1:19-cv-01330-MMM # 72 Page 1 of 52 E-FILED Monday, 28 June, 2021 07:40:10 PM Clerk, U.S. District Court, ILCD
IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF ILLINOIS PEORIA DIVISION
NOREEN PERDUE, ELIZABETH DAVIS-BERG, ) DUSTIN MURRAY, CHERYL ELLINGSON, ) ANGELA TRANG, GORDON GREWING, and ) MELISSA WARD individually and on behalf of all ) others similarly situated, ) ) Plaintiffs, ) CASE NO. 1:19-cv-01330-MMM-JEH ) v. ) ) HY-VEE, INC., ) ) Defendant. ) ) )
DECLARATION OF JEANNE C. FINEGAN, APR, CONCERNING IMPLEMENTATION OF CLASS NOTICE
INTRODUCTION 1. I am Managing Director and Head of Kroll Notice Media Solutions (“Kroll Media”) an affiliate company of Kroll Settlement Administration (“Kroll”) f/k/a Heffler Claims Group LLC. This Declaration is based upon my personal knowledge as well as information provided to me by my associates and staff, including information reasonably relied upon in the fields of advertising media and communications.
2. Pursuant to the Order Preliminarily Approving the Settlement and Certifying the Settlement Class (“Order”), dated January 25, 2021, Kroll Settlement Administration (formerly Heffler Claims Group) was appointed as the Settlement Administrator to provide notification and claims administration services in this case (referred to herein as the “Settlement.”) Specifically, Kroll Media was engaged by the parties to this litigation to develop and implement a legal notice program as part of the parties’ class action settlement.
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3. The purpose of this Declaration is to provide a report to the Court concerning the successful implementation of the notice program for this settlement. 4. The notice program employed best-in-class tools and technology to reach approximately 81% of targeted Class Members in the eight states with Hy-Vee store locations1, on average approximately 3.5 times, through online display, search and social impressions with cross-device targeting on desktop, mobile and tablet, a press release, a settlement website and a toll-free number. 5. At the direction of counsel for the Defendant Hy-Vee, Inc., 57 officials, which included the Attorney General of the United States and the Attorneys General of each of the 50 states, the District of Columbia, and the United States Territories, were identified to receive the CAFA notice. 6. Kroll maintains a list of these state and federal officials with contact information for the purpose of providing CAFA notice. Prior to mailing, the names and addresses selected from Kroll’s list were verified. 7. On January 22, 2021, Kroll sent 57 CAFA Notice Packages (“Notice”). The Notice was mailed by first class certified mail to 57 officials, including the Attorneys General of each of the 50 states, the District of Columbia, and the United States Territories. The CAFA Notice
Service List (USPS Priority Mail and UPS) is included hereto as Exhibit A.
8. The materials sent to the Attorneys General included a cover letter, which provided notice of the proposed settlement of the above-captioned case. The cover letter is included hereto as Exhibit B.
9. The cover letter was accompanied by a CD, which included the following:
. Complaint, First Amended Complaint, and Consolidated Second Amended Complaint;
1 Hy-Vee has store locations in Iowa, Illinois, Kansas, Minnesota, Missouri, Nebraska, South Dakota and Wisconsin. H0105971. -2- 1:19-cv-01330-MMM # 72 Page 3 of 52
. Motion for Preliminary Approval of Class Settlement Agreement;
. Forms of Notice of Class Action Settlement;
. Class Action Settlement Agreement;
. Proposed Final Order of Approval; and
A List showing the estimated number of Class Members per state as well as a list of the specific locations and time frames affected during the Security Incident.
NOTICE PROGRAM SUMMARY 10 The notice program for this settlement was designed to inform Class Members of the class action settlement between Plaintiffs and Defendant. Pursuant to the Settlement Agreement, §IV paragraph 1.26, the Settlement Class is defined as:
All persons residing in the United States who used a payment card to make a purchase at an affected Hy-Vee point-of-sale device during the Security Incident, which as described in the definition of Security Incident occurred during the time frames and at the locations set forth in Exhibit C to the Settlement Agreement. 11. Pursuant to the Court’s Order, the notice program included the following components: Direct e-mail or first-class U.S. mail notice to reasonably and readily identifiable Class Members; Online display banner advertising specifically targeted to reach Class Members; Keyword Search targeting Class Members; Social media through Facebook and Instagram; A press release across PR Newswire’s US1 Newslines; An informational website was established on which the notices and other important Court documents are posted; and A toll-free information line was established by which Class Members can call 24/7 for more information about the Settlement, including, but not limited to, requesting copies of the Long Form Notice. DIRECT NOTICE 12. On or around, January 13, 2021 Kroll was provided with the Class Data Lists from Hy-Vee. There were three separate data files provided. The first file contained 488,957 records and the data file’s key components were First Name, Last Name, Address, City, State
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and Zip. The second file contained 9,769 records and the data file’s key components were First Name, Last Name, Address, City, State, Zip Code, Fuel Saver Number and last digits of cards. The third file contained 23,260 records and the data file’s key components were First Name, Last Name, Email Address, Fuel Saver Number and last 4 digits of cards. The third file was used for an email campaign. After analyzing and de-duping the first two files, Kroll determined that 493,202 records would be mailed. All records from the third file were unique resulting in 23,260 emails being attempted. 13. Email Notice: On or around, February 2, 2021, Kroll received Word versions of the Email Notice from counsel. In preparation for the email notices, Kroll worked with the Parties to finalize the language for the Notice. Kroll prepared and formatted drafts of the materials that counsel reviewed and approved. In addition, Kroll prepared a file that contained records for which an email address was provided in the Class List. Kroll prepared email samples for the Parties to review and approve. Upon approval of the proofs by Kroll and the Parties, Kroll initiated the email campaign as directed in the settlement documents. On February 22, 2021, Kroll initiated an email blast to 23,260 Class Members. 14. As part of the email campaign process, the email provider notifies each of the major ISPs that Kroll is about to begin a large email campaign. This greatly reduces the risk that the ISPs will incorrectly identify Kroll-originated emails as junk mail and intercept them or otherwise divert them from recipients’ inboxes. Our email service provider also reviews the proposed email subject line and body content for potential spam filter triggering words and phrases and provides recommendations for any trouble spots. When the email campaign began, Kroll tracked and monitored emails that bounced. Kroll attempted to re-send hard and/or soft bounced emails in an effort to deliver as many emails as possible. Kroll reported to the Parties the number of records that had a successful notice delivery, and a count for the records that delivery failed. Kroll updated its administration database with the appropriate status of the email campaign.
