AdWords Clicks Class Action Settlement Administrator <donotreply@adwordsclicksclassaction.com> wrote:2025-5-6 05:27
Email subject: Rene Cabrera, et al. v. Google LLC – Notice of Class Action Settlement
*|MC_PREVIEW_TEXT|*
NOTICE ID: GCR14256953-1
CONFIRMATION CODE: KP9EJAGK74V4
Dear Potential Search Bundled Clicks Class member:
THIS NOTICE HAS BEEN ISSUED TO ADVISE YOU OF A PROPOSED CLASS ACTION
SETTLEMENT AND YOUR RIGHTS IN CONNECTION THEREWITH.
PLEASE READ THIS ENTIRE NOTICE. YOU ARE REQUIRED TO SUBMIT A
PAYMENT FORM IN ORDER TO RECEIVE A SETTLEMENT PAYMENT.
You are receiving this Court-approved notice because Google’s
records indicate that you or someone associated with your contact
information may be a member of the Search Bundled Clicks Class in the
pending class action lawsuit _Rene Cabrera, et al. v. Google LLC_,
Case No. 5:11-cv-1263-EJD (N.D. Cal.) (“Action”). You may have
been previously notified by email that the Action had been certified
by the Court to proceed as a class action (“Class Notice”). You
are now being notified that the Action has reached a proposed
settlement (“Settlement”). This notice contains summary
information regarding the Settlement, including important deadlines to
act. _YOUR LEGAL RIGHTS MAY BE AFFECTED BY THIS CASE, SO PLEASE READ
THIS NOTICE CAREFULLY. A FEDERAL COURT AUTHORIZED THIS NOTICE – IT
IS NOT A SOLICITATION FROM A LAWYER._
SEARCH BUNDLED CLICKS CLASS: As previously notified, the Court
certified two classes in the Action. One of the classes - the
“Search Bundled Clicks Class” is comprised of all persons and
entities located within the United States who, between June 1, 2009
and December 13, 2012, advertised through Google’s AdWords Program
and paid for clicks on ads on Google’s Display Network where the
advertiser’s settings allowed its ads to show on both the Search and
Display Networks and did not set a Display Network bid different from
the Search Network bid (“Search Bundled Clicks Class” or
“Class”). Excluded from the Search Bundled Clicks Class are Google
LLC (“Google” and “Defendant”) and its affiliates, officers,
and directors, as well as members of the judiciary and their staff.
Also excluded from the Search Bundled Clicks Class are (i) the
individuals and entities who requested exclusion from the Search
Bundled Clicks Class pursuant to Class Notice and do not opt back into
the Class in connection with the Settlement; and (ii) the individuals
and entities who submit timely and valid requests for exclusion from
the Search Bundled Clicks Class in connection with the Settlement.
THE PROPOSED SETTLEMENT: The parties to the Action have reached a
proposed Settlement of the claims against Google. If approved, the
Settlement will resolve the claims of _BOTH_ certified classes
(including the Search Bundled Clicks Class) and will dismiss the
Action in its entirety. More information regarding the claims being
resolved can be found in the detailed Notice of (I) Proposed
Settlement; (II) Final Fairness Hearing; and (III) Motion for
Attorneys’ Fees and Expenses (“Settlement Notice”), available at
www.AdWordsClicksClassAction.com. Google denies all claims and
wrongdoing asserted in the Action, as well as any liability arising
out of the conduct alleged in the Action.
Pursuant to the Settlement, Google has agreed to pay $100,000,000.00,
which, after deducting any Court-awarded attorneys’ fees and
expenses, notice and administration costs, and taxes, will be
allocated among those Search Bundled Clicks Class Members and Location
Targeting Class Members that (1) are eligible to receive a payment
under the Settlement based on an assessment by Plaintiffs’ experts
of data produced by Google in the Action, (2) submit a completed
Payment Form, and (3) have not requested exclusion from the Classes
(“Participating Class Members”), as long as they are entitled to
receive at least $1.00. A Participating Class Member’s actual share
of the Settlement will be determined pursuant to the proposed
Allocation Methodology set forth in the Settlement Notice, or other
allocation method ordered by the Court. If you are a Participating
Class Member, your _pro rata_ share of the Settlement will depend on
your alleged damages during the relevant time period based on an
assessment by Plaintiffs’ experts of data produced by Google in the
Action, in comparison to the total alleged damages of all
Participating Class Members. FOR ADDITIONAL INFORMATION REGARDING THE
SETTLEMENT AND THE PROPOSED ALLOCATION METHODOLOGY, PLEASE REVIEW THE
SETTLEMENT NOTICE AND THE PARTIES’ CLASS ACTION SETTLEMENT AND
RELEASE AGREEMENT DATED MARCH 27, 2025, AVAILABLE AT
WWW.ADWORDSCLICKSCLASSACTION.COM.
FINAL FAIRNESS HEARING: A hearing will be held on AUGUST 21, 2025 AT
9:00 A.M., before the Honorable Edward J. Davila, United States
District Court Judge for the Northern District of California, either
in person at the San Jose Courthouse, 280 South 1st Street, San Jose,
CA 95113, in Courtroom 4—5th Floor, or by telephone or
videoconference (in the discretion of the Court), to determine, among
other things: (i) whether the Settlement on the terms and conditions
provided for in the Settlement Agreement is fair, reasonable, and
adequate to the Classes, and should be finally approved by the Court;
(ii) whether the Action should be dismissed with prejudice against
Google and the releases specified and described in the Settlement
Agreement (and in the Settlement Notice) should be granted;
(iii) whether Class Counsel’s motion for attorneys’ fees in an
amount not to exceed 33% of the Settlement Fund and reimbursement/
payment of expenses in an amount not to exceed $4.2 million should be
approved; and (iv) whether a Service Award to Plaintiffs in an amount
not to exceed $20,000 should be approved. Any updates regarding the
hearing, including any changes to the date or time of the hearing or
updates regarding in-person or remote appearances at the hearing, will
be posted to www.AdWordsClicksClassAction.com.
