Court filing
Angeion Declaration — Plaid Privacy (Dkt. 191.1)
Record facts
| Court | U.S. District Court for the Northern District of California |
|---|---|
| Filed | 2023-08-21 |
U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 191-1 · 2023-08-21 · Docket on CourtListener
Full text
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 DECLARATION OF SETTLEMENT ADMINISTRATOR Case No. 4:20-cv-03056-DMR UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION IN RE PLAID INC. PRIVACY LITIGATION Master Docket No.: 4:20-cv-03056-DMR DECLARATION OF DENISE EARLE OF ANGEION GROUP, LLC RE: POST- DISTRIBUTION ACCOUNTING I, Denise Earle, hereby declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the following is true and correct: 1. I am a Senior Project Manager at the class action notice and settlement administration firm, Angeion Group, LLC (“Angeion”). I am over 21 years of age and am not a party to this action. I am fully familiar with the facts contained herein based upon my personal knowledge. 2. Angeion was retained to serve as the Settlement Administrator to, among other tasks, distribute payments to valid claims and perform other duties as specified in the Class Action Settlement Agreement (“Agreement”). Case 4:20-cv-03056-DMR Document 191-1 Filed 08/21/23 Page 1 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 DECLARATION OF SETTLEMENT ADMINISTRATOR Case No. 4:20-cv-03056-DMR 3. Pursuant to the United States District Court, Northern District of California’s Procedural Guidance for Class Action Settlements, Angeion submits the following Post- Distribution Accounting Report following closure of the distribution period: Settlement Details Total Settlement Fund $58,000,000 Approximate number of Class Members 98,000,000 Notice Details Methods of notice to Class Members Email, postcard, custom social media, digital and social media, paid search campaign, sponsored class action website listings Number of Class Members to whom email notice was sent 60,271,546 Number of Class Members to whom email notice was sent and not returned as undeliverable 58,787,099 Number of Class Members to whom postcard notice was sent 650,669 Number of postcards re-mailed to forwarding address or to an address located through skip-tracing 44,749 Number of Class Members to whom postcard notice was sent and not returned as undeliverable 633,219 Number of clicks-throughs on all digital noticing ads in initial campaign + reminder campaign 334,516 Case 4:20-cv-03056-DMR Document 191-1 Filed 08/21/23 Page 2 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 DECLARATION OF SETTLEMENT ADMINISTRATOR 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 ACH, 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 distributed1 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 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 $11,000,000.00 1 Physical checks were distributed to Authorized Claimants who opted to receive a paper check in the first instance, as well as to Authorized Claimants who opted to receive a digital payment but for whom the digital payment was not successful. Case 4:20-cv-03056-DMR Document 191-1 Filed 08/21/23 Page 3 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 DECLARATION OF SETTLEMENT ADMINISTRATOR Case No. 4:20-cv-03056-DMR 4. As of August 21, 2023, accounting for all expenses, a total of $1,516,834.18 remains in the Settlement Fund. 5. A second distribution to Authorized Claimants is not economically feasible in my professional opinion. Angeion estimates the administrative cost to effectuate a second round of payments to the 1,198,327 Authorized Claimants would be approximately $572,813.00. After deducting anticipated administration costs, there would be approximately $944,021.18 remaining in the Settlement Fund that could be distributed to Authorized Claimants. The pro rata payment amount would be approximately $0.78 per Claimant, as reflected in the chart below. It has been Angeion’s general experience that lower check amounts often result in a higher percentage of uncashed checks, as Class Members are less motivated to cash/negotiate a check for that lower amount. Furthermore, the costs associated with distributing the payments would surpass the actual value of the payment itself. In light of this, Angeion has recommended to the Parties that a second distribution is not economically feasible and recommends the remaining funds be distributed pro rata to the Cy Pres Recipient(s). Total Amount Remaining in the Settlement Fund $ 1,516,834.18 Approximate Administrative Costs to Effectuate a Second Distribution $ (572,813.00) Approximate Total Remaining in the Settlement Fund for a Second Distribution $ 944,021.18 Second Distribution Pro Rata Settlement Benefit 1,198,327 Payments @ $0.78 $ 934,695.06 Rounding Variance (Undistributed) $ 9,326.12 I hereby declare under penalty of perjury that the foregoing is true and correct. Dated: August 21, 2023 _____________________________ DENISE EARLE Case 4:20-cv-03056-DMR Document 191-1 Filed 08/21/23 Page 4 of 4
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