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15. If the email notice was delivered successfully, no further action was taken with respect to the record. 16. If the email not was not successfully delivered, and if a physical address is provided for the record, Kroll sent a notice via mail as detailed below. 17. Mailed Notice: Kroll received physical addresses for individuals on the Class List. In preparation for the notice mailing, Kroll ran the addresses on the Class List through the United States Postal Service’s (USPS) National Change of Address (NCOA) database. The NCOA process provided updated addresses for Class Members who have submitted a change of address with the USPS in the last 48 months, and the process also standardized the addresses for mailing. Kroll then prepared a mail file of Class Members that were to receive the notice via First Class Mail. 18. Also, in preparation for the notice mailing, Kroll worked with the Parties to format the Postcard Notice for mailing. Kroll prepared and formatted drafts of the materials that counsel reviewed and approved. Postcard proofs were provided for the Parties and Kroll to review and approve. The approved Postcards Notices were sent via First Class mail to 493,202 Class Members as directed in the Court documents. 19. As of June 24, 2021, Kroll has received 5 Notices returned by the USPS with a forwarding address. Kroll has re-mailed 5 of the forwarded Notices to the updated addresses provided by the USPS.
20. As of June 24, 2021, Kroll has received 1,460 Notices returned by the USPS as undeliverable as addressed. Kroll has updated the records in the database to identify these as undeliverable. Kroll sent 1,406 records through a skip trace process with LexisNexis and obtained 1,078 updated addresses. As of June 24, 2021, Kroll has re-mailed Notices to the 1,406 addresses obtained through the skip-trace process. 54 undeliverable notices were not skip traced or remailed since they were received recently but Kroll will process these undeliverable notices accordingly.
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21. Class members were able to submit claims online or through the mail. As of June 24, 2021, Kroll has received 6,454 timely Claim Forms. Kroll will validate the Claims for accuracy, in accordance with the settlement agreement. The deadline for Claims to be filed is June 22, 2021. 22. The deadline for the filing of requests for exclusion from the settlement was May 24, 2021. As of June 24, 2021, Kroll has received and processed 34 requests for exclusion from the Settlement. A list of the names of the persons who submitted timely exclusion requests is being submitted by counsel as an exhibit to the updated proposed order granting final approval to the settlement. Attached as Exhibit C is a list of those who have submitted exclusion requests. 23. The deadline for the filing of objections was also on May 24, 2021. As of June 24, 2021, Kroll has received one (1) objection to the Settlement.
DIGITAL PUBLICATION NOTICE 24. Over 45 million online display, search and social media impressions were served across a whitelist2 of pre-vetted websites, multiple exchanges, and the social media platforms Facebook and Instagram. 25. Display ads were targeted to frequent Hy-Vee shoppers, i.e. people who, on average, visit the grocery store at least 2 times per month and spend at least 10 minutes at each visit, as well as adults in the cities where Hy-Vee has store locations. Additionally, geo-fence3 location targeting was used to target people as they shopped at Hy-Vee grocery stores.
26. Keyword search targeting was employed to show advertisements to users in their Google search results. A list of search topics including Hy-Vee settlement, Hy-Vee class action, Hy-Vee locations, Hy-Vee coupons, among others, was applied.
2 A whitelist is a custom list of acceptable websites where ad content may be served. Creating a whitelist helps to mitigate ad fraud, ensure ads will be served in relevant digital environments to the target audience and helps to ensure that ads will not appear next to offensive or objectionable content. 3 Geofencing refers to location-based targeting using users’ IP addresses. Ads inside this parameter can be seen on a computer, tablet, or mobile devices by any users within this location. H0105971. -6- 1:19-cv-01330-MMM # 72 Page 7 of 52
27. On Facebook and Instagram, those who have liked or followed Hy-Vee pages as well as adults 35 years and older and those with a college education or higher in the cities where Hy-Vee has store locations were targeted. Further, the social media campaign included retargeting to users who visited the Settlement website. Copies of the display and social media ads are attached as Exhibit D.
PRESS RELEASE 28. On February 23, 2021, A press release was issued over PR Newswire’s US1 Newslines. Approximately 69 news mentions of the settlement have resulted from the press release. Attached as Exhibit E is a copy of the pick-up report.
OFFICIAL SETTLEMENT WEBSITE 29. An informational website was established on February 20, 2021 and continues to be maintained by Kroll: https://www.grocerysecurityincidentsettlement.com. All of the aforementioned methods of notice directed class members to this website. The website served as a “landing page for the banner advertising,” where Class Members could get information about the Settlement along with other information which includes information about the class action, their rights, the Long Form Notice, answers to frequently asked questions, contact information that includes the address for the Claim Administrator and addresses and telephone numbers for Plaintiffs’ Counsel, and related information, including the Settlement Agreement, Court Orders, and Plaintiffs’ Motion for Approval of Attorneys’ Fees, Costs, and Expenses, and Class
Representative incentive compensation. Class members may also view information about the claims submission process and submit claims via the website. As of June 24, 2021, over 46,500 users have visited the Settlement Website, with 97,618 page views4.
TOLL FREE INFORMATION LINE 30. Additionally, Kroll established and continues to maintain a 24-hour toll-free Interactive Voice Response (“IVR”) telephone line, where callers may obtain information about
4 A page view is an instance of a page being loaded (or reloaded) in a browser. This metric provided the total number of pages viewed on a website including repeat views. H0105971. -7- 1:19-cv-01330-MMM # 72 Page 8 of 52
the class action, including, but not limited to, requesting copies of the Long Form Notice. As of June 24, 2021, the IVR has received over 1,022 calls and 444 have selected a live operator.
CONCLUSION 31. In my opinion, the outreach efforts described above reflect a particularly appropriate, highly targeted, and contemporary way to employ notice to this class. Through a multi-media channel approach to notice, which employed direct notice, display, search, social media and a press release, an estimated 81 percent of targeted Class Members were reached by the media program, on average, 3.5 times. In my opinion, the efforts used in this notice program are of the highest modern communication standards, are reasonably calculated to provide notice, and are consistent with best practicable court-approved notice programs in similar matters and the Federal Judicial Center’s guidelines concerning appropriate reach. I declare under the penalty of perjury, under the laws of the United States of America, that the foregoing is true and correct. Executed on June 28, 2021, in Tigard, Oregon.
