GOOGLE PLUS PROFILE LITIGATION

CASE NO. 5:18-CV-06164-EJD (VKD)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Important Dates

October 8, 2020 — Exclusion (Opt Out) Deadline

October 8, 2020 — Objection Deadline

October 8, 2020 — Claim Deadline

November 19, 2020 at 9 a.m. — Final Fairness Hearing

On June 10, 2020, the Honorable Edward J. Davila of the U.S. District Court for the Northern District of California, granted preliminary approval of this class action Settlement and directed the litigants to provide this notice about the Settlement. You have received this notice because Google’s records indicate that you may be a Settlement Class Member, and you may be eligible to receive a payment from the Settlement. The Final Approval Hearing on the adequacy, reasonableness, and fairness of the Settlement will be held at 9:00 am on November 19, 2020 in San Jose Courthouse, Courtroom 4, 5th Floor located at 280 South 1st Street, San Jose, CA 95113. You are not required to attend the Final Approval Hearing, but you are welcome to do so at your own expense.

Summary of Litigation

Google operated the Google+ social media platform for consumers from June 2011 to April 2019. In 2018, Google announced that the Google+ platform had experienced software bugs between 2015 and 2018, which allowed app developers to access certain Google+ profile field information in an unintended manner. Plaintiffs Matthew Matic, Zak Harris, Charles Olson, and Eileen M. Pinkowski thereafter filed this lawsuit asserting various legal claims on behalf of a putative class of Google+ users who were allegedly harmed by the software bugs (“Class”). Google denies Plaintiffs’ allegations, denies any wrongdoing and any liability whatsoever, and believes that no Class Members, including the Plaintiffs, have sustained any damages or injuries due to the software bugs.

Summary of Settlement Terms

Settlement Fund: Under the Settlement, Google will pay $7.5 million which will be used to fund: (1) Class Member Settlement payments; (2) attorneys’ fees not to exceed 25% of the Settlement Fund and costs and expenses not to exceed $200,000.00; (3) four service awards to the Class Representatives in an amount not to exceed $1,500 each for their services on behalf of the Settlement Class and for a general release of all claims they may have against Google; (4) administration fees and costs; and, if necessary, (5) cy pres distribution of any residual funds. No portion of the Settlement Fund can be returned to Google.

Amount of Payments: Class Members who submit a Valid Claim may receive a pro rata share of the Net Settlement Fund up to a cash payment of $12.00 depending on the number of claimants. Each Class Member can submit only one claim. Any funds remaining in the Net Settlement Fund after distribution(s) to Class Members will be distributed to Cy Pres Recipients that have been selected by a neutral third party and approved by the Court.

Method of Payment: The payments above for Class Members who submit a Valid Claim will be made by Electronic Payment (Paypal or Digital Check).

Your Options Under the Settlement

Submit a Claim Form to Be Eligible for a Cash Payment

If you submit a Valid Claim by October 8, 2020, you may receive a payment. You will also give up your rights to sue Google and/or any other released entities regarding the legal claims in this case.

Opt Out of the Settlement

This is the only option that allows you to sue Google and/or other released parties on your own regarding the legal claims in this case. You will not receive a payment from the Settlement. The deadline for excluding yourself is October 8, 2020.

File an Objection with the Court

Write to the Settlement Administrator about why you do not like the Settlement. The deadline for objecting is October 8, 2020. These Objections will be shared with the Court. If you object to the Settlement, you will be bound by the Settlement’s terms and will not be allowed to exclude yourself from the Settlement; you will lose the right to sue Google and/or any other released entities regarding the legal claims in this case.

Do Nothing

If you do nothing, you will not receive any payment. You will be bound by the Settlement’s terms and will lose the right to sue Google and/or any other released entities regarding the legal claims in this case.