In re Google Referrer Header Privacy Litigation

Filing 70

OBJECTION (re #65 MOTION for Settlement (Final Approval), #66 MOTION for Attorney Fees Expenses and Costs filed by Theodore H Frank, Melissa Holyoak. (Attachments: #1 Declaration of Melissa Holyoak, #2 Declaration of Theodore H. Frank)(Frank, Theodore) (Filed on 8/8/2014) Modified TEXT on 8/8/2014 (cv, COURT STAFF).

Case5:10-cv-04809-EJD Document70-1 Filed08/08/14 Page1 of 2

1 II Theodore H. Frank (SBN 196332)
CENTER FOR CLASS ACTION FAIRNESS
2 11 1718 M Street NW
No. 236
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Washington, DC 20036
4 11 Voice: [phone]
Email: [e-mail]
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Attornrys for Of:jectors Theodore H. Frank and Melissa Ho/yoak
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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In re GOOGLE REFERRER HEADER PRIVACY

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Case No. 5:10-cv-04809-EJD

1211 LITIGATION

I DECLARATION OF MELISSA HOLYOAK

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1511 THEODORE H. FRANK and MELISSA A.
HOLYOAK
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Objectors.

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Case No: 5:10-cv-04809 EJD
DECLARATION OF MELISSA HOLYOAJ...::

Date:
Time:
Courtroom:
Judge:

August 29, 2014
9:00 a.m.
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Hon. Edward J. Davila

Case5:10-cv-04809-EJD Document70-1 Filed08/08/14 Page2 of 2

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I, Melissa A. Holyoak, declare as follows:

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1. I have personal knowledge of the facts set forth herein and, if called as a witness, could and

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would testify competendy to them.
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2. My mailing address is 1718 M Street NW, #236, Washington, DC 20036. My telephone
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number is [phone]. My email address is [e-mail].
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3. I am a United States resident who has submitted a search query to Google on hundreds or
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thousands of occasions since October 25, 2006.
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4. I am thus a member of the proposed setdement class with standing to object. See Fed. R.
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Civ. P. 23(e)(5).
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5. I have an email account through Google's Gmail service. Nonetheless, I did not receive any
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direct notice of the setdement in this case, even though the defendant undoubtedly
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possesses my contact information in its records.
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6. I bring this objection in good faith to prevent approval of an unfair setdement and
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ratification of an improper certification. I am a senior attorney with the Center for Class
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Action Fairness ("Center"). Because the Center is non-profit, it cannot and does not setde
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its objections for a quid pro quo cash payment to withdraw, as many professional objectors
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do. I am willing to stipulate to an injunction forbidding me from setding my objection for
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personal fmancial gain. See BrianT. Fitzpatrick, The End ifOijector Blackmail?, 62 VAND. L.
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REV.

1623 (2009) (suggesting inalienability of objections as solution to objector blackmail

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problem).
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7. The specific grounds of my objection are identified in my contemporaneously-flied

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objection.
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I declare under penalty of perjury of the laws of the United States of America that the foregoing is

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true and correct.
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Executed on August 8, 2014 in Salt Lake City, Utah. ~
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Melissa A. Holyoak

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Case No: 5:10-cv-04809 EJD
DECLARATION OF MELISSA HOLYOAK

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