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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

If you have previously had either the Google “Web & App Activity” control or the “Supplemental Web & App Activity” sub-setting turned off or “paused,” you could be included in an ongoing class action lawsuit.
For more information about the lawsuit, read below or visit www.GoogleWebAppActivityLawsuit.com.

Para una notificacion en Español, visitar www.GoogleWebAppActivityLawsuit.com.

A federal Court authorized this Notice. This is not a solicitation from a lawyer.

What is the lawsuit about? Four Google account holders (“Plaintiffs”) filed a class action lawsuit alleging that Google LLC (“Google”) unlawfully accessed their devices and data, including app activity data on their mobile devices, even though the Google activity controls called Web & App Activity (“WAA”) and/or a sub-setting concerning “Chrome history and activity from sites, apps, and devices that use Google services,” sometimes called supplemental Web & App Activity (“sWAA”) were turned off or “paused.” Plaintiffs allege Google unlawfully accessed their mobile devices to collect, save, and use the data concerning their activity on non-Google apps that have incorporated certain Google software code into the apps. Plaintiffs have three legal claims: (1) invasion of privacy; (2) intrusion upon seclusion (similar to invasion of privacy); and (3) violation of the Comprehensive Computer Data Access and Fraud Act (“CDAFA”). For all three legal claims, Plaintiffs seek money damages and changes to Google’s practices.

Google denies Plaintiffs’ legal claims and does not admit any wrongdoing. The Court has not decided who is right.

You are receiving this Notice because Google’s records indicate that you may be a Class Member.

The Court decided the legal claims brought by Plaintiffs can proceed as a nationwide class action. You may be included as a Class Member if you have or had WAA and/or sWAA turned off or “paused” at any time between July 1, 2016, and September 23, 2024. This Notice only advises you of the existence of this lawsuit, your rights and options, and the deadlines to exercise them, if you are a Class Member. More specifically, the Court certified the following classes.

Comprehensive Computer Data Access and Fraud Act (“CDAFA”)

For the alleged violation of the CDAFA, the Court certified the following classes:

Class 1: All individuals who, during the period beginning July 1, 2016, and continuing through September 23, 2024, (a) had their “Web & App Activity” and/or “supplemental Web & App Activity” setting turned off and (b) whose activity on a non-Google-branded mobile app was still transmitted to Google, from (c) a mobile device running the Android operating system, because of the Firebase Software Development Kit (“SDK”) and/or Google Mobile Ads SDK.

Class 2: All individuals who, during the period beginning July 1, 2016, and continuing through September 23, 2024, (a) had their “Web & App Activity” and/or “supplemental Web & App Activity” setting turned off and (b) whose activity on a non-Google-branded mobile app was still transmitted to Google, from (c) a mobile device running a non-Android operating system, because of the Firebase SDK and/or Google Mobile Ads SDK.

Invasion of Privacy and Intrusion upon Seclusion

For the alleged invasion of privacy and intrusion upon seclusion legal claims, the Court certified the same Class 1 and Class 2 but excluded individuals who only have an “Enterprise” account or “supervised Google Account for users under age 13” (also known as a “Unicorn” account). An “Enterprise” account is an account managed by an administrator that is designed for use by end users within an organization, such as businesses, non-profits, and schools. A “supervised Google Account for users under age 13” is an account created for a minor when they are under the age of 13, which is created and supervised by a parent using Google Family Link.

Class 1: All “non-Enterprise” and “non-Unicorn” individuals who, during the period beginning July 1, 2016, and continuing through September 23, 2024, (a) had their “Web & App Activity” and/or “supplemental Web & App Activity” setting turned off and (b) whose activity on a non-Google-branded mobile app was still transmitted to Google, from (c) a mobile device running the Android operating system, because of the Firebase Software Development Kit (“SDK”) and/or Google Mobile Ads SDK.

