Notice of Class Action Settlement
Google Street View WiFi Communications
Important Information – Read Carefully.


A class action Settlement has been proposed in litigation against Google LLC (“Google”) relating to allegations that Google “Street View” vehicles unlawfully captured electronic communications sent or received over wireless network connections (“WiFi connections”). If you used an unencrypted wireless network from which Google’s Street View vehicles obtained Payload Data (defined below) in the United States between January 1, 2007, and May 15, 2010, you are a Settlement Class Member.

“Payload Data” means data frames under the 802.11 Wireless Standard, consisting of a body that may contain the content of communications being transmitted over the network. Payload Data does not include data frames consisting of a header, nor does it include data frames containing solely network identifying information, such as a MAC Address or SSID.

Under the Settlement, Google has agreed to destroy the Payload Data that Street View vehicles acquired in the United States between January 1, 2007, and May 15, 2010. Google has also agreed not to collect and store Payload Data via Street View vehicles for use in any product or service, except with notice and consent. In addition to these and other commitments described below, Google has agreed to pay $13 million into a Settlement Fund. Google denies any wrongdoing, and no court or other entity has made any determination that any law has been violated.

The money in the Settlement Fund will be distributed to non-profit organizations that have a track record of addressing consumer concerns regarding the privacy of their electronic communications, as well as to pay attorneys’ fees and expenses as awarded by the Court, and the costs of giving notice of the Settlement to Class Members.

The non-profit organizations that will receive funds from the Settlement are called “Cy Pres Recipients.” The Plaintiffs have recommended the following organizations to the Court to be Cy Pres Recipients:

• American Civil Liberties Union Foundation, Inc.
• Center for Digital Democracy
• The Center on Privacy & Technology at Georgetown Law
• Consumer Reports, Inc.
• Massachusetts Institute of Technology - Internet Policy Research Initiative
• Public Knowledge
• Rose Foundation for Communities and the Environment
• World Privacy Forum

In addition, the Electronic Privacy Information Center has filed a motion with the Court seeking to also be a Cy Pres Recipient. The Court will select the Cy Pres Recipients and will decide how much money each will receive from the Settlement Fund. As a condition of receiving this money, each Cy Pres Recipient must commit to use the funds to promote the protection of Internet privacy.

The Court will decide whether to approve the proposed Settlement. If approved, the Settlement will resolve the litigation entitled In re Google Inc. Street View Electronic Communications Litigation, Case No. 10-md-02184, which is pending before Judge Charles R. Breyer in the Northern District of California.

The class action settlement approval process may take several months, or more if there is an appeal.


Please read this Notice carefully.


Your Legal Rights and Options in This Settlement
OBJECT TO OR COMMENT ON THE SETTLEMENT You may object to the Settlement by writing to the Court about why you don’t think the Settlement should be approved.

You can also write the Court to provide comments or reasons why you support the Settlement.

For detailed information about how to object to or comment on the Settlement, see Question 15 of the Long-Form Notice.
Deadline: January 20, 2020
GO TO THE FINAL APPROVAL HEARING You may, but are not required to, attend the Final Approval Hearing where the Court may hear arguments concerning the approval of the Settlement. If you wish to speak at the Final Approval Hearing, you must state your intention to do so in your written objection or comment. February 28, 2020 at 10:00 a.m
EXCLUDE YOURSELF FROM THIS SETTLEMENT You can exclude yourself from the Settlement by informing the Notice Administrator that you want to “opt-out” of the Settlement. If the Settlement becomes final, this is the only option that allows you to retain your rights to sue for claims relating to unencrypted WiFi communications acquired by Street View vehicles in the United States between January 1, 2007, and May 15, 2010. Deadline: January 20, 2020
DO NOTHING If you do nothing before the deadline to comment, object, or exclude yourself, and if the Settlement becomes final, you will give up your rights to sue for claims relating to the Plaintiffs’ complaint in this case, which alleges alleges between 2007 and May 15, 2010, Google Street View vehicles in the United States intentionally intercepted electronic communications that were sent over unencrypted wireless networks.

