WELCOME TO THE ALPHABET SECURITIES SETTLEMENT WEBSITE

The purpose of this website is to inform you of the pendency of this class action (the “Action”) between Lead Plaintiff State of Rhode Island, Office of the Rhode Island Treasurer on behalf of the Employees’ Retirement System of Rhode Island (“Rhode Island” or “Lead Plaintiff”) and Defendants Alphabet, Inc., Google LLC, Lawrence E. Page, Sundar Pichai, Keith P. Enright, and John Kent Walker, Jr., and the proposed $350,000,000.00 settlement reached therein (the “Settlement”) and of the hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement as well as counsel’s application for fees and expenses. This website and Notice of Pendency and Proposed Settlement of Class Action (“Notice”) describes what steps you may take in relation to the Settlement and this class action.

WHAT IS THIS LAWSUIT ABOUT

On October 11, 2018, an initial complaint in the Action was filed in the United States District Court for the Northern District of California and a substantially similar complaint was filed in the United States District Court for the Eastern District of New York, Khaled El Mawardy v. Alphabet, Inc., et al., No. 1:18-cv-05704 (E.D.N.Y.). On November 7, 2018, the El Mawardy case was transferred to the Northern District of California.

On January 25, 2019, Judge Jeffrey S. White consolidated the two related cases, appointed Rhode Island as Lead Plaintiff, and approved Rhode Island’s selection of Robbins Geller Rudman & Dowd LLP as Lead Counsel.

On April 26, 2019, Lead Plaintiff filed the Consolidated Amended Complaint for Violation of the Federal Securities Laws, alleging violations of §§10(b) and 20(a) of the Securities Exchange Act of 1934 (“1934 Act”) and Rule 10b-5 promulgated thereunder against Defendants (the “Complaint”).

On June 21, 2022, against the backdrop of contentious discovery disputes and disagreements between the Parties regarding the scope of the Action, Rhode Island moved for class certification. Shortly thereafter, the Parties engaged the services of the Hon. Layn R. Phillips (Ret.), a nationally recognized mediator, to facilitate settlement negotiations. On August 5, 2022, the Parties engaged in an in-person mediation session. The mediation session was preceded by submission of mediation statements and exhibits by each party. The Parties engaged in arm’s-length negotiations during the mediation session, but did not reach an agreement at that mediation.

The Parties continued their settlement discussion through the Mediator following their initial mediation session, without success. On October 20, 2023, however, the Parties accepted the Mediator’s proposal to resolve the Action. The agreement included, among other things, the Settling Parties’ agreement to settle and release all claims that were asserted or could have been asserted in the Action in return for a cash payment of $350,000,000.00 to be paid by Alphabet on behalf of Defendants, for the benefit of the Settlement Class, subject to the negotiation of the terms of a Stipulation of Settlement and approval by the Court. The Stipulation (together with the Exhibits thereto) reflects the final and binding agreement between the Settling Parties.

Defendants deny each and all of the claims and contentions of wrongdoing alleged by Lead Plaintiff in the Action. They have expressly denied and continue to deny that they have violated the federal securities laws or any other laws, or have otherwise misled investors as alleged in the Action. Defendants have denied and continue to deny the allegations that any of the Defendants made any material misstatements or omissions or engaged in any fraudulent scheme, and that any member of the Settlement Class has suffered damages resulting from the conduct alleged in the Action. In addition, Defendants maintain that they have meritorious defenses to the claims alleged in the Action.

ADDITIONAL INFORMATION

Although the information in this website is intended to assist you, it does not replace the information contained in the Notice and Stipulation, both of which can be found and downloaded by clicking on the Case Documents tab above. We recommend that you read the Notice and other relevant case documents carefully. You may also wish to read the answers to Frequently Asked Questions provided on this website.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

IMPORTANT DATES AND DEADLINES