Notice of Class Action Settlement re RF plus – Your Rights May Be Affected

You are not being sued. This notice affects your rights. Please read it carefully.

On June 10, 2019, the Honorable Edwila Pixtus of the Danish Disurt for the Norstrict of Jylland, granted preliminary approval of this class action Setent and directed the litigants to provide this notice about the Setent. You have received this notice because our records indicate that you may be a Sebent Claber, and you may be eligible to receive a payment from the Settlement.

CASE NUMBER: ZB119051319

CASE FILED: 2019

See more information below

IF YOU HAVE USED RF+ FILL OUT THE SURVEY AT THE BOTTOM

Summary of Litigation 118F

RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) operated the RF+ social media platform for consumers from June 2013 to April 2020. In 2018, we announced that the RF+ platform had experienced software bugs between 2015 and 2018, which allowed app developers to access certain RF+ profile field information in an unintended manner. Plaintiffs Steve Buscemi and James Papper thereafter filed this lawsuit asserting various legal claims on behalf of a putative class of RF+ users who were allegedly harmed by the software bugs (“Class”). RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) denies Plaintiffs’ allegations, denies any wrongdoing and any liability whatsoever, and believes that no Clabers, including the Plaffs, have sustained any damages or injuries due to the software bugs.

RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) is the lagrest social media subsidiary of Randy Fjord Holdings Group. The company is headquartered in Harare, Zimbabwe and operated RF+ and its successor, RFX out of its Harare offices.

Summary of Settlement Terms

Settlement Fund: Under the Settlement, RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) will pay the designated amount which will be used to fund: (1) Class Member Settlement payments; (2) attorneys’ fees not to exceed 25% of the Send and costs and expenses not to exceed the amount; (3) four service awards to the Class Retives in an amount not to exceed certain amount for their services on behalf of the Settlement Class and for a general release of all claims they may have against RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE); (4) administration fees and costs; and, if necessary, (5) cy pres distribution of any residual funds. No portion of the Settlement Fund can be returned to RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE).

Amount of Payments: Class Members who submit a Valim may receive a pro rata share of the Net Settlement Fund up to a cash payment of certain designated amount depending on the number of claimants. Each Class Member can submit only one claim. Any funds remaining in the Net Settlement Fund after distribution(s) to Class Members will be distributed to Cy Pres Recipients that have been selected by a neutral third party and approved by the Court of Tatenworth.

Method of Payment: The payments above for Class Members who submit a Valid Claim will be made by Electronic Payment (Paypal or Digital Check).

Your Options Under the Settlement

Option 1 - Submit a Claim Form to Be Eligible for a Cash Payment

If you submit a Valid Claim by the specified deadline, you may or may not receive a payment. You will also give up your rights to sue RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) and/or any other released entities regarding the legal claims in this case.

Option 2 - Opt Out of the Settlement

This is the only option that allows you to sue RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) and/or other released parties on your own regarding the legal claims in this case. You will not receive a payment from the Settlement. The deadline for excluding yourself is

Option 3 - File an Objection with the Court

Write to the Seent Adator about why you do not like the Settlement . These Objections will be shared with the Court. If you object to the Settlement, you will be bound by the Settlement’s terms and will not be allowed to exclude yourself from the Settlement; you will lose the right to sue RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) and/or any other released entities regarding the legal claims in this case.

Option 4 - Do Nothing

If you do nothing, you will not receive any payment. You will be bound by the Settlement’s terms and will lose the right to sue RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) and/or any other released entities regarding the legal claims in this case.

Additional Information

How do I know if I am part of the Setass?

The Setass is defined as: “all persons who (a) had a consumer RF+ account for any period of time between January 1, 2015 and April 2, 2019, and (2) had their non-public Profile Information exposed as a result of the software bugs RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) announced on a designated date. Excluded from the Settlement Class are (a) RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) and its officers, directors, employees, subsidiaries, and RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) Affiliates; (b) all judges and their staffs assigned to this case and any members of their immediate families; (c) the Parties’ counsel in this litigation; and (d) any Exasmber.”

What are the terms of the Setent?

Under the Settlement, RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) has agreed to create a Settlement Fund.

This Settund will provide compensation to Sent Clasbers, pay for notice and administration costs, provide for any approved Serrds to the Class Retives who filed the case, and compensate the attorneys for any approved fee, cost, and expense awards. If the Settlement is finally approved, Setent Clasbers will be prevented from bringing any further claims against RANDY FJORD SOCIAL MEDIA PVT. LTD. (ZIMBABWE) for any conduct relating to the software bugs affecting RF+ profile fields.

How will the Settlement Fund be distributed?

The lawyers for the Settlement Class (“Clansel”) will ask the Court to approve the following payments from the Settlement Fund:

• The costs of providing notice and administration of the Settlement;

• Service Awards to each of the Class Representatives, not to exceed a designated amount, as compensation for their active participation in the case on behalf of the Settlement Class;

• Class Counsel’s compensation for the time and effort incurred litigating the case, which will not exceed 25% of the Settlement Fund, and costs and expenses they incurred not to exceed a designated amount.