______Jeanne C. Finegan, APR
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Exhibit A 1:19-cv-01330-MMM # 72 Page 10 of 52
January 22, 2021 Page 4
SERVICE LIST FOR CAFA NOTICE
U.S. Attorney General Jeffrey A. Rosen U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001
Alabama Attorney General Steve Marshall 501 Washington Ave. P.O. Box 300152 Montgomery, AL 36130-0152
Alaska Attorney General Clyde Sniffen, Jr. 1031 W. 4th Avenue, Suite 200 Anchorage, AK 99501-1994
Arizona Attorney General Mark Brnovich 2005 N Central Ave Phoenix, AZ 85004
Arkansas Attorney General Leslie Rutledge 323 Center St., Suite 200 Little Rock, AR 72201-2610
California Attorney General Xavier Becerra 1300 I St., Ste. 1740 Sacramento, CA 95814
Colorado Attorney General Phil Weiser Ralph L. Carr Colorado Judicial Center 1300 Broadway, 10th Floor Denver, CO 80203
Connecticut Attorney General William Tong 165 Capitol Avenue Hartford, CT 06106 1:19-cv-01330-MMM # 72 Page 11 of 52
January 22, 2021 Page 5
Delaware Attorney General Kathy Jennings Carvel State Office Building 820 N. French St., Wilmington, DE 19801
District of Columbia Attorney General Karl A. Racine 400 6th St., NW Washington, DC 20001
Florida Attorney General Ashley Moody The Capitol, PL 01 Tallahassee, FL 32399-1050
Georgia Attorney General Chris Carr 40 Capitol Square, SW Atlanta, GA 30334-1300
Hawaii Attorney General Clare E. Connors 425 Queen St. Honolulu, HI 96813
Idaho Attorney General Lawrence Wasden 700 W. Jefferson Street, Suite 210 P.O. Box 83720 Boise, ID 83720-1000
Illinois Attorney General Kwame Raoul James R. Thompson Ctr. 100 W. Randolph St. Chicago, IL 60601
Indiana Attorney General Todd Rokita Indiana Government Center South 302 West Washington Street 5th Floor Indianapolis, IN 46204 1:19-cv-01330-MMM # 72 Page 12 of 52
January 22, 2021 Page 6
Iowa Attorney General Tom Miller Hoover State Office Building 1305 E. Walnut Des Moines, IA 50319
Kansas Attorney General Derek Schmidt 120 S.W. 10th Ave., 2nd Fl. Topeka, KS 66612-1597
Kentucky Attorney General Daniel Cameron 700 Capitol Avenue Capitol Building, Suite 118 Frankfort, KY 40601
Louisiana Attorney General Jeff Landry P.O. Box 94095 Baton Rouge, LA 70804-4095
Maine Attorney General Aaron Frey State House Station 6 Augusta, ME 04333
Maryland Attorney General Brian Frosh 200 St. Paul Place Baltimore, MD 21202-2202
Massachusetts Attorney General Maura Healey 1 Ashburton Place Boston, MA 02108-1698
Michigan Attorney General Dana Nessel P.O. Box 30212 525 W. Ottawa St. Lansing, MI 48909-0212 1:19-cv-01330-MMM # 72 Page 13 of 52
January 22, 2021 Page 7
Minnesota Attorney General Keith Ellison Suite 102, State Capital 75 Dr. Martin Luther King Jr. Blvd. St. Paul, MN 55155
Mississippi Attorney General Lynn Fitch Department of Justice P.O. Box 220 Jackson, MS 39205
Missouri Attorney General Eric Schmitt Supreme Ct. Bldg. 207 W. High St. Jefferson City, MO 65101
Montana Attorney General Austin Knudsen Justice Bldg. 215 N. Sanders Helena, MT 59620-1401
Nebraska Attorney General Doug Peterson State Capitol P.O. Box 98920 Lincoln, NE 68509-8920
Nevada Attorney General Aaron D. Ford Old Supreme Ct. Bldg. 100 N. Carson St. Carson City, NV 89701
New Hampshire Attorney General Gordon MacDonald 33 Capitol St. Concord, NH 03301
New Jersey Attorney General Gurbir S. Grewal Richard J. Hughes Justice Complex 25 Market Street, P.O. Box 080 Trenton, NJ 08625 1:19-cv-01330-MMM # 72 Page 14 of 52
January 22, 2021 Page 8
New Mexico Attorney General Hector Balderas P.O. Drawer 1508 Santa Fe, NM 87504-1508
New York Attorney General Letitia A. James Department of Law - The Capitol, 2nd fl. Albany, NY 12224
North Carolina Attorney General Josh Stein Dept. of Justice P.O. Box 629 Raleigh, NC 27602-0629
North Dakota Attorney General Wayne Stenehjem State Capitol 600 E. Boulevard Ave. Bismarck, ND 58505-0040
Ohio Attorney General Dave Yost State Office Tower 30 E. Broad St., Columbus, OH 43266-0410
Oklahoma Attorney General Mike Hunter 313 NE 21st Street Oklahoma City, OK 73105
Oregon Attorney General Ellen F. Rosenblum Justice Bldg. 1162 Court St., NE Salem, OR 97301
Pennsylvania Attorney General Josh Shapiro Pennsylvania Office of Attorney General 16th Floor, Strawberry Square Harrisburg, PA 17120 1:19-cv-01330-MMM # 72 Page 15 of 52
January 22, 2021 Page 9
Rhode Island Attorney General Peter F. Neronha 150 S. Main St. Providence, RI 02903
South Carolina Attorney General Alan Wilson Rembert C. Dennis Office Building P.O. Box 11549, Columbia, SC 29211-1549
South Dakota Attorney General Jason Ravnsborg 1302 East Highway 14, Suite 1 Pierre, SD 57501-8501
Tennessee Attorney General Herbert H. Slatery, III 425 5th Avenue North Nashville, TN 37243
Texas Attorney General Ken Paxton Capitol Station P.O.Box 12548 Austin, TX 78711-2548
Utah Attorney General Sean Reyes State Capitol, Rm. 236 Salt Lake City, UT 84114-0810
Vermont Attorney General TJ Donovan 109 State St. Montpelier, VT 05609-1001
Virginia Attorney General Mark Herring 202 North Ninth Street Richmond, VA 23219 1:19-cv-01330-MMM # 72 Page 16 of 52
January 22, 2021 Page 10
Washington Attorney General Bob Ferguson 1125 Washington St. SE P.O. Box 40100 Olympia, WA 98504-0100
West Virginia Attorney General Patrick Morrisey State Capitol 1900 Kanawha Blvd., E. Charleston, WV 25305
Wisconsin Attorney General Josh Kaul Wisconsin Department of Justice, State Capitol, Room 114 East P.O. Box 7857 Madison, WI 53707-7857
Wyoming Attorney General Bridget Hill State Capitol Bldg. Cheyenne, WY 82002 1:19-cv-01330-MMM # 72 Page 17 of 52
Exhibit B 1:19-cv-01330-MMM # 72 Page 18 of 52
Paul G. Karlsgodt direct dial: 303.764.4013 January 22, 2021 [email protected]
VIA FIRST CLASS CERTIFIED MAIL
Re: CAFA Notice for the Proposed Settlement in Perdue, et al. v Hy-Vee, Inc., Case No. 1:19-cv-01330-MMM-JEH in the United States District Court for the Central District of Illinois Peoria Division
Dear
Baker & Hostetler LLP represents Defendants, Hy-Vee, INC., (“Defendants”) in a putative Class Action Lawsuit entitled Perdue, et al. v. Hy-Vee, INC., Case No. 1:19-cv-01330-MMM-JEH. The Lawsuit is pending before the Honorable Judge Michael M. Mihm in the United States District Court for the Central District of Illinois. This letter is to advise you that Plaintiff, Noreen Perdue, filed a Motion for Preliminary Approval of Class Action Settlement in connection with this Class Action Lawsuit on January 12, 2021.