WHAT ARE MY OPTIONS?:
* SETTLEMENT PAYMENTS: If an assessment by Plaintiffs’ experts of
data produced by Google in the Action indicates that you are eligible
to receive a payment from the Settlement and you submit a completed
Payment Form, the Settlement Administrator will issue you a Settlement
Payment, as long as you are entitled to at least $1.00. You can fill
out the Payment Form online here
[https://lzzgcc5d.r.us-east-1.awstrack.me/L0/https:%2F%2Fadwordsclicksclassaction.com%2Fsubmit-claim/1/01000196a4104f18-caa01800-f4d4-4a00-af11-92c8116304ec-000000/iGiWiY3-WJ1e4BgmyVFiPLoiNIU=424].
You can also print out the Payment Form at
www.AdWordsClicksClassAction.com and mail your completed form to the
Settlement Administrator. PAYMENT FORMS MUST BE COMPLETED AND
SUBMITTED BY JULY 20, 2025. You may elect to receive your Settlement
Payment by physical check, virtual prepaid MasterCard, Venmo, or ACH
transfer (direct deposit). ACH transfer (direct deposit) may only be
requested via online submission. If you are eligible for a Settlement
Payment and do not indicate a payment method on the Payment Form, you
will receive the default payment (i.e., a virtual prepaid Mastercard)
* IMPORTANT: ONLY ONE PAYMENT WILL BE ISSUED PER CUSTOMER ID/ACCOUNT
NUMBER. To the extent there is more than one email address associated
with a single Customer ID/Account Number and multiple Payment Forms
are submitted for the same Customer ID/Account Number, the Settlement
Administrator will take steps to determine the primary Payment Form
and ensure that only one payment is issued.
* REQUEST EXCLUSION FROM THE SEARCH BUNDLED CLICKS CLASS: If you DO
NOT want to be a Search Bundled Clicks Class member and be legally
bound by any releases, judgments, or orders in the Action, YOU MUST
EXCLUDE YOURSELF from the Search Bundled Clicks Class by JULY 20,
2025. To exclude yourself or someone for whom you are an authorized
representative, you must: (i) send a letter by mail to _AdWords Clicks
Class Action_, ATTN: Exclusion Request, P.O. Box 58220, Philadelphia,
PA 19102 or (ii) submit your request for exclusion online at
www.AdWordsClicksClassAction.com, in accordance with the instructions
set forth in the Settlement Notice. Excluding yourself from the Class
is the only option that allows you to reserve your right to separately
sue Google regarding the legal claims in this lawsuit. Google retains
all of its defenses to any individual claims against it and may seek
the dismissal of those claims. If you exclude yourself, you will not
be eligible to receive a payment from the Settlement
* PLEASE NOTE: If you previously requested exclusion from the Class
pursuant to Class Notice, you do not have to request exclusion again.
If you previously requested exclusion, you will remain excluded from
the Class unless you request to opt back into the Class to be
potentially eligible to receive a Settlement Payment. You can request
to opt back into the Class by mailing a letter to _AdWords Clicks
Class Action_, ATTN: Opt Back In Request, P.O. Box 58220,
Philadelphia, PA 19102 or by emailing
info@AdWordsClicksClassAction.com by JULY 20, 2025.
* SUBMIT AN OBJECTION: Any Class Member who or that does not request
exclusion from the Class may file a written objection to the proposed
Settlement, the proposed Allocation Methodology, and/or Class
Counsel’s motion for attorneys’ fees and Litigation Expenses.
Objections must be submitted to the Court by JULY 20, 2025, in
accordance with the instructions set forth in the Settlement Notice.
Any Class Member who or that does not make his, her, or its objection
in the manner provided in the Settlement Notice may be deemed to have
waived his, her, or its right to object to any aspect of the proposed
Settlement, the proposed Allocation Methodology, and/or Class
Counsel’s motion for attorneys’ fees and Litigation Expenses and
shall be forever barred and foreclosed from objecting to the fairness,
reasonableness, or adequacy of the Settlement, the Allocation
Methodology, or the requested attorneys’ fees and Litigation
Expenses, or from otherwise being heard on these matters.
MORE INFORMATION: This notice summarizes the proposed Settlement.
Additional information regarding the Settlement and your options in
connection therewith can be found at www.AdWordsClicksClassAction.com.
You may also contact the Settlement Administrator at _AdWords Clicks
Class Action Settlement Administrator_, 1650 Arch Street, Suite 2210,
Philadelphia, PA 19103; 1-833-355-0988;
info@AdWordsClicksClassAction.com, or Court-appointed Class Counsel
Kessler Topaz Meltzer & Check, LLP, 280 King of Prussia Road, Radnor,
PA 19087; 1-610-667-7706; info@ktmc.com or Nix Patterson, LLP, 8701
Bee Cave Road, Building 1, Suite 500, Austin, TX 78746;
1-512-328-5333; info@nixlaw.com. You may also access the Settlement
Agreement and other case documents by accessing the Court docket for
the Action, for a fee, through the Court’s Public Access to Court
Electronic Records (PACER) system at https://ecf.cand.uscourts.gov.
PLEASE DO NOT CONTACT THE COURT, GOOGLE, OR GOOGLE’S COUNSEL
REGARDING THIS NOTICE.
UNSUBSCRIBE
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