Class 2: All “non-Enterprise” and “non-Unicorn” individuals who, during the period beginning July 1, 2016 and continuing through September 23, 2024, (a) had their “Web & App Activity” and/or “supplemental Web & App Activity” setting turned off and (b) whose activity on a non-Google-branded mobile app was still transmitted to Google, from (c) a mobile device running a non-Android operating system, because of the Firebase SDK and/or Google Mobile Ads SDK.

If you are a child for whom a supervised Google Account for users under age 13 was created, please discuss this Notice with your parent or guardian to help you decide whether you may be a Class Member. If you are a parent or guardian supervising a Google Account for users under age 13, and if Google’s records indicate your child may be a Class Member, you will receive a separate Notice. Please review that Notice with your child to help them decide whether they may be a Class Member.

Is there any money or benefits available now? No money or benefits are available now. The Court has not decided whether Google did anything wrong, and Plaintiffs and Google have not settled the lawsuit. There is no guarantee money or benefits will be obtained in the future. You will be notified if money or benefits become available.

What happens if I do nothing at all? If you do nothing, you will remain a Class Member. If Plaintiffs obtain money or benefits from this lawsuit—as a result of a trial or a settlement—you may receive a payment or benefits in the future. If you do nothing now, regardless of whether Plaintiffs win or lose, you will be legally bound by all Court orders and judgments regarding the legal claims in this lawsuit. You will lose the right to bring or maintain a separate lawsuit against Google for the legal claims alleged in this lawsuit.

How do I exclude myself? To exclude yourself, you must send a written request by mail stating that you want to be excluded from Rodriguez v. Google LLC. You must include your name, address, telephone number, email address, and your signature. You must mail your exclusion request postmarked by February 20, 2025, to: Rodriguez v. Google Exclusions, P.O. Box 2749, Portland, OR 97208-2749.

You cannot exclude yourself on the phone or by email. To exclude yourself, you must do so individually and separately; no consolidated, group, or mass requests for exclusion will be accepted. If you timely ask to be excluded, you will not be legally bound by anything that happens in this lawsuit. You may be able to sue (or continue to sue) Google in the future regarding the legal claims in this lawsuit. If you do not exclude yourself, by February 20, 2025, you will remain a Class Member and be bound by the orders of the Court in this lawsuit.

Do I have a lawyer in this case? Yes. The Court has appointed the following lawyers as Class Counsel to represent Class Members. You may also hire your own lawyer at your own expense who may appear on your behalf.

Mark C. Mao
Beko Reblitz-Richardson
BOIES SCHILLER FLEXNER LLP
44 Montgomery St., 41st Floor
San Francisco, CA 94104

John A. Yanchunis
Ryan J. McGee
MORGAN & MORGAN
201 N. Franklin Street, 7th Floor
Tampa, FL 33602

Bill Carmody
SUSMAN GODFREY LLP
One Manhattan West
50th Floor
New York, NY 10001

James Lee
BOIES SCHILLER FLEXNER LLP
100 SE 2nd St., 28th Floor
Miami, FL 33131

Amanda Bonn
SUSMAN GODFREY LLP
1900 Ave. of the Stars, Suite 1400
Los Angeles, California 90067

How do I get more information? This Notice is a summary. Learn more about the lawsuit at www.GoogleWebAppActivityLawsuit.com or call 1-855-822-8821.

You may also obtain information regarding the lawsuit on the Court docket in this lawsuit, for a fee, through the Court’s Public Access to Court Electronic Records (PACER) system at https://ecf.cand.uscourts.gov, or by visiting the office of the Clerk of the Court for the United States District Court for the Northern District of California, Phillip Burton Federal Building & United States Courthouse, 450 Golden Gate Avenue, San Francisco, CA 94102, between 9:00 a.m. and 4:00 p.m., Monday through Friday, excluding Court holidays.

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE ABOUT THIS LAWSUIT. ALL QUESTIONS SHOULD BE DIRECTED TO THE NOTICE ADMINISTRATOR OR CLASS COUNSEL.

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