Case Names: Perdue, et al. v. Hy-Vee, INC.
Lead Case Number: 1:19-cv-01330-MMM-JEH
Jurisdiction: United States District Court, Central District of Illinois, Peoria Division
Date Settlement Filed with Court: January 12, 2021 1:19-cv-01330-MMM # 72 Page 19 of 52
January 22, 2021 Page 2
Defendants deny any wrongdoing or liability whatsoever but have decided to settle this Action solely in order to eliminate the burden, expense, and uncertainties of further litigation. In compliance with 28 U.S.C. § 1715(b), the following documents referenced below are included on the CD that is enclosed with this letter:
1. 28 U.S.C. § 1715(b)(1) – Complaint and Related Materials: The Complaint, First Amended Complaint, and Consolidated Second Amended Complaint are provided in electronic form on the enclosed CD as Exhibit A, A1, and A2, respectively.
2. 28 U.S.C. § 1715(b)(2) – Notice of Any Scheduled Judicial Hearing: On January 12, 2021 the Plaintiffs filed a Motion for Preliminary Approval with Defendants of the Class Action. The motion date has not been set. A Final Approval Hearing has not been set. A copy of the Plaintiffs’ Motion for Preliminary Approval of Class Action and Proposed Preliminary Approval are provided in the electronic form on the enclosed CD as Exhibit B and B1, respectively.
3. 28 U.S.C. § 1715(b)(3) – Notification to Class Members: A copy of the Long- Form Notice, Email Notice, Publication Notice, Postcard Notice, and Claim Form to be provided to the Class is provided on the enclosed CD as Exhibit C, C1, C2, C3, and C4, respectively.
4. 28 U.S.C. § 1715(b)(4) – Class Action Settlement Agreement: A copy of the Settlement Agreement is provided on the enclosed CD as Exhibit D.
5. 28 U.S.C. § 1715(b)(5) – Any Settlement or Other Agreement: As of January 22, 2021, there have not been any settlement or other agreements contemporaneously made between Class Counsel and Counsel for the Defendants.
6. 28 U.S.C. § 1715(b)(6) – Final Judgment: No Final Judgment has been reached as of January 22, 2021, nor have any Notices of Dismissal been granted at this time. A copy of the Proposed Final Order of Approval is provided on the enclosed CD as Exhibit E.
7. 28 U.S.C. § 1715(b)(7)(A)-(B) – Names of Class Members/Estimate of Class Members: A complete list of names of Class Members is not presently available. A list showing the estimated number of Class Members per state as well as a list of the specific locations and time frames affected during the Security Incident are provided on the enclosed CD as Exhibit F and F1, respectively.
8. 28 U.S.C. § 1715(b)(8) – Judicial Opinions Related to the Settlement: As of January 22, 2021, there have been no written judicial opinions related to the Settlement. 1:19-cv-01330-MMM # 72 Page 20 of 52
January 22, 2021 Page 3
If you have any questions about this Notice, the Action, or the enclosed materials, please contact the undersigned Counsel for Defendant listed below.
Yours very truly,
Paul G. Karlsgodt
Enclosures 1:19-cv-01330-MMM # 72 Page 21 of 52
Exhibit C 1:19-cv-01330-MMM # 72 Page 22 of 52
Exclusion First Name Last Name 1 DAVID BARNEY 2 ROBERT CHAPLIN 3 SARA COOK 4 SANDI COOPER 5 CHRISTINE CURTIS 6 JAMES DAVIS 7 ELIZABETH ENGLIN 8 APRIL HARTMAN 9 LINDA HILL 10 JAIRED HOIUM 11 JOSH JACOBSON 12 ALLISON JETER 13 BRIAN JETER 14 BRADLEY JOHNSON 15 DAN MALLINGER 16 BRIAN MCCART 17 DARRELL OLTMAN 18 DEMETRA PACE 19 BRENDAN PRENDERGAST 20 KATHERINE REXROAD 21 JOSH RIECK 22 KATRINKA SCHNABELHILGERT 23 DENISE SCHRADER 24 STEVE SHORT 25 MELISSA SMIDT 26 SHIRLEY STARK 27 DIANA THOMAS 28 NICK TRAMP 29 WILLIAM UHLER 30 MICHELLE VULGAMOTT 31 RYAN VULGAMOTT 32 ROBERT WASKO 33 MEGAN WHEELER 34 JULIE WITTROCK 1:19-cv-01330-MMM # 72 Page 23 of 52
Exhibit D 1:19-cv-01330-MMM # 72 Page 24 of 52
Display Banner Ad 1:19-cv-01330-MMM # 72 Page 25 of 52
Facebook/Instagram Ad
Mobile Desktop 1:19-cv-01330-MMM # 72 Page 26 of 52
Google Search Ad 1:19-cv-01330-MMM # 72 Page 27 of 52
Exhibit E 1:19-cv-01330-MMM # 72 Page 28 of 52
If you made a purchase at a Hy-Vee fuel pump, drive-thru coffee shop, or restaurant using a credit, debit, or other payment card, you may be eligible for a payment from a class action settlement.
English PR Newswire ID: 3073004-1 Clear Time Feb 23, 2021 9:17 AM ET
Pickup
61M 69
TOTAL POTENTIAL AUDIENCE TOTAL EXACT MATCHES
TOP EXACT MATCH PICKUP
MarketWatch 36M visitors/month [1]
PR Newswire 8M visitors/month [1]
Benzinga 8M visitors/month [1]
Morningstar 3M visitors/month [1]
WFMZ-TV IND-6... 1M visitors/month [1]
Marietta Dail... 609K visitors/month [1]
KTVN-TV CBS-2... 399K visitors/month [1]
WBOC-TV CBS-1... 340K visitors/month [1]
1st Discount ... 250K visitors/month [1]
Daily Local News 220K visitors/month [1]
Daily Journal... 219K visitors/month [1]
WICZ-TV FOX-4... 175K visitors/month [1]
KPVI-TV NBC-6 136K visitors/month [1]
Canadian Insider 109K visitors/month [1]
Suncoast News... 105K visitors/month [1]
*DATA SOURCES: [1] [2] ALEXA, [3] SITEWORTHTRAFFIC.COM [4] CISION DIGITAL REACH 1:19-cv-01330-MMM # 72 Page 29 of 52
*THE DATA CITED HERE BY SIMILARWEB REPRESENTS SITE TRAFFIC DATA OF WORLDWIDE UNIQUE VISITORS ON DESKTOP AND MOBILE DEVICES. DATA IS UPDATED
MONTHLY.
Views & Engagement
Views & Engagement data will continue to mature over time. Totals below are expected to have reached 98% maturity when the circles below are darker in color.
