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This statement makes sense. Lots of lenders report wild inaccuracies in data dump. This is not a

Summary

Exhibit 4, filed March 11, 2025 as Document 68-4 in Case 4:21-cv-00110-SDJ, is a nine-page email chain among Kabbage, Inc. employees dated July 16, 2020, with the subject line Reuters media request regarding SBA PPP loan data issues. The forwarded request from a Reuters reporter says SBA's reported PPP data appeared to contain systematic errors, including Kabbage loans listed in a million-dollar range to very small businesses, and asks whether Kabbage knew of data-entry issues. Kabbage's head of communications proposes a statement that some applications are inaccurately listed as approved and that approved does not necessarily mean funded, and notes that possible fraud cases were sent for further review. Kabbage's head of policy replies that the statement makes sense. The email also includes the reporter's list of flagged borrower names.

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Case 4:21-cv-00110-SDJ   Document 68-4   Filed 03/11/25   Page 1 of 9 PageID #: 600




                Exhibit 4
Case 4:21-cv-00110-SDJ        Document 68-4           Filed 03/11/25   Page 2 of 9 PageID #: 601




 From:                 Sam Taussig[staussig@kabbage.com]
 Sent:                 Thur 7/16/2020 8:00:49 PM (UTC)
 To:                   Paul Bernardini[pbernardini@kabbage.com]
 Cc:                   Robert Frohwein[rfrohwein@kabbage.com]; Kathryn
                       Petralia[kpetralia@kabbage.com]; Laura Goldberg[lgoldberg@kabbage.com]
 Subject:              Re: Reuters media request regarding SBA PPP loan data issues

 This statement makes sense. Lots of lenders report wild inaccuracies in data dump. This is not a
 Kabbage story.




  Sam Taussig               Kabbage, Inc.
  Head of Policy            730 Peachtree Street NE
  M: 301-412-9193           Suite 1100
  www.kabbage.com           Atlanta, GA 30308




 On Thu, Jul 16, 2020 at 3:55 PM Paul Bernardini <pbernardini@kabbage.com> wrote:

   Hey -- See below. I combed through these and there are a variety of statuses.
   Applications were either closed, expired, returned, never signed or have
   inconsistencies with SBA's data we never received SBA approval

   As for a statement, I'm OK saying that if you all agree. Reconfirming SBA
   inconsistencies helps shift attention away from fraud and instead to inaccurate data.


                                            Exhibit 4 - Page 1
Case 4:21-cv-00110-SDJ        Document 68-4         Filed 03/11/25   Page 3 of 9 PageID #: 602




   Also, I think it's helpful reporters recognize that an approved loan in SBA's dataset
   does not necessarily mean funded:

   Statement:
   "Yes, we have seen inconsistencies with the SBA's data as some
   applications are inaccurately listed as approved. Please also know that an
   'approved' status does not necessarily mean funded as some loans may
   have expired, were returned, withdrawn or are not yet signed."

   NOTE: For the ones that may be fraud, I've sent it to that team for further review.

   ---------- Forwarded message ---------
   From: Price, Michelle (Reuters) <michelle.price@thomsonreuters.com>
   Date: Thu, Jul 16, 2020 at 10:36 AM
   Subject: Reuters media request regarding SBA PPP loan data issues
   To: pbernardini@kabbage.com <pbernardini@kabbage.com>



   Dear Paul,



   I’m a reporter for Reuters in DC covering the SBA PPP loan program.



   I have noticed what look to be like systematic errors in the data SBA reported on the PPP
   earlier this month. Many of the loans for Kabbage reported to be of between $1-$2 million
   appear to be to one or two people businesses who would not qualify for such a large amount
   (highlighted below). Also worth noting David Horvath nearer the bottom who appears to
   have netted three large loans.



   Given the number of companies below that look to be erroneous, I was wondering if you
   might be aware of any systematic issues with the SBA data/data entry process that would
   explain this.



   As you may be aware, Radius Bank has said publicly that a systematic error caused many of
   their small loans in the thousands to be reported as in the millions – some issue with the
   decimalization being in the wrong place (it’s still not clear if Radius or SBA was to blame,
   but Radius has told customers that the issue was with the SBA).




                                          Exhibit 4 - Page 2
Case 4:21-cv-00110-SDJ       Document 68-4         Filed 03/11/25   Page 4 of 9 PageID #: 603




   I’m trying to ascertain how widespread this systematic issue may have been and would be
   grateful for any feedback Kabbage can offer.



   Thanks in advance

   Michelle Price

   Reuters

   202 604 1711




    c $1-2     GODS ANOINTED YOUTH MINISTRY
    million


    c $1-2     ID EQUITIES, LLC
    million


    c $1-2     SPHYRAENA VENTURES LLC, https://bisprofiles.com/fl/sphyraena-ventures-l16000091504
    million


    c $1-2     ALL CARS US, https://www.zillow.com/homedetails/511-Lewandowski-St-Lyndhurst-NJ-07071
    million



    c $1-2     GEORGIA POWER COMPANY
    million


    c $1-2     LOLA'S LEVEL
    million


    c $1-2     DAILY BURNOUTS, LLC https://www.zillow.com/homedetails/17507-E-Orchid-Ln-Gilbert-AZ
    million




