UNITED STATES DISTRICT COURT WESTERN DISTRICT ......• Facebook data was sent in one excel file containing 35,544 records. The data file contained Hashed Ids, email addresses, and

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DECLARATION OF BRIAN SMITHEMAN, IN SUPPORT OF FINAL APPROVAL

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

AT SEATTLE

SEAN WILSON, individually and on behalf of all other persons similarly situated, Plaintiff, v. PLAYTIKA, LTD., an Israeli limited company, and CAESARS INTERACTIVE ENTERTAINMENT, LLC., a Delaware limited liability company. Defendants.

Case No. 18-CV-05277

DECLARATION OF BRIAN SMITHEMAN OF HEFFLER CLAIMS GROUP, IN SUPPORT OF FINAL APPROVAL

I, Brian Smitheman, declare as follows:

1. I am Client Services Manager for Heffler Claims Group (“Heffler”) in

Philadelphia, Pennsylvania. I am over twenty-one years of age and am authorized to

make this declaration on behalf of Heffler and myself. The following statements are

based on my personal knowledge and information provided by other experienced

Heffler employees working under my supervision. This declaration is being filed in

support of final approval.

2. Heffler has extensive experience in class action matters, having provided

services in class action settlements involving antitrust, securities fraud, employment

Case 3:18-cv-05277-RSL Document 150 Filed 12/14/20 Page 1 of 25

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DECLARATION OF BRIAN SMITHEMAN ISO FINAL APPROVAL

and labor, consumer, and government enforcement matters. Heffler has provided

notification and/or claims administration services in more than 2,500 cases.

3. Heffler was appointed as the Settlement Administrator to provide

notification and claims administration services in the Sean Wilson v. Playtika, LTD, et

al., No. 18-cv-05277 referred to herein as the “Settlement.” Heffler’s duties in this

Settlement have and will include: (a) preparing and sending CAFA notice; (b) receiving

and analyzing the Class Member data (“the Class List”) from various sources; (c)

establishing a post office box for the receipt of general mail and correspondence; (d)

creating a website with online claim filing capabilities; (e) establishing a toll-free

number with an Interactive Voice Response (IVR) system and live operators; (f)

preparing and sending email and Postcard Notice; (g) receiving and processing mail

from the United States Postal Service (“USPS”) with forwarding addresses; (h)

receiving and processing undeliverable mail from the USPS; (i) receiving and

processing opt-outs and objections; (j) receiving and processing claim forms; and (k)

such other tasks as counsel for the Parties or the Court orders Heffler to perform.

4. On behalf of the Defendant, Heffler provided notice of the proposed

settlement reflected in the Settlement Agreement pursuant to the Class Action Fairness

Act 28 U.S.C. §1715(b) (“the CAFA Notice”). At Defense Counsel’s direction, Heffler

sent the CAFA Notice, attached hereto as Exhibit A, and an accompanying CD

containing the documents required under 28 U.S.C. §1715(b)(1)-(8) to the Attorney


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General of the United States and the Washington state Attorney General identified in

the Manifest for the CAFA Notice via First-Class Certified Mail, on August 13, 2020.

5. Heffler received a data files from six various sources: Apple, Microsoft,

Google, Facebook, Playtika and Amazon. In preparation for the Postcard Notice

mailings Heffler did a search for names and addresses using the email addresses

provided from the respective lists below. In addition, Heffler ran the mailing data files

through a postal standardization process prior to mailing.

• Apple data was sent in four text files and one excel summary file

containing 4,058 records. Heffler undertook several steps to reconcile the

four lists and compile the eventual Potential Class Member List for the

email and mailing of notices. The data file contained Person Ids, names,

addresses, email addresses, and transaction amounts. Heffler combined

four text files into one file containing 2,473,460 records with multiple

transactions per Person Id. Heffler performed an analysis of the data and

determined that of 2,473,460 records, 73,169 records were unique. Of

73,169 records, 21,334 records had total spent amount of over $100.

• Microsoft data was sent in one Excel file containing 4,047 records. The

data file contained PUIDs, names, addresses, email addresses. Heffler

performed an analysis of the data and determined 4,018 records were

unique. Of 4,018 records, 4,018 records had total spent amount of over

$100.


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• Google data was sent in two excel files. First file contained 1,048,575

records. The data file contained Order Ids, email addresses, and

transaction amounts. Second file contained 17,350 records. The data file

contained names, addresses, email addresses, and transaction amounts.

Heffler performed an analysis of the data and determined 64,836 records

were unique. Of 64,836 records, 17,411 records had total spent amount of

over $100.

• Facebook data was sent in one excel file containing 35,544 records. The

data file contained Hashed Ids, email addresses, and transaction amounts.

Heffler performed an analysis of the data and determined 35,138 records

were unique. Of 35,138 records, 12,046 records had total spent amount of

over $100.