522 1 1,929 CLICK-THROUGHS SHARES RELEASE VIEWS
Distribution
1K
TOTAL AP OUTLETS DISTRIBUTED
TOP AP OUTLETS
C-SPAN 86M Visitors/Month Washington, DC
Scribd, Inc. 43M Visitors/Month San Francisco, CA
FoxNews.com 32M Visitors/Month New York, NY
CBS News Radio 30M Visitors/Month New York, NY
New York Time... 29M Visitors/Month New York, NY
Apple Inc. 29M Visitors/Month Cupertino, CA
CNBC.com 26M Visitors/Month Englewood Cliffs, NJ
CBSnews.com 26M Visitors/Month 1:19-cv-01330-MMM # 72 Page 30 of 52 New York, NY 1:19-cv-01330-MMM # 72 Page 31 of 52
Pickup
Overview
TOTAL PICKUP 69 TOTAL POTENTIAL 61M AUDIENCE
Exact Match 69 postings Exact Match 61M visitors
Total Pickup Over Time Total pickup since your content was distributed 100
10 t n u o C
p u k c i P
l a t o T 1
0 23 Feb 24 Feb 25 Feb 1:19-cv-01330-MMM # 72 Page 32 of 52
Total Pickup by Source Type Total Pickup by Industry
Newspaper (34/50.0%) Media & Information (51/73.9%) Online News Sites & Other Influencers (16/23.5%) Financial (10/14.5%) Broadcast Media (7/10.3%) Retail & Consumer (4/5.8%) Financial News Service (4/5.9%) Policy & Public Interest (2/2.9%) Trade Publications (2/2.9%) Business Services (1/1.4%) Other (5/7.4%) Other (1/1.4%)
Exact Match Pickup Exact matches are full text postings of your content which we have found in the online and social media that we monitor. Understand how it is calculated.
Total Exact Matches: 69 Total Potential Audience: 61,347,315
Logo Outlet Name Location Source Type Industry Potential Audience
MarketWatch United Online News Sites & Other Financial 36,364,389 [1] Online View Release States Influencers visitors/month
PR Newswire Global PR Newswire Media & Information 8,488,264 [1] Online View Release visitors/month
Benzinga United Online News Sites & Other Financial 8,276,975 [1] Online View Release States Influencers visitors/month
Morningstar Global Financial Data, Research & Financial 3,700,752 [1] Online View Release Analytics visitors/month
WFMZ-TV IND-69 [Allentown, PA] United Broadcast Media Media & Information 1,284,970 [1] Online View Release States visitors/month 1:19-cv-01330-MMM # 72 Page 33 of 52
WFMZ-TV IND-69 [Allentown, PA] United Broadcast Media Media & Information 1,284,970 [1] Online View Release States visitors/month
Marietta Daily Journal [Marietta, GA] United Newspaper Media & Information 609,057 [1] Online View Release States visitors/month
KTVN-TV CBS-2 [Reno, NV] United Broadcast Media Media & Information 399,304 [1] Online View Release States visitors/month
WBOC-TV CBS-16 [Salisbury, MD] United Broadcast Media Media & Information 340,829 [1] Online View Release States visitors/month
1st Discount Brokerage United Financial News Service Financial 250,855 [1] Online View Release States visitors/month
Daily Local News United Newspaper Media & Information 220,588 [1] Online View Release States visitors/month
Daily Journal [Tupelo, MS] United Newspaper Media & Information 219,784 [1] Online View Release States visitors/month
WICZ-TV FOX-40 [Binghamton, NY] United Broadcast Media Media & Information 175,475 [1] Online View Release States visitors/month
KPVI-TV NBC-6 United Broadcast Media Media & Information 136,426 [1] Online View Release States visitors/month
Canadian Insider Canada Financial News Service Financial 109,350 [1] Online View Release visitors/month
Suncoast News Network [Sarasota, FL] United Broadcast Media Media & Information 105,752 [1] Online View Release States visitors/month
The Courier Express [DuBois, PA] United Newspaper Media & Information 94,000 [1] Online View Release States visitors/month
WRDE-TV CBS [Milton, DE] United Broadcast Media Media & Information 80,570 [1] Online View Release States visitors/month
One News Page Global Edition Global Online News Sites & Other Media & Information 79,208 [1] Online View Release Influencers visitors/month 1:19-cv-01330-MMM # 72 Page 34 of 52
Daily American [Somerset, PA] United Newspaper Media & Information 72,123 [1] Online View Release States visitors/month
Tioga Publishing United Newspaper Media & Information 64,671 [1] Online View Release States visitors/month
Bradford Era United Newspaper Media & Information 46,755 [1] Online View Release States visitors/month
Montgomery Media United Newspaper Media & Information 37,957 [1] Online View Release States visitors/month
Mainline Media News United Newspaper Media & Information 35,520 [1] Online View Release States visitors/month
Bucks Local News United Newspaper Media & Information 35,131 [1] Online View Release States visitors/month
The Progress News [Clearfield, PA] United Newspaper Media & Information 24,202 [1] Online View Release States visitors/month
Daily Herald [Chicago, IL] United Newspaper Media & Information 18,756 [1] Online View Release States visitors/month
NewsBlaze US United Online News Sites & Other Media & Information 16,388 [1] Online View Release States Influencers visitors/month
Delaware County News Network United Newspaper Media & Information 9,831 [1] Online View Release States visitors/month
Magazines Today Global Trade Publications Media & Information 9,667 [1] Online View Release visitors/month
Ridgway Record [Ridgway, PA] United Newspaper Media & Information 4,589 [1] Online View Release States visitors/month
Ticker Technologies United Financial News Service Financial 4,542 [1] Online View Release States visitors/month
Oklahoman [Oklahoma City, OK] United Newspaper Media & Information 4,240 [1] Online View Release States visitors/month
Buffalo News [Buffalo, NY] United Newspaper Media & Information 3,270 [1] Online View Release States visitors/month 1:19-cv-01330-MMM # 72 Page 35 of 52
CNHI News United Newspaper Media & Information 3,084 [1] Online View Release States visitors/month
My Silly Little Gang United Blog-Parental Influencers Retail & Consumer 2,507 [1] Online View Release States visitors/month
myMotherLode.com [Sonora, CA] United Newspaper Media & Information 2,068 [1] Online View Release States visitors/month
The SPIRIT United Newspaper Media & Information 1,864 [1] Online View Release States visitors/month
ProfitQuotes United Financial News Service Financial 1,646 [1] Online View Release States visitors/month
One News Page United States Edition United Online News Sites & Other Media & Information 1,497 [1] Online View Release States Influencers visitors/month
Jotup Global Online News Sites & Other Business Services 954 [1] Online View Release Influencers visitors/month
