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" Title ‪Notification re: Class Action Notice Program in Rodriguez et al., v. Google LLC affecting some of your end users‬‬ Summary

Workspace Administrator,

You are receiving this email because a federal court recently ordered that notice be sent to all Enterprise Dasher account holders (i.e., End Users) who may be class members in a class action filed against Google in July 2020 titled, Rodriguez et al., v. Google LLC pending in the United States District Court for the Northern District of California, Case No. 3:20-cv-04688-RS.

Details of when notice will be distributed to End Users are being finalized but, for now, we know that they will be sent to your End Users by email and wanted to keep you apprised and ask that you consider and satisfy any obligations that you may have under the Google Workspace Terms of Service, including those outlined in Sections 3 and 7 as a result of this notice. Please find attached a list of email addresses of all the Workspace End Users in your organization who will be sent a class notification email. We are sending this notice consistent with our obligations under these Terms, the Court’s orders regarding class notice, and standard class notification practices. More detail about the case, email notices, and proposed next steps are provided for you below.

Case overview

Four Google account holders (“Plaintiffs”) filed a class action lawsuit against Google LLC (“Google”) alleging that Google unlawfully accessed their devices and data from non-Google mobile apps, even though Web & App Activity (“WAA”) and/or supplemental Web & App Activity (“sWAA”) were turned off or “paused.”

Plaintiffs allege Google unlawfully accessed their mobile devices to collect, save, and use data concerning their activity on non-Google apps that have incorporated certain Google software code into the apps while WAA and/or sWAA were turned off or “paused.”

Plaintiffs assert three legal claims against Google: 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.

Activity data generated by end users using Google Workspace apps or services is not at issue in this case, but Workspace end users are class members if they fit the class definitions, including, e.g., because they used non-Google apps while signed into their Workspace accounts.

Google denies Plaintiffs’ legal claims and does not admit to any wrongdoing. The Court has not decided who is right.

Who is in the class?

The Court certified four classes to assert claims for damages, detailed below.

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 G...