| Notice ID: KATL0570752536 United States District Court for the Northern District of California NOTICE OF PROPOSED CLASS ACTION SETTLEMENT Our Records Indicate You May Be Entitled to a Payment from a Class Action Settlement A federal court authorized this notice. You are not being sued. This is not an advertisement. A Settlement has been proposed in class action litigation against Oracle America, Inc. (“Oracle”). This class action alleges that Oracle improperly captured, compiled, and sold individuals’ online and offline data to third parties without obtaining their consent. Oracle denies all the allegations made in the lawsuit and any wrongdoing and maintains that its practices were lawful and disclosed to individuals. Who is included in the Settlement? You are included if you are a Settlement Class Member, which is defined as “all natural persons residing in the United States whose personal information, or data derived from their personal information, was acquired, captured, or otherwise collected by Oracle Advertising technologies or made available for use or sale by or through ID Graph, Data Marketplace, or any other Oracle Advertising product or service from August 19, 2018 to the date of final judgment in the Action.” What does the Settlement provide? Under the Settlement, Oracle will pay $115 million to establish a Settlement Fund. To submit your claim, go to: www.KatzPrivacySettlement.com/submit-claim. Class Counsel will ask the Court to award up to 25% of the Settlement Fund (i.e. up to $28.75 million) for attorneys’ fees. In addition, Class Counsel will ask the Court to reimburse them out of the Settlement Fund for the expenses they reasonably incurred and will incur in litigating this case on behalf of Settlement Class Members in an amount not to exceed $225,000. Oracle has reserved the right to object or comment on Class Counsel’s request for attorneys’ fees and expenses in the District Court and has also agreed not to appeal any order of the District Court awarding attorneys’ fees and expenses. Class Counsel will also ask the Court to approve Service Awards of up to $10,000 each for the two Class Representatives named in the complaint as an award for their service to the Settlement Class as Plaintiffs and Class Representatives ($20,000 in total) out of the Settlement Fund. Class Counsel’s application for attorneys’ fees, expenses, and Service Awards will be made available on the Settlement Website at www.KatzPrivacySettlement.com before the deadline for you to comment on or object to the Settlement. After deducting any Court-approved attorneys’ fees and expenses and Service Awards for the Class Representatives, and the costs of the Settlement administration, the Settlement Fund will be distributed to Class Members on a pro rata basis. Oracle will also certify that, for as long as it continues to offer the products and services described in the complaint, it will: (i) not capture (a) user-generated information within referrer URLs (i.e., the URL of the previously-visited page) associated with a website user or (b) except for Oracle’s own websites, any text entered by a user in an online web form,; and (ii) implement an audit program to reasonably review customer compliance with contractual consumer privacy obligations. How do I get a payment? You must submit a valid Claim Form by October 17, 2024. Claim forms may be submitted online at www.KatzPrivacySettlement.com or printed from the website and mailed to the address on the Claim Form. Claim Forms are also available by calling 1-888-255-4036 or emailing Questions@KatzPrivacySettlement.com. You are not required to submit a claim, but if you are in the Settlement Class and do not submit a claim, you will lose your right to claim compensation in connection with the Settlement. Your other options. If you don’t want to be legally bound by the Settlement, you must exclude yourself from it by October 17, 2024. Unless you exclude yourself, you won’t be able to sue or continue to sue Oracle for any claim made in this lawsuit or released by the Settlement Agreement. If you stay in the Settlement (i.e., don’t exclude yourself), you may file an objection or other comment no later than October 17, 2024. More information about these options is available at www.KatzPrivacySettlement.com. Do I have a lawyer in the case? If you are a Settlement Class Member, you have a lawyer in this case. The Court appointed as “Class Counsel” the law firm of Lieff Cabraser Heimann & Bernstein, LLP to represent Settlement Class Members. If you want to be represented by your own lawyer, you may hire one at your own expense. The Court’s hearing. The Court will hold the Final Approval Hearing at 1:30 p.m. on November 14, 2024 in Courtroom 3 (17th Floor) of the San Francisco Courthouse, 450 Golden Gate Avenue, San Francisco, CA 94102. There is no requirement that you attend the hearing—you may submit a claim, object, comment or exclude yourself from the Settlement without attending the hearing. At the Final Approval Hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate, including Class Counsel’s application for attorneys’ fees, expenses, and for Service Awards. How Do I Get More Information? For more information, including the full notice, claim form and Settlement Agreement visit www.KatzPrivacySettlement.com, or contact the Settlement Administrator by email at Questions@KatzPrivacySettlement.com, by phone at 1-888-255-4036, or by mail at: Katz-Lacabe et al v. Oracle America, Inc. If you are member of the Settlement Class, you may go to the Settlement website (www.KatzPrivacySettlement.com) now and make a claim. PLEASE DO NOT CONTACT THE COURT OR THE COURT CLERK’S This notice is only a summary. |
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