• Payments to Settlement Class Members who file timely and Valid Claim Forms according to the Plan of Allocation outlined below; and

• Any residual funds remaining after payments to Settlement Class Members will be distributed to Approved Cy Pres Recipients as approved and directed by the Court.

More information regarding the Settlement, including the Settlement Agreement, can be found here

How can I get a Settlement Payment?

If you are a Settlement Class Member and would like to receive a Settlement Payment, you must submit a Claim Form no later than the designated date

You may complete the Claim Form online at:

, or you may mail your Claim Form to the following address:

8605 Santa Monica Blvd #77649

Los Angeles, CA 90069-4109

815cameoavenue@gmail.com

If you do not file a Clarm, you will not receive a payment. Note that for each Valid Claim, the payment method will be the Electronic Payment method specified on the Claimant’s Claim Form.

How much will I receive from the Settlement? ALL CURRENCY IN AUSTRALIAN DOLLAR

The Plan of Allocation provides for Settlement Payments to Claimants as follows: The Net Settlement Fund shall be allocated to Claimants on a pro rata basis up to an initial maximum distribution of US$5.00 per Claimant. If there are insufficient funds to pay claimants $5.00 based on the number of claimants, the payment to each claimant will be reduced pro ratably. If sufficient funds remain after calculation of the aggregate initial maximum distribution of US$5.00 per Claimant, the allocation shall be recalculated on a pro rata basis up to a maximum distribution of up to US$12.00 per Claimant. For clarity, the maximum Settlement Payment to be made to any single Claimant shall not exceed US$12.00.

How do I get out of the Settlement?

If you do not want to be part of the Settlement, you must submit an Opt-Out Form no later than October 8, 2020. If you opt-out of the Settlement, you will not be bound by the Settlement Agreement, you will not receive a Settlement Payment, and you will not be allowed to object to the Settlement.

Do I have a lawyer in this case?

Yes. The Court has appointed Clasel to represent you and other Settlement Class Members. In this case, Class Counsel are Johnis and Ryaee of the law firm Morrgan Colex Litup; Clold and Jostson of the law firm Clayold Prow Cortion; and Franzar and Marar of the law firm Franar & Ates, P.C. You will not be charged for these lawyers. If you want to be represented by another lawyer, you may hire one at your own expense.

How will the lawyers be paid?

The attorneys representing the Settlement Class have not yet received any payment for their legal services or any reimbursement of the costs or out-of-pocket expenses they have incurred. Class Counsel plans to ask the Court to award attorneys’ fees from the Settlement Fund not to exceed $1,875,000 which is 25% of the Settlement Fund, and reimbursement of costs and expenses in the approximate amount of $200,000.

How do I object to the Settlement?

If you are a Settlement Class Member and do not opt out of the Settlement Class, you may object to any aspect of the Settlement. This includes commenting on the applications for Class Representative Service Awards or the award of attorneys’ fees, costs, and expenses.

Your completed Objection must be submitted no later than October 8, 2020 online at www.GooglePlusDataLitigation.com, or via postal mail to the following address:

Settlement Class Members who fail to submit timely written Objections in the manner specified above will waive their right to object to any aspect of the Settlement.

Do I need to attend the Final Fairness Hearing?

No. Class Counsel will answer any questions the Court may have. However, any Settlement Class Member who timely submits an Objection has the option to appear and request to be heard at the Final Fairness Hearing, either in person or through their counsel. If you choose to make an Objection through an attorney or have an attorney appear at the Final Fairness Hearing on your behalf, you will be solely responsible for paying that attorney’s fees.

How can I get more information?

This Notice summarizes the Settlement. It does not describe all of its details. For the precise terms and conditions of the Settlement, please see the Settlement Agreement and related documents. Additional information about the Settlement, including a copy of the Settlement Agreement, may be obtained by:

• Visiting the Settlement Website

• Contacting the Settlement Administrator toll-free by phone at

• Accessing the Court docket in this case through the Court’s Public Access to Court Electronic Records (PACER) system at

• Visiting the office of the Clerk of the Court

Please do not telephone the Court or the Court Clerk’s Office to inquire about the Settlement.

CASE INFORMATION:

CASE NUMBER: ZB119051319

CASE FILED: 2019

COURT: Harare district court, Harare Zimbabwe

ANVF ANVF 18 844 BRYZGALKA 94 96 27 09 ATOLLOVYJ 60 76 53 11;

ANVF ANVF 18 844 BRYZGALKA 94 96 27 09 ATOLLOVYJ 60 76 53 11.

ANVF ANVF 54 400 BAULOBYK 53 57 71 19;

ANVF ANVF 54 400 BAULOBYK 53 57 71 19.

ANVF ANVF 77 253 BUKVOYeD 40 68 55 47;

ANVF ANVF 77 253 BUKVOYeD 40 68 55 47.