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Paul B. Maslo (admitted pro hac)

Andrew J. Dressel (admitted pro hac)

NAPOLI SHKOLNIK PLLC 

360 Lexington Avenue, 11th Floor 

New York, New York 10017 

Telephone: (212) 397-1000 

Fax: (646) 843-7603

Email: pmaslo@napolilaw.com

 adressel@napolilaw.com

Counsel for Plaintiffs

RANDALL W. EDWARDS (S.B. #179053)

redwards@omm.com

MATTHEW D. POWERS (S.B. #212682)

mpowers@omm.com 

DAMALI A. TAYLOR (S.B. #262489)

dtaylor@omm.com

ADAM M. KAPLAN (S.B. #298077)

akaplan@omm.com 

O’MELVENY & MYERS LLP

Two Embarcadero Center, 28th Floor

San Francisco, California 94111-3823

Telephone: (415) 984-8700

Facsimile: (415) 984-8701

Counsel for Defendants

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

MARTIN DULBERG, individually, and on 

behalf of all others similarly-situated,

Plaintiff,

v.

UBER TECHNOLOGIES, INC., and

RASIER, LLC,

Defendants.

Case No. 3:17-cv-00850-WHA

JOINT PROPOSAL FOR DISTRIBUTION 

OF CLASS NOTICE

Judge: The Honorable William H. Alsup
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Pursuant to the Court’s Order granting class certification [Dkt. No. 80], Plaintiff Martin Dulberg 

and Defendants Uber Technologies, Inc. and Rasier, LLC (collectively, “Uber”) submit this joint 

proposal for distribution of class notice.

Notice Plan: Within 10 days of the Court’s Order approving the parties’ notice proposal, Uber 

shall produce the Class List (defined below) to the Class Administrator (defined below). The Class

Administrator will send notice, substantially similar to that attached as Exhibit A, by e-mail to the

class members’ e-mail addresses currently on file with Uber by approximately March 22, 2018. The 

Class Administrator shall follow-up on any e-mails that are returned as undelivered in an effort to

locate those class members whose e-mail addresses have changed or have otherwise been disabled.

The parties agree to cooperate in good faith to make reasonable efforts to locate class members for 

whom notice is returned as undeliverable.

Class List: To facilitate distribution of notice, Uber shall provide, on a confidential basis, a list

containing class members’ names and e-mail addresses to the Class Administrator. Uber declines at

this juncture to provide Plaintiff’s counsel with class members’ contact information.

Class Members: Notice will be sent to the 4,594 individuals identified in Exhibit B. These 

individuals are members of the following defined class:

All persons nationwide who (1) drove for UberX or Uber Select; (2) opted out of arbitration; 

(3) transported a passenger who was charged an upfront Fare before May 22, 2017, when 

Uber issued its updated fee addendum; and (4) made less money overall on rides where they 

transported passengers who were charged an upfront Fare because they were paid on a Fare 

calculated based on actual time and distance values instead of the upfront Fare calculated 

based on estimated time and distance values.

Opt-Out: Class members may opt-out of the class by mailing a signed written request for

exclusion, as detailed in the proposed notice attached as Exhibit A, to the Class Administrator within 

30 days from the date the notice is e-mailed to them.

Class Administrator: Angeion Group, 1801 Market Street, Suite 660, Philadelphia, PA 19103, 

shall serve as the Class Administrator. Dulberg shall pay the Class Administrator’s costs for 

distribution of notice.
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DATED: March 1, 2018 

Respectfully submitted,

/s/ Paul B. Maslo

Paul B. Maslo (admitted pro hac)

Andrew J. Dressel (admitted pro hac)

NAPOLI SHKOLNIK PLLC 

360 Lexington Avenue, 11th Floor 

New York, New York 10017 

Telephone: (212) 397-1000 

Fax: (646) 843-7603

Email: pmaslo@napolilaw.com

 adressel@napolilaw.com

Counsel for Plaintiffs

Respectfully submitted,

/s/ Randall W. Edwards

RANDALL W. EDWARDS (S.B. #179053)

redwards@omm.com

MATTHEW D. POWERS (S.B. #212682)

mpowers@omm.com 

DAMALI A. TAYLOR (S.B. #262489)

dtaylor@omm.com

ADAM M. KAPLAN (S.B. #298077)

akaplan@omm.com 

O’MELVENY & MYERS LLP

Two Embarcadero Center, 28th Floor

San Francisco, California 94111-3823

Telephone: (415) 984-8700

Facsimile: (415) 984-8701

Counsel for Defendants
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CERTIFICATE OF SERVICE

The undersigned attorney certifies that on March 1, 2018, he electronically filed a copy of the 

attached via the CM/ECF filing system, which sent notification of such filing to all Filing Users.

/s/ Paul B. Maslo