear Disclosures at the Time of Account Connection 
To ensure clarity on Plaid’s role in the financial account connection process, and to ensure 
that users (including Class Members) clearly understand who they are sharing their information 
with and for what purposes, Plaid’s Link flow includes: 
 The credentials pane, meaning the pane where users enter their financial account 
username and password, explains that the user’s credentials are being “provided to 
Plaid.” 
 The background color of the credential pane will not utilize the color scheme 
associated with a specific financial institution for that financial institution. 
 The consent pane, meaning the pane where users agree to Plaid’s End User 
Privacy Policy and that Plaid will connect their application to their financial 
institution, continues to (a) refer expressly to Plaid and explain that Plaid is used to 
link the user’s accounts; (b) include a conspicuous link to Plaid’s End User 
Privacy Policy; and (c) require the user to agree to Plaid’s End User Privacy Policy 
by taking clear affirmative action (e.g., by clicking “Continue”).   
Settlement ¶ 56; Jambekar Decl. ¶ 5.   
Plaid makes reasonable commercial efforts to ensure that its customers using the standard 
Link flow continue to comply with these parameters, with certain limited exceptions. Settlement 
¶ 57; Jambekar Decl. ¶ 6. 
D. 
Minimizing the Data Plaid Stores 
Plaid is implementing changes to minimize the data it stores from users’ financial 
accounts as follows: 
 With respect to data retrieved from users’ financial accounts, subject to certain 
limitations such as for compliance with applicable law, Plaid will only store the 
categories of data for the Plaid product(s) that the user’s application specifically 
requests from Plaid or that are necessary for Plaid to offer its services, unless the 
user has expressly consented to the retrieval of additional data fields. 
 Plaid uses its best efforts to continue to inform the applications that use Plaid 
about its “/item/remove endpoint,” which is a means for those applications to 
inform Plaid that a user has terminated their account with the application, which 
then terminates the application’s access to data from Plaid and may lead to data 
deletion from Plaid’s systems (if such data is not actively used by another 
application).   
Settlement ¶¶ 60–62; Jambekar Decl. ¶¶ 8–9.   
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 5 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
E. 
Enhancing Disclosures About What Plaid Is and Does 
In addition to the disclosures and controls discussed above, on February 22, 2023, Plaid 
updated its End User Privacy Policy (“EUPP”) to provide more detail about Plaid’s data 
collection, storage, use, sharing, and deletion practices. See Jambekar Decl. ¶ 2. Per the 
Settlement, the updated EUPP: 
 Provides more detail about the categories of personal information Plaid collects 
from users’ financial accounts for each Plaid generally available product, including 
a plain-language list of the category or categories of personal information Plaid 
collects and a plain-language statement of the general reasons it is collected. 
 Provides more detail about how Plaid uses data, including by providing, for each 
category of personal information that Plaid collects about users, the categories of 
uses for which Plaid collects the information and the categories of parties with 
whom Plaid shares personal information (if any) (e.g., the developer of the user’s 
application). 
 Provides a plain-language explanation of Plaid’s deletion and retention practices 
related to personal information collected from users’ financial accounts. 
 Provides a dedicated section explaining in plain-language terms the privacy 
controls Plaid has made available to users (e.g., “Privacy Control Section”), 
regardless of whether those controls are guaranteed by any legal right.   
Settlement ¶ 53; Jambekar Decl. ¶ 2. 
III. 
Cy Pres Distribution 
As reported by the Settlement Administrator, $1,516,834.18, including earned interest, 
remains in the Settlement Fund following the deduction of all expenses, including outstanding 
expenses for administration, tax liabilities, distributions to the Class and the expiration of all 
mailed checks. Angeion Decl. ¶ 4. Pursuant to ¶ 78(b)(iv) of the Settlement, if a secondary pro 
rata distribution of these funds to Authorized Claimants (or a subset thereof) is not economically 
feasible, the Parties may direct the Settlement Administrator to distribute them pro rata to the Cy 
Pres Recipients(s) approved by the Court within forty-five (45) days after settlement checks have 
expired.   
Pursuant to ¶ 84 of the Settlement, Class Counsel proposed Cy Pres Recipients in 
Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement. Specifically, Class 
Counsel proposed the Privacy Rights Clearinghouse (“PRC”) and Consumer Reports (“CR”). 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 6 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
Dkt. 137-1 at 4; see also Dkt. 153 (Prelim. Approval Order) at 5.   
Class counsel have conferred with the Settlement Administrator and with counsel for 
Plaid, and have determined that a secondary distribution to Authorized Claimants in this action is 
not economically feasible. Angeion Decl. ¶ 5; Gardner Decl. ¶ 5. Class Counsel therefore intend 
to authorize the Settlement Administrator to distribute the remaining funds to PRC and CR. Each 
of PRC and CR will report to the Parties how it has used those funds pursuant to Settlement ¶ 85. 
Pursuant to Settlement ¶ 86, Plaid will not exercise any control or influence over PRC’s and CR’s 
expenditure of cy pres funds.   
 
