Hibnick v. Google Inc.

Filing 62

Declaration of Susan Fahringer in Support of 61 MOTION to Approve Consent Judgment Notice of Motion and Memorandum in Support of Motion for Order Granting Final Approval of Class Settlement, Certifying Settlement Class, and Appointing Class Representatives and Class Counsel filed byJohn Case, Barry Feldman, Lauren Maytin, Mark Neyer, Andranik Souvalian, Katherine C Wagner, Rochelle Williams. (Related document(s) 61 ) (Mason, Gary) (Filed on 12/20/2010)

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Susan D. Fahringer, Bar No. 162978 [e-mail] PERKINS COIE LLP 1201 Third Avenue, Suite 4800 Seattle, WA 98101-3099 Telephone: [phone] Facsimile: 206.359.9000 Attorneys for Defendant GOOGLE INC.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

IN RE GOOGLE BUZZ PRIVACY LITIGATION

Case No. 10-CV-00672-JW DECLARATION OF SUSAN FAHRINGER

Original Complaint Filed 02/17/10

Susan Fahringer declares: 1. I am a partner with Perkins Coie LLP, counsel for Google Inc. ("Google"). I make

this declaration based upon my personal knowledge, and I am competent to testify to its contents. 2. On September 10, 2010, seven (7) days after plaintiffs filed their motion for

preliminary approval of the settlement of this matter, Perkins Coie staff acting under my direction served on the appropriate federal and state officials notice of the proposed settlement of this action pursuant to 28 U.S.C. § 1715(b) (the "CAFA Notice"). A copy of the Notice is attached as Exhibit 1. It was accompanied by a cover letter (attached as Exhibit 2), and enclosed the following, in portable document format (PDF) on CD-ROM:

DECLARATION OF SUSAN FAHRINGER
41063-0140/LEGAL19727130.1

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(a)

Plaintiff's original Complaint, First Amended Class Action Complaint, and

Consolidated Amended Complaint (pursuant to CAFA, 28 U.S.C. § 1715(b)(1)); (b) the parties' proposed notice to class members, including notice regarding

class members' rights regarding exclusion from the settlement, and notice regarding the proposed settlement (pursuant to CAFA, 28 U.S.C. § 1715(b)(3)); and (c) the parties' Settlement Agreement and all exhibits thereto (pursuant to

CAFA, 28 U.S.C. § 1715(b)(4)). 3. The CAFA Notice was served on the Attorney General of the United States and

the Attorneys Generals of each of the United States. A list of the names and addresses of the federal and state officials served with the CAFA Notice is attached as Exhibit 3. 4. On September 17, 2010, Perkins Coie staff acting under my direction sent a

supplemental letter to the state and federal officials identified in Exhibit 3, notifying those officials that the hearing date on the parties' Motion for Preliminary Approval had been scheduled for October 4, 2010 at 9:00 a.m. (pursuant to CAFA, 28 U.S.C. § 1715(b)(2)). A copy of the supplemental letter is attached as Exhibit 4. I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. EXECUTED this 15th day of December, 2010, at Seattle, Washington.

s/ Susan Fahringer Susan D. Fahringer, SBN 162978 PERKINS COIE LLP 1201 Third Avenue, Suite 4800 Seattle, WA 98101-3099 Tel [phone] Fax [phone] Email [e-mail] Attorneys for Defendant GOOGLE INC.

DECLARATION OF SUSAN FAHRINGER
41063-0140/LEGAL19727130.1

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