                                         Exhibit 4 - Page 3
Case 4:21-cv-00110-SDJ     Document 68-4        Filed 03/11/25   Page 5 of 9 PageID #: 604




    c $1-2    1224 ROSEMARY, LLC
    million


    c $1-2    MY FD FINANCIAL GROUP LLC
    million



    c $1-2    ENERGY EFFICIENT CONSTRUCTION SOLUTIONS
    million



    c $1-2    1 PONCE DE LEON LLC
    million


    c $1-2    ENERGY SOLUTION SERVICES, LLC https://clustrmaps.com/c/1kcs88-53kj
    million


    c $1-2    PROPEL OPPORTUNITY FUND INC.
    million


    c $1-2    FLAIR GROUP INC
    million


    c $1-2    KEEPING THE BLUES ALIVE FOUNDATION INC https://keepingthebluesalive.org/contact/
    million


    c $1-2    FEDERAL CREDIT UNION
    million



    c $1-2    ELEXON SERVICES LLC https://opencorporates.com/companies/us_nj/0400179851
    million




    c $1-2
    million   REPAIRO LLC https://start.cortera.com/company/research/m0n8orp1m/repairo-llc/


                                      Exhibit 4 - Page 4
Case 4:21-cv-00110-SDJ     Document 68-4         Filed 03/11/25   Page 6 of 9 PageID #: 605




    c $1-2    DOG TRAINING WITH MARIO HOLLAND LLC https://www.linkedin.com/in/mario-holland-
    million



    c $1-2    THE EW LAW FIRM, LLC https://www.bizapedia.com/ga/the-ew-law-firm-llc.html
    million



    c $1-2    MB BOAT & RIDE CORP https://florida.intercreditreport.com/company/mb-boat-ride-corp-p190
    million


    c $1-2    ELITE FITNESS CONCIERGE LLC https://www.georgia-register.com/14011667-elite-fitness-c
    million



    c $1-2    R & M THERA INC
    million


    c $1-2    TRADEX CONSULTING GROUP LLC https://www.bizapedia.com/az/tradex-consulting-group-
    million



    c $1-2    NEW GENERATION ABUNDANT MISSION CHURCH OF GOD
    million


    c $1-2    POSSIBLE PAT LLC
    million



    c $1-2    PAPER TREASON LLC
    million   http://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=OfficerRegis
              ACELLICLEMENTE%20L060001016540&aggregateId=flal-l06000101654-8050a517-2638-4c9
              95818f5492c4&searchTerm=Bornacelli%20%20%20%20%20%20%20%20%20%20Paola&listN


    c $1-2    BIG SHOT LLC


                                       Exhibit 4 - Page 5
Case 4:21-cv-00110-SDJ    Document 68-4       Filed 03/11/25   Page 7 of 9 PageID #: 606




    million



    c $1-2    FINESSE TRUCKING & LOGISTICS LLC https://www.quicktransportsolutions.com/truckingco
    million



    c $1-2    THE GASPARDS GROUP HOME INC https://opencorporates.com/companies/us_fl/P19000055
    million


    c $1-2    JLITE MORTORS
    million


    c $1-2    EL CENTRO GROUP LLC
    million



    c $1-2    ORLANDO SALON LLC https://www.yelp.com/biz/orlando-salon-chicago-3
    million



    c $1-2    HEEL CRUSH BOUTIQUE, INC https://opencorporates.com/companies/us_fl/P19000047438
    million


    c $1-2    SMART TECH FLORIDA LLC https://opencorporates.com/companies/us_fl/L16000127165
    million



    c $1-2    MUIRHEAD-GRAHAM TECHNOLOGY LLC
    million



    c $1-2    114 MACON LLC https://www.propertyshark.com/mason/Property/175187/114-Macon-St-Brook
    million




                                    Exhibit 4 - Page 6
Case 4:21-cv-00110-SDJ      Document 68-4       Filed 03/11/25   Page 8 of 9 PageID #: 607




    c $1-2      RANGEVIEW AG LABOR LLC https://www.manta.com/c/mkhw838/rangeview-agriculture-lab
    million


    c $1-2      GLOBAL PLATFORM SERVICES, LLC https://www.globalplatformservices.com/About
    million



    c $1-2      CUSTOM CONTROL SOLUTIONS ENGINEERING INC
    million


    c $1-2      DAVID HORVATH LAW PA
    million


    c $1-2      DAVID HORVATH, PA
    million


    c $1-2      DAVID HORVATH PA
    million




 Michelle Price
 Deputy finance editor

 Reuters, Washington D.C.

 Desk: +1 202 789 8542

 Cell/WhatsApp: + 1 202 604 1711

 http://www.reuters.com/



 Read my latest stories

 Follow me on Twitter




                                      Exhibit 4 - Page 7
Case 4:21-cv-00110-SDJ                        Document 68-4                  Filed 03/11/25               Page 9 of 9 PageID #: 608




 This e-mail is for the sole use of the intended recipient and contains information that may be
 privileged and/or confidential. If you are not an intended recipient, please notify the sender by
 return e-mail and delete this e-mail and any attachments. Certain required legal entity disclosures
 can be accessed on our website: https://www.thomsonreuters.com/en/resources/disclosures.html


 --


                                                    Kabbage, Inc.
      Paul Bernardini                               201 California
      Head of Communications                        Suite 325
      www.kabbage.com                               San Francisco, CA 94111




      Notice of Confidentiality: The information transmitted is intended only for the person or entity to which it is addressed and may contain
      confidential and/or privileged material. Any review, re-transmission, dissemination or other use of, or taking of any action in reliance
      upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact
      the sender immediately by return electronic transmission and then immediately delete this transmission, including all attachments,
      without copying, distributing or disclosing same.

      Kabbage Platform/Partnerships: Your privacy is important to us. To learn more about how we collect, use, and protect your personal
      data, please view our Privacy Notice at https://www.kabbageplatform.com/privacy/




                                                                 Exhibit 4 - Page 8


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