Starkville Daily News [Starkville, MS] United Newspaper Media & Information 814 [1] Online View Release States visitors/month
Axcess News United Online News Sites & Other Media & Information 794 [1] Online View Release States Influencers visitors/month
Latin Business Today United Online News Sites & Other Multicultural & 783 [1] Online View Release States Influencers Demographic visitors/month
SOGOTRADE United News & Information Service Financial 727 [1] Online View Release States visitors/month
Forefront Media News United Online News Sites & Other Media & Information 644 [1] Online View Release States Influencers visitors/month
Winslow, Evans & Crocker United Online News Sites & Other Financial 633 [1] Online View Release States Influencers visitors/month
Valley City Times-Record [Valley City, United Newspaper Media & Information 555 [1] ND] States visitors/month Online View Release
The Kane Republican [Kane, PA] United Newspaper Media & Information 476 [1] Online View Release States visitors/month 1:19-cv-01330-MMM # 72 Page 36 of 52
Malvern Daily Record [Malvern, AR] United Newspaper Media & Information 472 [1] Online View Release States visitors/month
The Luxury Chronicle India Online News Sites & Other Retail & Consumer 412 [1] Online View Release Influencers visitors/month
The Punxsutawney Spirit [Punxsutawney, United Newspaper Media & Information 383 [1] PA] States visitors/month Online View Release
Daily Times Leader [West Point, MS] United Newspaper Media & Information 357 [1] Online View Release States visitors/month
The Pilot News [Plymouth, IN] United Newspaper Media & Information 350 [1] Online View Release States visitors/month
The Evening Leader [St. Marys, OH] United Newspaper Media & Information 323 [1] Online View Release States visitors/month
Fat Pitch Financials United Online News Sites & Other Financial 300 [1] Online View Release States Influencers visitors/month
Sweetwater Reporter [Sweetwater, TX] United Newspaper Media & Information 251 [1] Online View Release States visitors/month
Inyo Register [Bishop, CA] United Newspaper Media & Information 230 [1] Online View Release States visitors/month
Mammoth Times [Mammoth Lakes, CA] United Newspaper Media & Information 205 [1] Online View Release States visitors/month
The Newport Daily Express [Newport, VT] United Newspaper Media & Information 199 [1] Online View Release States visitors/month
Tactics Magazine for Shopping Centers Canada Trade Publications Retail & Consumer 144 [1] Online View Release visitors/month
1stCounsel United Online News Sites & Other Policy & Public 88 [1] Online View Release States Influencers Interest visitors/month
360WiseMedia United Online News Sites & Other Media & Information 62 [1] Online View Release States Influencers visitors/month 1:19-cv-01330-MMM # 72 Page 37 of 52
Mystery Shopping Teacher United Blog Retail & Consumer 62 [1] Online View Release States visitors/month
Manhattanweek United Online News Sites & Other Media & Information 62 [1] Online View Release States Influencers visitors/month
Poteau Daily News [Poteau, OK] United Newspaper Media & Information 62 [1] Online View Release States visitors/month
Decatur Daily Democrat [Decatur, IN] United Newspaper Media & Information 62 [1] Online View Release States visitors/month
The Antlers American [Antlers, OK] United Newspaper Media & Information 55 [1] Online View Release States visitors/month
Canadian Journalism Forum on Violence Canada Online News Sites & Other Policy & Public Not Available and Trauma Influencers Interest Online View Release
*Data sources: [2] Alexa, [3] siteworthtraffic.com [4] Cision Digital [1] Reach *The data cited here by SimilarWeb represents site traffic data of worldwide unique visitors on desktop and mobile devices. Data is updated monthly. 1:19-cv-01330-MMM # 72 Page 38 of 52
Traffic
Overview
RELEASE VIEWS & HITS 2K MULTIMEDIA 0
Release Views 1K
Media Views 67
Public Views 1K Partner Sites 468
PR Newswire Properties 1K
Release Web Crawler Hits 498
Release Views Release Views Over Time
10000
1 079 1:19-cv-01330-MMM # 72 Page 39 of 52 1 079 1000
159
s 95
w 100 62 63 e i 5042
V 37
e
s 17 a 1314 1215 12 e l 9 e 8 8 10 7 7 6 7 7 6 R 5 5 4 4 4 4 4 3 3 3 3 2 2 2 1 1 1 1
0 r r r r r r r r r r r r r r r r r b b b p p a a a a a a a a a a a a a a a e e e A A M M M M M M F M M M M M F M F M M M
1 3 1 1 2 3 4 4 3 5 6 6 8 8 5 7 7 9 0 0 0 0 0 1 2 0 1 2 2 0 1 2 1 2 2 0 2 0 2 3
Cumulative Media Views Partner Sites PRN Properties
Media Views on PR Newswire for Journalists Top 10 Outlets
Law360 (Portfolio 1 Media) (1) PA Media Group 1 (1) Philadelphia Business Journal 1 (1) NBC News (1) 1
KrazzyMag (1) 1
CNN (1) 1
Elsevier Ltd (1) 1
Cision (PR 1 Newswire) (1)
N/A (1) 1
ABC (1) 1
0 1 2 Views
Views on Partner Sites 1:19-cv-01330-MMM # 72 Page 40 of 52 Top 10 Sites
WFMZ-TV IND-… 157
Tioga Publishing 50 (50)
Benzinga Pro (48) 48
Daily Local News 13 (13)
Bradford Era (12) 12 The Courier Express [DuBois, 9 PA] (9) Google Mail (9) 9
Winslow, Evans & 8 Crocker (8)
Morningstar (8) 8
Opoint Media 7 Intelligence (7) 0 50 100 150 200 Views
Traffic to PR Newswire Properties
Type of Views Views
Type Views
Desktop Views 1,231
Mobile/Tablet Views 163
Total Views on PR Newswire Properties 1,394
Desktop Views Mobile/Tablet Views
External Traffic Sources Understand how viewers found your release.
Source Type Source Instances
Direct 895
Direct Direct 895
Search Engine (6) 358
Total 1,394 1:19-cv-01330-MMM # 72 Page 41 of 52
Source Type Source Instances
Search Engine Google 282
Search Engine Bing 46
Search Engine Yahoo! 17
Search Engine DuckDuckGo 10
Search Engine AOL 2
Search Engine Baidu 1
Social Media (1) 1 Direct Search Engine Social Media Social Media Twitter 1 PR Newswire Properties Other Sites PR Newswire Properties (2) 128
PR Newswire Properties prnewswire.com 127
PR Newswire Properties prnewswire.co.uk 1
Other Sites (7) 12
Other Sites r20.rs6.net 4
Other Sites search.myway.com 2
Other Sites mma.prnewswire.com 2
Other Sites searchatlas.centrum.cz 1
Other Sites app.asana.com 1
Other Sites feeder.co 1
Other Sites menafn.com 1
Total 1,394 1:19-cv-01330-MMM # 72 Page 42 of 52
Audience
Overview
VIEWS FROM IDENTIFIED AP & INFLUENCER LIST RECIPIENTS 1K AUDIENCES 92 Wire Distribution / AP Outlets 1K
Media Views 67
Organization Views 25
Audience Summary
Media Demographics A break down of the industries covered, the media types and the locations of the journalists & bloggers accessing your release on PR Newswire for Journalists.