• Playtika Data was sent in one excel file containing 166,892 records. The

data file contained User Ids, names, email addresses, and transaction

amounts. Heffler performed an analysis of the data and determined

118,151 records were unique. Of 118,151 records, 31,821 records had

total spent amount of over $100.

• Amazon data was sent in five excel files. Four data files contained

Customer Ids, email addresses and transaction amounts for 3,216 records.

Fifth data file contained PUIDs, names, addresses, email addresses for 188

records. Heffler performed an analysis of the data and determined of 3,404


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records, 2,636 were unique. Of 2,636 records, 74 records had total spent

amount of over $100.

6. On September 16, 2020, Heffler obtained a post office box with the

mailing address Wilson v Playtika, LTD c/o Settlement Administrator, P.O. Box 190,

Warminster, PA 18974-0190 for the receipt of requests for exclusion, Claim Forms and

correspondence from Class Members.

7. On September 3, 2020, Heffler created and is currently hosting a dedicated

website entitled www.playtikasettlement.com. The website went live on September 8,

2020. The website contains a summary of the Settlement, frequently asked questions,

the Complaint, the Settlement Agreement, the Plan of Allocation, the Preliminary

Approval Order, the Order Continuing Settlement Deadlines, the Claim Form, the Long

Form Notice, information on the claim filing/exclusion/objection deadlines and allows

Class Members the opportunity to file a Claim Form online.

8. On September 15, 2020, Heffler established and is still maintaining a toll-

free number, 1-844-412-1946, for Class Members to call and obtain additional

information regarding the Settlement using both Live Operators and an IVR system.

As of December 10, 2020, 450 Class Members have called the IVR, and 215 Class

Members have called to speak to Live Operators.

9. On or about August 11, 2020, Heffler received Word versions of the Long

Form Notice, Postcard Notice, Email Notice, and Claim Form from counsel. Heffler

prepared and formatted drafts of the materials that counsel reviewed and approved.


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True and correct copies of the Long Form Notice, Postcard Notice, Email Notice and

Claim Form are attached hereto as Exhibit B.

10. The Notice program consisted of email notices to all records with an email

address on file, followed by postcard notices to Class Members who had a total spent

of $100 or more or to Class Members whose email notice bounced. The details of the

notice campaign for the respective data sets is as follows:

• Apple Data: Heffler has emailed 73,169 Notices to known email

addresses. Following the email notice Heffler has mailed 21,320 Postcard

Notices to those with a spend of $100 or more and 16,630 Postcard

Notices were mailed to email bounces.

• Microsoft Data: Heffler has emailed 4,047 Notices to known email


Notices to those with a spend of $100 or more.

• Google Data: Heffler has emailed 64,836 Notices to known email


Notices to those with the spend of $100 or more.

• Facebook Data: Heffler has emailed 49,214 Notices to known email




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• Playtika Data: Heffler has emailed 100,240 Notices to known email



• Amazon Data: Heffler has emailed 2,636 Notices to known email

addresses. Following the email notice Heffler has mailed 74 Postcard


11. The Notice program commenced on November 9, 2020. In total 294,142

emails were sent that affected 279,929 records, and 70,076 notices were mailed.

12. Of 294,142 emails sent, 73,536 emails bounced that affected 68,845

records. Of 68,845 records affected, 32,241 were notified via mail. Bounced emails

with a spend of $100 or more were sent through a reverse email address lookup process

to obtain names and mailing address.

13. As of December 10, 2020, Heffler has received 21 Notices returned by the

USPS with a forwarding address. Heffler has re-mailed 21 of the forwarded Notices to

the updated addresses provided by the USPS and will continue to re-mail Notices as

they are received.

14. As of December 10, 2020, Heffler has received 421 Notices returned by

the USPS as undeliverable as addressed. Heffler has updated the records in the

database to identify these as undeliverable.


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15. On December 4, 2020 Heffler has emailed 211,657 Reminder Notices to

Class Members that have not filed a claim. Of 211,657 emails sent, 2,004 emails

bounced that affected 1,979 records.

16. As of December 10, 2020, Heffler has not received any requests for

exclusion from the Settlement.

17. As of December 10, 2020, Heffler has not received any objections to the

Settlement.

18. As of December 10, 2020, Heffler has received 32 claim forms received

through the mail and 6,786 claims filed electronically through the Settlement Website.

Heffler is still in the process of reviewing and validating claims.

I declare under penalty of perjury under the laws of the United States that the

above is true and correct to the best of my knowledge and that this declaration was

executed on December 11, 2020 in Philadelphia, Pennsylvania.

