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NOLEN V. PEOPLECONNECT, INC


CASE NO. 3:20-CV-09203-EMC


UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

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NOTICE OF CLASS CERTIFICATION





The deadline for requesting exclusion is August 2.

The United States District Court for the Northern District of California has
decided that this lawsuit should proceed as a class action and has certified the
following Class:

All persons residing in the State of California: (1) who are not, and have never
been, registered users of Classmates.com; (2) who have never donated a yearbook
to Classmates.com; and (3) for whom a search of their name, using the search bar
to search a California yearbook made available for viewing on the Classmates.com
website, yields at least one record corresponding to the class member from a
California yearbook that Classmates.com first made publicly available on or
after December 18, 2018.

Class Members must decide whether they want to exclude themselves from the
lawsuit.

A class action lawsuit is pending in the United States District Court for
Northern District of California (“the Court”), filed by Alicia Nolen
(“Plaintiff”) against PeopleConnect, Inc. (“Defendant”). Defendant owns and
operates a website on which users may search for and view photographs and names
from school yearbooks. Plaintiff alleges that Defendant uses the names,
personas, and photographs of individuals in school yearbooks to advertise
website subscriptions without consent in violation of California law. Defendant
denies any wrongdoing or that its practices violate California law.

At this stage, the court has not ruled on the merits of either Plaintiff’s
claims or Defendant’s defenses and no money or benefits are currently available.

IMPORTANT:

If you would like to remain a member of the Class, do not register for an
account on the Defendant’s website in response to this notice. If you have
previously registered or now register for an account on Classmates.com, you will
no longer be part of the Class.

YOUR RIGHTS AND OPTIONS IF YOU ARE A CLASS MEMBER:DO NOTHING

Stay in this lawsuit and share in possible benefits. Give up certain rights. By
doing nothing, you are choosing to stay in the Class. You may be permitted to
share in any recovery that may result from this lawsuit, but you will give up
your right to sue Defendant in a separate lawsuit for the claims made in this
lawsuit. In addition, you will be bound by past and any future court rulings on,
or settlement of, the claims made against Defendant.

ASK TO BE EXCLUDED

Get out of this lawsuit. Get no benefit from this suit. If you opt out of the
Class (meaning you say in writing that you do not want to be included in this
lawsuit), you will not be entitled to any recovery that may result from this
lawsuit, but you will not be bound by any past or future court rulings in this
lawsuit. You will be free to pursue your own claims against Defendant on your
own or as part of a different lawsuit.


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