Top Industries Top Media Types Top Locations
30 30
25 25
20 20
15 15
10 10
5 5
0
0 r r s n e l e e r c o s s a y i a i g t i p e s v g c s c g d i a i r h e o t u o v e l d p e l n i d s e o o O l S i B M s o
n r w e r u e h e e T P n c B
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N
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e United States L e e a - T r d n India Canada m e a u O r n /
s United Kingdom T e b n e G
o Israel The rest W C
Geo-segmentation 1:19-cv-01330-MMM # 72 Page 43 of 52 See where views of your release originated. Hover over map to see totals by location. Select a region: World View
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000 1:19-cv-01330-MMM # 72 Page 44 of 52
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000 1:19-cv-01330-MMM # 72 Page 45 of 52
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000
> 0 1 - 10 10 - 30 30 - 100 100 - 300 300 - 1 000 > 1 000
Audience Details Media Views See the details of each media outlet from PR Newswire for Journalists that viewed your release.
Outlet Industry Source Type Location Views
Law360 (Portfolio Energy Web/On-Line Service United States 1 Media)
Total 67 1:19-cv-01330-MMM # 72 Page 46 of 52
PA Media Group General Business Newspaper United States 1
Philadelphia Consumer Products, Energy, Financial Services, Newspaper United States 1 Business Journal General Business, Healthcare, Media, Other, Sports, Technology, Transportation, Travel
NBC News Auto, Consumer Products, Financial Services, Television, Web/On-Line Service United States 1 General Business, Media, Other, Public Issues, Technology
KrazzyMag Auto, Entertainment, Environment, Financial Blogger, Other, Web/On-Line India 1 Services, General Business, Healthcare, Media, Service Public Issues, Sports, Technology, Travel
CNN Consumer Products, Environment, General Business Web/On-Line Service United States 1
Elsevier Ltd Environment, Heavy Industry, Other Trade Periodicals, Web/On-Line United Kingdom 1 Service
Cision (PR Auto, Broadcast, Consumer Products, Energy, Blogger, Consumer Periodicals, United States 1 Newswire) Entertainment, Environment, Features, Financial Freelance/Writer, Newspaper, Services, General Business, Healthcare, Heavy Other, Radio, Television, Trade Industry, Media, Other, Public Issues, Sports, Periodicals, Web/On-Line Service, Technology, Transportation, Travel Wire Service
N/A Auto, Broadcast, Consumer Products, Energy, Newspaper, Web/On-Line Service Israel 1 Entertainment, Environment, Features, Financial Services, General Business, Healthcare, Heavy Industry, Media, Other, Public Issues, Sports, Technology, Transportation, Travel
ABC Auto, Broadcast, Consumer Products, Energy, Television United States 1 Entertainment, Environment, Features, Financial Services, General Business, Healthcare, Heavy Industry, Media, Other, Public Issues, Sports, Technology, Transportation, Travel
PR Newswire Sports Web/On-Line Service, Wire Service United States 1 cision Auto Blogger United States 1
FreshOut.Today Auto, Consumer Products, Entertainment, Features, Web/On-Line Service Vietnam 1 Healthcare, Technology
Delion Environment, Financial Services, General Business, Blogger, Newspaper Canada 1 Other, Technology
Yahoo Canada Broadcast, Consumer Products, Entertainment, Web/On-Line Service Canada 1 Environment, Features, General Business, Healthcare, Heavy Industry, Media, Public Issues, Technology, Travel
Auburn Wire Sports Freelance/Writer, Web/On-Line United States 1 Service
National Other Newspaper United States 1 Observer
Accion Labs Broadcast, Consumer Products, Energy Newspaper, Radio India 1
Times of News Healthcare Blogger, Other, Web/On-Line India 1 24x7 Service
Total 67 1:19-cv-01330-MMM # 72 Page 47 of 52
NewsRise Auto, Broadcast, Consumer Products, Energy, Freelance/Writer, Newspaper, Malaysia 1 Entertainment, Environment, Features, Financial Radio, Wire Service Services, General Business, Healthcare, Heavy Industry, Media, Other, Public Issues, Sports, Technology, Transportation, Travel
Goodnet Consumer Products, Energy, Environment, Newspaper Israel 1 Healthcare, Technology, Transportation, Travel mmirandalaurenn Consumer Products, Entertainment, Media, Other Blogger United States 1
WRHU Broadcast, Entertainment, General Business, Radio, Television United States 1 Healthcare, Media, Public Issues
Business Digest General Business Consumer Periodicals United Kingdom 1 Magazine
NBCUniversal Consumer Products, Media Television, Web/On-Line Service United States 1
The Citizens' Auto, Broadcast, Consumer Products, Energy, Newspaper United States 1 Voice Entertainment, Environment, Features, Financial Services, General Business, Healthcare, Heavy Industry, Media, Other, Public Issues, Sports, Technology, Transportation, Travel
Sustaina Stocks Financial Services, General Business Web/On-Line Service Denmark 1
Pennsylvania Bar Other Other United States 1 Institute
NTD News Broadcast Television United States 1
Business Insider Financial Services, Technology Newspaper United States 1
Les Affaires Financial Services, General Business Newspaper Canada 1
Design World Technology Freelance/Writer, Trade Periodicals United States 1
Winsight Auto, Consumer Products, Technology Trade Periodicals United States 1
MMP USA Consumer Products, Financial Services, Healthcare, Television United States 1 Technology
Kingsport Times- Other Newspaper United States 1 New
Economic Auto, Energy, Features, Financial Services, Media, Freelance/Writer, Newspaper, Pakistan 1 Review Public Issues, Sports Trade Periodicals
SNL Energy Energy Trade Periodicals United States 1
Randall-Reilly Transportation Trade Periodicals United States 1 Publishing Co.