Notice of Class Action Settlement
Google Street View WiFi Communications
Important Information – Read Carefully.


A class action Settlement has been proposed in litigation against Google LLC (“Google”) relating to allegations that Google “Street View” vehicles unlawfully captured electronic communications sent or received over wireless network connections (“WiFi connections”). If you used an unencrypted wireless network from which Google’s Street View vehicles obtained Payload Data (defined below) in the United States between January 1, 2007, and May 15, 2010, you are a Settlement Class Member.

“Payload Data” means data frames under the 802.11 Wireless Standard, consisting of a body that may contain the content of communications being transmitted over the network. Payload Data does not include data frames consisting of a header, nor does it include data frames containing solely network identifying information, such as a MAC Address or SSID.

Under the Settlement, Google has agreed to destroy the Payload Data that Street View vehicles acquired in the United States between January 1, 2007, and May 15, 2010. Google has also agreed not to collect and store Payload Data via Street View vehicles for use in any product or service, except with notice and consent. In addition to these and other commitments described below, Google has agreed to pay $13 million into a Settlement Fund. Google denies any wrongdoing, and no court or other entity has made any determination that any law has been violated.

The money in the Settlement Fund will be distributed to non-profit organizations that have a track record of addressing consumer concerns regarding the privacy of their electronic communications, as well as to pay attorneys’ fees and expenses as awarded by the Court, and the costs of giving notice of the Settlement to Class Members.

The non-profit organizations that will receive funds from the Settlement are called “Cy Pres Recipients.” The Plaintiffs have recommended the following organizations to the Court to be Cy Pres Recipients:

• American Civil Liberties Union Foundation, Inc.
• Center for Digital Democracy
• The Center on Privacy & Technology at Georgetown Law
• Consumer Reports, Inc.
• Massachusetts Institute of Technology - Internet Policy Research Initiative
• Public Knowledge
• Rose Foundation for Communities and the Environment
• World Privacy Forum

In addition, the Electronic Privacy Information Center has filed a motion with the Court seeking to also be a Cy Pres Recipient. The Court will select the Cy Pres Recipients and will decide how much money each will receive from the Settlement Fund. As a condition of receiving this money, each Cy Pres Recipient must commit to use the funds to promote the protection of Internet privacy.

The Court will decide whether to approve the proposed Settlement. If approved, the Settlement will resolve the litigation entitled In re Google Inc. Street View Electronic Communications Litigation, Case No. 10-md-02184, which is pending before Judge Charles R. Breyer in the Northern District of California.

The class action settlement approval process may take several months, or more if there is an appeal.


Please read this Notice carefully.


Your Legal Rights and Options in This Settlement

OBJECT TO OR COMMENT ON THE SETTLEMENT

You may object to the Settlement by writing to the Court about why you don’t think the Settlement should be approved.

You can also write the Court to provide comments or reasons why you support the Settlement.

For detailed information about how to object to or comment on the Settlement, see Question 15 of the Long-Form Notice.


GO TO THE FINAL APPROVAL HEARING

You may, but are not required to, attend the Final Approval Hearing where the Court may hear arguments concerning the approval of the Settlement. If you wish to speak at the Final Approval Hearing, you must state your intention to do so in your written objection or comment.


EXCLUDE YOURSELF FROM THIS SETTLEMENT

You can exclude yourself from the Settlement by informing the Notice Administrator that you want to “opt-out” of the Settlement. If the Settlement becomes final, this is the only option that allows you to retain your rights to sue for claims relating to unencrypted WiFi communications acquired by Street View vehicles in the United States between January 1, 2007, and May 15, 2010.


DO NOTHING

If you do nothing before the deadline to comment, object, or exclude yourself, and if the Settlement becomes final, you will give up your rights to sue for claims relating to the Plaintiffs’ complaint in this case, which alleges alleges between 2007 and May 15, 2010, Google Street View vehicles in the United States intentionally intercepted electronic communications that were sent over unencrypted wireless networks.