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RODRIGUEZ V. GOOGLE LLC

Case No. 20-cv-4688-RS (N.D. Cal.)

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WELCOME TO THE WEBSITE FOR THE RODRIGUEZ V. GOOGLE LLC CLASS ACTION LAWSUIT

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.

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 to any wrongdoing. The
Court has not decided who is right.


The Court decided the legal claims brought by Plaintiffs can proceed as a
nationwide class action. You may be 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.


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 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.

Individuals who signed up for an account type other than an Enterprise account
or supervised Google Account for users under age 13 could be included for all
three legal claims. These individuals could be Class Members for both the
invasion of privacy and intrusion upon seclusion classes and the CDAFA classes.


It is possible for you to be a Class Member of one or more of these certified
classes.


Your Legal Rights and Options in This Lawsuit

Do Nothing

Stay in this lawsuit and await the outcome. Lose certain rights.

This option means you will remain a Class Member and keep the possibility of
getting money or benefits that may be available in the future from a trial or
settlement. If you choose this option, you will be bound by any judgments in
this lawsuit and you will lose any rights to sue Google separately regarding the
legal claims in this lawsuit.

Ask to Be Excluded

Get no money or benefits from the lawsuit. Keep certain rights.

If you ask to be excluded from this lawsuit and money or benefits are later
awarded, you will not receive any. However, you will keep your right to sue
Google at your own expense regarding the legal claims in this lawsuit. The
deadline to ask to be excluded is Thursday, February 20, 2025.


There is no money available now, and no guarantee there will be in the future.
However, your legal rights may be affected, and you have a choice to make now.

Your rights and options as a Class Member—and how to exercise them—are explained
in more detail on the Frequently Asked Questions page of this website.

Important Dates
 * July 25, 2024, at 1:30 p.m. PT
   Motion for Summary Judgment Hearing
 * September 23, 2024 - ongoing
   Email notice sent to Class Members
 * February 20, 2025
   Deadline to exclude yourself from the lawsuit
 * July 23, 2025, at 10:00 a.m. PT
   Final Pretrial Conference
 * August 18, 2025, at 9:00 a.m. PT
   Trial

Please Note: All court dates are subject to change.

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