Freelancer Entertainment, Features, Healthcare Freelance/Writer, Newspaper United States 1
News Aktuell Other Wire Service Switzerland 1
Houston Features Newspaper United States 1 Chronicle heart & soul Entertainment, Healthcare, Travel Consumer Periodicals, Radio, United States 1 Web/On-Line Service
Total 67 1:19-cv-01330-MMM # 72 Page 48 of 52
PR Technology Other Malaysia 1
WSAZ Financial Services Television United States 1
Courthouse Other Consumer Periodicals, Trade United States 1 News Periodicals
Pittsburgh Broadcast, Consumer Products, Energy, Newspaper United States 1 Business Times Entertainment, Features, Financial Services, Healthcare, Media, Public Issues, Sports, Technology, Transportation, Travel
New York 1 Other Television United States 1 News
Freelancer Other Trade Periodicals United States 1
Feather River Other Newspaper United States 1 Bulletin
Coelum Other Consumer Periodicals, Web/On- Italy 1 Line Service
Okinawa Marine Broadcast, Environment, Features, Financial Freelance/Writer, Newspaper, Japan 1 Services, Media, Public Issues, Technology, Web/On-Line Service, Wire Service Transportation, Travel
NewsRx Auto, Broadcast, Consumer Products, Energy, Web/On-Line Service United States 1 Entertainment, Environment, Features, Financial Services, General Business, Healthcare, Heavy Industry, Media, Other, Public Issues, Sports, Technology, Transportation, Travel
The Legal General Business Newspaper United States 1 Intelligencer
Retail Gazette Auto, Broadcast, Consumer Products, Energy, Blogger, Consumer Periodicals, United Kingdom 1 Entertainment, Environment, Features, Financial Freelance/Writer, Newspaper, Services, General Business, Healthcare, Heavy Other, Radio, Television, Trade Industry, Media, Other, Public Issues, Sports, Periodicals, Web/On-Line Service, Technology, Transportation, Travel Wire Service
Cognizant Auto, General Business Blogger, Freelance/Writer India 1
Main Line Today Entertainment, Features, Healthcare, Media, Public Other, Web/On-Line Service United States 1 Issues, Sports, Technology
Food Dive Consumer Products Trade Periodicals United States 1
Retail Leader Media Trade Periodicals United States 1
Book And Coffee Other Blogger United States 1 Addict Blog
Daily News Other Other South Africa 1
The Kyle & Broadcast, Consumer Products, Entertainment, Radio Australia 1 Jackie O Show Features, Media, Other, Public Issues, Technology
Gaceta UNAM Environment, Features, Healthcare, Media, Public Newspaper, Web/On-Line Service Mexico 1 Issues, Sports, Travel
Total 67 1:19-cv-01330-MMM # 72 Page 49 of 52
Sing Tao Daily Other Newspaper Canada 1 Toronto Edition 多伦多星岛
Bloomberg News Other Wire Service Netherlands 1
NRIT media Auto, Consumer Products, Entertainment, Sports, Trade Periodicals, Web/On-Line Netherlands 1 Technology, Travel Service
Pittsburgh Post Energy, Environment, Transportation Newspaper, Web/On-Line Service United States 1 Gazette
Slice Other Other New Zealand 1 Publications Ltd
Total 67
Organization Views See which organizations have viewed your release
Visitor
Organization Headquarters Location Parent Organization Industry Views
HY-VEE, INC 5820 WESTOWN PKWY , United States UNITED Hy-Vee Inc Retail 3 STATES
Nutrien 122 1 Ave S Suite 500 , Canada UNITED Nutrien Ltd Manufacturing 3 STATES
American Family Insurance 6000 American Parkway , United States UNITED American Family Insurance Group Insurance 2 STATES
Spencer Hospital LLC 1200 First Avenue East , United States UNITED Spencer Hospital LLC Travel, Recreation, and 2 STATES Leisure
LEAR WERTS LLP 2003 W BROADWAY , United States UNITED Lear Werts LLP Law Firms & Legal 2 STATES Services
Rockwell Collins, Inc. 400 Collins Rd N.E. , United States UNITED Rockwell Collins Inc Manufacturing 2 STATES
PDC CONSTRUCTION 1612 PIERCE ST , United States UNITED PDC CONSTRUCTION INC Real Estate & 2 STATES Construction
Anthem Blue Cross Blue Shield 120 Monument Circle , United States UNITED Anthem , Inc. Insurance 2 STATES
Chippewa Valley Technical 620 West Clairemont Ave. , United States UNITED Chippewa Valley Technical College Education 2 College STATES
QCR Holdings INC. 4500 North Brady Street , United States UNITED QCR HOLDINGS INC Financial Services 1 STATES
SOUTH DAKOTA SOYBEAN 5000 S BROADBAND LN STE STE 100 , UNITED SOUTH DAKOTA SOYBEAN 1 ASSOCIATION United States STATES ASSOCIATION
Principal Financial Group IS Network Administration 711 High Street , UNITED The Principal Financial Group 1 United States STATES
DERMATOLOGY ASSOCIATES 1720 S BECKHAM AVE , United States UNITED 1 STATES
Augustana University 2001 S. Summit , United States UNITED 1 STATES
Total 25 1:19-cv-01330-MMM # 72 Page 50 of 52 Associated Press Outlets Every PR Newswire U.S. wire newsline includes targeted distribution to the Associated Press, an essential global news network that delivers content to an extensive set of media platforms and formats. The list below represents the outlets you reach via this partnership.
Outlet Name City State Newsline Type Audience
C-SPAN Washington DC US1 Television 86,200,000 Subscribers
Scribd, Inc. San Francisco CA US1 Aggregator 43,531,670 Visitors per Month
FoxNews.com New York NY US1 Online 32,516,438 Visitors per Month
CBS News Radio New York NY US1 Radio 30,000,000 Broadcast Audience
New York Times Digital New York NY US1 Newspaper 29,886,442 Visitors per Month
Apple Inc. Cupertino CA US1 Organization/Company 29,709,459 Visitors per Month
CNBC.com Englewood Cliffs NJ US1 Online 26,089,260 Visitors per Month
CBSnews.com New York NY US1 Online 26,080,671 Visitors per Month
abcnews.com New York NY US1 Online 24,167,779 Visitors per Month
U.S. News & World Report Washington DC US1 Magazine 23,945,529 Visitors per Month 1:19-cv-01330-MMM # 72 Page 51 of 52
Engagement
Overview
TOTAL ENGAGEMENT ACTIONS 523
Click-throughs 522
Shares 1
Engagement Timeline See when your audience engaged with your release. 1000
100 61 59 40 45 28 26 29 16 12 10 10 8 7 7 8 7 6 6 6 5 5 5 5 6 5 4 4 4 4 4 4 4 3 3 3 3 3 3 61 59 2 2 2 2 2 2 2 2 2 2 2 2 28 1 2 1 1 1 1 1 1 1 1 1 1 16 12 1 8 10 8 6 6 7 7 5 7 5 5 5 6 5 4 4 4 4 4 4 3 3 4 3 3 3 2 2 2 2 2 2 2 2 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1
0 7 6 7 3 3 2 5 1 9 2 0 1 2 2 1 2 0 0 1 0 ------3 4 3 2 3 4 4 3 3 5 0 0 0 0 0 0 0 0 0 0 ------1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2 2 0 0 0 0 0 0 0 0 0 0 2 2 2 2 2 2 2 2 2 2
Cumulative Click-throughs Shares Downloads Web Conversions
Engagement Details A break down of click-throughs, shares and other engagement actions. Click-throughs The number of times your release sent visitors to the pages you linked to
URL Click-throughs
http://www.grocerysecurityincidentsettlement.com/ 522
Total 522 1:19-cv-01330-MMM # 72 Page 52 of 52
Shares A breakdown of the types of sharing your release generated.
Type of share Shares
tweet 1
Total Shares 1
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