GOOGLE PLUS PROFILE LITIGATION

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

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Frequently Asked Questions

  1. How do I know if I am part of the Settlement Class?

    The Settlement Class is defined as: “all persons within the United States who (a) had a consumer Google+ account for any period of time between January 1, 2015 and April 2, 2019, and (2) had their non-public Profile Information exposed as a result of the software bugs Google announced on October 8, 2018 and December 10, 2018. Excluded from the Settlement Class are (a) Google and its officers, directors, employees, subsidiaries, and Google Affiliates; (b) all judges and their staffs assigned to this case and any members of their immediate families; (c) the Parties’ counsel in this litigation; and (d) any Excluded Class Member.”

  2. What are the terms of the Settlement?

    Under the Settlement, Google has agreed to create a Settlement Fund of $7,500,000. This Settlement Fund will provide compensation to Settlement Class Members, pay for notice and administration costs, provide for any approved Service Awards to the Class Representatives who filed the case, and compensate the attorneys for any approved fee, cost, and expense awards. If the Settlement is finally approved, Settlement Class Members will be prevented from bringing any further claims against Google for any conduct relating to the software bugs affecting Google+ profile fields.

  3. How will the Settlement Fund be distributed?

    The lawyers for the Settlement Class (“Class Counsel”) will ask the Court to approve the following payments from the Settlement Fund:

    • The costs of providing notice and administration of the Settlement;
    • Service Awards to each of the Class Representatives, not to exceed $1,500 each, as compensation for their active participation in the case on behalf of the Settlement Class;
    • Class Counsel’s compensation for the time and effort incurred litigating the case, which will not exceed 25% of the Settlement Fund, and costs and expenses they incurred not to exceed $200,000.00;
    • Payments to Settlement Class Members who file timely and Valid Claim Forms according to the Plan of Allocation outlined below; and
    • Any residual funds remaining after payments to Settlement Class Members will be distributed to Approved Cy Pres Recipients as approved and directed by the Court.

  4. How can I get a Settlement Payment?

    If you are a Settlement Class Member and would like to receive a Settlement Payment, you must submit a Claim Form no later than October 8, 2020.

    You may complete the Claim Form online here, or you may mail your Claim Form to the following address:

    Google Plus Data Litigation
    1650 Arch Street, Suite 2210
    Philadelphia, PA, 19103

    If you do not file a Claim Form, you will not receive a payment. Note that for each Valid Claim, the payment method will be the Electronic Payment method specified on the Claimant’s Claim Form.

  5. How much will I receive from the Settlement?

    The Plan of Allocation provides for Settlement Payments to Claimants as follows: The Net Settlement Fund shall be allocated to Claimants on a pro rata basis up to an initial maximum distribution of US$5.00 per Claimant. If there are insufficient funds to pay claimants $5.00 based on the number of claimants, the payment to each claimant will be reduced pro ratably. If sufficient funds remain after calculation of the aggregate initial maximum distribution of US$5.00 per Claimant, the allocation shall be recalculated on a pro rata basis up to a maximum distribution of up to US$12.00 per Claimant. For clarity, the maximum Settlement Payment to be made to any single Claimant shall not exceed US$12.00.

  6. How do I get out of the Settlement?

    If you do not want to be part of the Settlement, you must submit an Opt-Out Form no later than October 8, 2020. You may obtain the Opt-Out Form here. Your completed Opt-Out Form may be submitted via e-mail to Info@GooglePlusDataLitigation.com, or via postal mail to the following address:

    Google Plus Data Litigation
    Attn: Opt-Out Requests
    P.O. Box 58220
    Philadelphia, PA, 19102

    If you opt-out of the Settlement, you will not be bound by the Settlement Agreement, you will not receive a Settlement Payment, and you will not be allowed to object to the Settlement.

  7. Do I have a lawyer in this case?

    The Court has appointed Class Counsel to represent you and other Settlement Class Members. In this case, Class Counsel are John A. Yanchunis and Ryan J. McGee of the law firm Morgan & Morgan Complex Litigation Group; Clayeo C. Arnold and Joshua H. Watson of the law firm Clayeo C. Arnold Professional Law Corporation; and Franklin D. Azar and Margeaux R. Azar of the law firm Franklin D. Azar & Associates, P.C. You will not be charged for these lawyers. If you want to be represented by another lawyer, you may hire one at your own expense.

  8. How will the lawyers be paid?

    The attorneys representing the Settlement Class have not yet received any payment for their legal services or any reimbursement of the costs or out-of-pocket expenses they have incurred. Class Counsel plans to ask the Court to award attorneys’ fees from the Settlement Fund not to exceed $1,875,000 which is 25% of the Settlement Fund, and reimbursement of costs and expenses in the approximate amount of $200,000.

  9. How do I object to the Settlement?

    If you are a Settlement Class Member and do not opt out of the Settlement Class, you may object to any aspect of the Settlement. This includes commenting on the applications for Class Representative Service Awards or the award of attorneys’ fees, costs, and expenses. Your completed Objection must be submitted no later than October 8, 2020 online here or via postal mail to the following address:

    Google Plus Data Litigation
    Attn: Settlement Objections
    P.O. Box 58220
    Philadelphia, PA, 19102

    Any Objection must be in writing and must:

    1. Clearly identify the case name and number, In re Google Plus Profile Litigation, Case No. 5:18-cv-06164-EJD;
    2. Include the full name, address, telephone number, and email address of the person objecting;
    3. Include the full name, address, telephone number, and email address of the Objector's counsel (if the Objector is represented by counsel);
    4. State whether the objection applies only to the objector, to a specific subset of the Class, or to the entire Class, and also state with specificity the grounds for the Objection; and
    5. Be verified by an accompanying declaration submitted under penalty of perjury or a sworn affidavit.

    Settlement Class Members who fail to submit timely written Objections in the manner specified above will waive their right to object to any aspect of the Settlement.

  10. Do I need to attend the Final Fairness Hearing?

    No. Class Counsel will answer any questions the Court may have. However, any Settlement Class Member who timely submits an Objection has the option to appear and request to be heard at the Final Fairness Hearing, either in person or through their counsel. If you choose to make an Objection through an attorney or have an attorney appear at the Final Fairness Hearing on your behalf, you will be solely responsible for paying that attorney’s fees.

  11. How can I get more information?

    This Notice summarizes the Settlement. It does not describe all of its details. For the precise terms and conditions of the Settlement, please see the Settlement Agreement and related documents. Additional information about the Settlement, including a copy of the Settlement Agreement, may be obtained by:

    • Downloading here;
    • Contacting the Settlement Administrator toll-free by phone at 1-833-509-1101 or by email at Info@GooglePlusDataLitigation.com;
    • Accessing the Court docket in this case through the Court’s Public Access to Court Electronic Records (PACER) system at ecf.cand.uscourts.gov; or
    • Visiting the office of the Clerk of the Court for the United States District Court for the Northern District of California, 280 South 1st Street, 2nd Floor, San Jose, CA 95113, between 9:00 am and 4:00 pm, Monday through Friday, excluding Court holidays.

Please do not telephone the Court or the Court Clerk’s Office to inquire about the Settlement.