Instagram Privacy Settlement Administrator <donotreply@instagrambipasettlement.com>

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NOTICE OF PROPOSED CLASS ACTION SETTLEMENT

IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
DUPAGE COUNTY, ILLINOIS

If you used Instagram while in Illinois between August 10, 2015 and August 16, 2023,
You May Be Entitled to a Payment from a Class Action Settlement.

A court has authorized this notice. This is not a solicitation from a lawyer.
Why have I received this notice?

A settlement has been reached in a class action lawsuit against Meta Platforms, Inc. (“Defendant”) for alleged violations of Illinois’ Biometric Information Privacy Act, 740 ILCS 14/1, et seq. (“BIPA”), based on the Defendant allegedly collecting and storing biometric identifiers and/or biometric information (collectively, “biometric data”) via Instagram without complying with BIPA’s requirements.

A Court has authorized this notice because you have a right to know about the proposed settlement of this class-action lawsuit (the “Settlement”), and your options, before the Court decides whether to give “final approval” to the Settlement. This notice summarizes the lawsuit, the proposed Settlement, and your legal rights.

Who is included in the Settlement Class?

The Settlement Class includes: All individuals who used Instagram while in Illinois at any time between August 10, 2015, and August 16, 2023 (the “Class Period”).

What are the benefits of the Settlement?

The Settlement provides for the establishment of a Settlement Fund in the amount of $68,500,000.00 (Sixty-Eight Million Five Hundred Thousand Dollars), to pay for: (i) all Settlement Payments; (ii) all Settlement Administration Expenses; (iii) all Taxes and Tax Expenses; (iv) any Service Awards to the Class Representatives; and (v) any Fee Award to Class Counsel.

Each Settlement Class Member who timely files with the Settlement Administrator an Approved Claim will receive a settlement payment of a pro rata share of the Settlement Fund.

In order to receive a Settlement Payment, you must complete and submit a Claim Form by September 27, 2023. Claim Forms may be submitted online at www.InstagramBIPAsettlement.com or printed from the website and mailed to the Settlement Administrator. Claim Forms submitted by mail must be postmarked no later than September 27, 2023.

How can I exclude myself from the Settlement Class?

If you don’t want to make a claim and you don’t want to be legally bound by the Settlement, your letter requesting to be excluded must be submitted no later than August 16, 2023, or you will not be able to sue, or continue to sue, the Defendant about the claims and allegations in this case. Refer to the Settlement Website and the Class Notice for information and instructions on how to exclude yourself.

How can I object?

If you want to stay in the Settlement Class, but you want to object to the Settlement and/or to Class Counsel’s request for Attorneys’ Fees and Costs, your objection must be filed with the Court no later than August 16, 2023. Refer to the Settlement Website and the Class Notice for information and instructions on how to object.

Do I have a lawyer in this case?

Yes, the Court has appointed the law firm of Milberg Coleman Bryson Phillips Grossman PLLC to represent the Class. These attorneys are called Class Counsel. You will not be charged for their services. If you want to be represented by another lawyer, you may hire one to appear in Court for you at your own expense.

The Court’s Final Approval Hearing.

The Court has scheduled a Final Approval Hearing on October 11, 2023 at 10:00 a.m. at the DuPage County Judicial Center, 505 N County Farm Road, Wheaton, IL 60187. The hearing may be moved to a different date or time without additional notice, so it is a good idea to check www.InstagramBIPAsettlement.com for updates. At the Final Approval Hearing, the Parties will request that the Court consider whether the Settlement Class should be certified as a class pursuant to 735 ILCS 5/2 for settlement and, if so, (i) consider any properly-filed objections; (ii) determine whether the Settlement is fair, reasonable and adequate, was entered into in good faith and without collusion, and should be approved, and shall provide findings in connection therewith; and (iii) enter the Final Approval Order, including final approval of the Class Action Settlement Agreement and Release, and a Fee Award. It is unknown how long these decisions will take.

Where can I get more information?

This Notice summarizes the proposed Settlement. More details are in the Class Action Settlement Agreement & Release, which you can view at www.InstagramBIPAsettlement.com. You can also contact the Settlement Administrator by mail, email or phone.

Instagram Privacy Settlement
c/o Settlement Administrator
1650 Arch Street, Suite 2210
Philadelphia, PA 19103
Info@InstagramBIPAsettlement.com
(844) 688-8804