Dated:  August 21, 2023 
 
Respectfully submitted, 
LIEFF CABRASER HEIMANN &  BERNSTEIN, LLP 
 
By: /s/ Rachel Geman            
       Rachel Geman 
LIEFF CABRASER HEIMANN & 
BERNSTEIN, LLP 
Rachel Geman (Pro Hac Vice) 
rgeman@lchb.com 
250 Hudson Street, 8th Floor 
New York, NY 10013-1413 
Tel: (212) 355-9500 
Fax: (212) 355-9592 
 
LIEFF CABRASER HEIMANN &  
BERNSTEIN, LLP 
Michael W. Sobol (SBN 194857) 
msobol@lchb.com 
Melissa Gardner (SBN 289096) 
mgardner@lchb.com 
Michael K. Sheen (SBN 288284) 
msheen@lchb.com 
Nicholas R. Hartmann (SBN 301049) 
nhartmann@lchb.com 
275 Battery Street, 29th Floor 
San Francisco, CA 94111-3339 
Tel: (415) 956-1000 
Fax: (415) 956-1008 
 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 7 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
 
HERRERA KENNEDY LLP 
 
By: /s/ Shawn Kennedy 
 
Shawn M. Kennedy 
HERRERA KENNEDY LLP 
Shawn M. Kennedy (SBN 218472) 
skennedy@herrerakennedy.com  
Bret D. Hembd (SBN 272826) 
bhembd@herrerakennedy.com  
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
Telephone: (949) 936-0900 
Fax: (855) 969-2050 
 
HERRERA KENNEDY LLP 
Nicomedes Sy Herrera (SBN 275332) 
nherrera@herrerakennedy.com 
Laura E. Seidl (SBN 269891) 
lseidl@herrerakennedy.com 
1300 Clay Street, Suite 600 
Oakland, CA 94612 
Telephone: (510) 422-4700 
Fax: (855) 969-2050 
 
 
 
BURNS CHAREST LLP 
 
By:  /s/ Christopher Cormier  
 
 
Christopher J. Cormier 
 
BURNS CHAREST LLP 
Christopher J. Cormier (Pro Hac Vice) 
ccormier@burnscharest.com 
4725 Wisconsin Avenue, NW 
Washington, DC 20016 
Tel: (202) 577-3977 
Fax: (469) 444-5002 
 
BURNS CHAREST LLP 
Warren T. Burns (Pro Hac Vice) 
wburns@burnscharest.com 
900 Jackson Street, Suite 500 
Dallas, TX 75202 
Tel: (469) 904-4550 
Fax: (469) 444-5002 
 
 
Co-Lead Class Counsel  
 
 
 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 8 of 9

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2749446.7  
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POST-DISTRIBUTION ACCOUNTING 
CASE NO. 4:20-CV-03056-DMR 
 
ATTESTATION 
Pursuant to Civil L.R. 5-1(i)(3), I hereby attest that concurrence in the filing of this 
document has been obtained from the above signatories. 
Dated:  August 21, 2023 
By: /s/ Melissa Gardner 
 
Case 4:20-cv-03056-DMR   Document 191   Filed 08/21/23   Page 9 of 9

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