______________________________

Brian Smitheman


Exhibit A


1515 Market Street, Suite 1700 ◼ Philadelphia, PA 19102

www.HefflerClaims.com

August 13, 2020

VIA FIRST CLASS CERTIFIED MAIL

To: All “Appropriate” Federal and State Officials Per 28 U.S.C. § 1715 (see attached distribution list)

Re: CAFA Notice for the Proposed Settlement in Sean Wilson v. Playtika, LTD, et al.,

No. 3:18-cv-05277-RBL in the United States District Court for the Western District of Washington

Ladies and Gentlemen:

Pursuant to Section 3 of the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1715, Defendants Playtika, LTD (“Playtika”) and Caesars Interactive Entertainment, LLC (“CIE”) (collectively “Defendants”) hereby notify you of the proposed settlement of the above-captioned action (the “Action”) currently pending in the United States District Court for the Western District of Washington at Tacoma (the “Court”).

28 U.S.C. § 1715(b) lists eight items that must be provided to you in connection with any

proposed class action settlement. Each of these items is addressed below: 1. 28 U.S.C. § 1715 (b)(l) - a copy of the complaint and any materials filed with the

complaint and any amended complaints. The Class Action Complaint is provided in electronic form on the enclosed CD as Exhibit A.

2. 28 U.S.C. § 1715 (b)(2) - notice of any scheduled judicial hearing in the class action.

On August 6, 2020, Plaintiff filed a motion for preliminary approval of the class action.

The motion date has not been set. A Final Approval Hearing date has not been set. A

copy of the Plaintiffs’ Motion for Preliminary Approval of Class Action and Proposed

Preliminary Approval Order are provided in electronic form on the enclosed CD as

Exhibit B and B1, respectively.

3. 28 U.S.C. § 1715(b)(3) - any proposed or final notification to Class Members.

A copy of the proposed Postcard Notice, email Notice and Long-Form Notice of

Settlement that will be provided to Class Members by first-class mail and/or email and


that will be available on the website created for the administration of this matter are provided in electronic form on the enclosed CD as Exhibit C, C1, and C2 respectively. The Notices describe among other things, claim submission and the Class Members’ rights to object or exclude themselves from the Class. Also enclosed, as Exhibit C3, is the Declaration of Scott M. Fenwick and Exhibit C4, is the Declaration of Jeanne C. Finegan concerning the Proposed Class Member Notice Program, which sets forth how the Settlement Administrator will publish notice to at least 80 percent of the Settlement Class Members through a combination of online and streaming radio advertisements.

4. 28 U.S.C. § 1715(b)(4) - any proposed or final class action settlement.

The Settlement Agreement is provided in electronic form on the enclosed CD as

Exhibit D. 5. 28 U.S.C. § 1715(b)(5) - any settlement or other agreement contemporaneously made

between class counsel and counsel for defendants.

There are no other settlements or other agreements between Class Counsel and counsel for Defendants beyond what is set forth in the Agreement.

6. 28 U.S.C. § 1715(b)(6) - any final judgment or notice of dismissal.

The Court has not yet entered a final judgment or notice of dismissal. Accordingly, no

such document is presently available. 7. 28 U.S.C. § 1715(b)(7) – (A) If feasible, the names of class members who reside in each

State and the estimated proportionate share of the claims of such members to the entire settlement to that State’s appropriate State official; or (B) if the provision of the information under subparagraph (A) is not feasible, a reasonable estimate of the number of class members residing in each State and the estimated proportionate share of the claims of such members to the entire settlement.

The definition of the class in the proposed Settlement Agreement means all persons who played the Applications on or before preliminary approval of the settlement while located in the state of Washington. Defendants currently do not know or have a means of reasonably determining how many settlement class members played the Applications. Given the class definition, however, it is highly likely that all or almost all class members reside in the state of Washington.

8. 28 U.S.C. § 1715(b)(8) - any written judicial opinion relating to the materials described

in 28 U.S.C. § 1715(b) subparagraphs (3) through (6).

There has been no written judicial opinion. Accordingly, no such document is presently available.


If you have any questions about this notice, the Action, or the enclosed materials, please contact the undersigned Settlement Administrator listed below.

Respectfully,

Scott M. Fenwick Chief of Operations [email protected]


SERVICE LIST FOR CAFA NOTICE

U.S. Attorney General William Barr U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001 Washington Attorney General Bob Ferguson 1125 Washington St. SE P.O. Box 40100 Olympia, WA 98504-0100


Exhibit B



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QUESTIONS? CALL 1-844-412-1946 TOLL FREE, OR VISIT WWW.PLAYTIKASETTLEMENT.COM

BASIC INFORMATION

1. Why was this Notice issued?

A Court authorized this Notice because you have a right to know about a proposed Settlement of this class action

lawsuit and about all of your options, before the Court decides whether to give final approval to the Settlement. This

Notice explains the lawsuit, the Settlement, and your legal rights.

Judge Ronald B. Leighton of the United States District Court for the Western District of Washington is overseeing this

class action. The lawsuit is known as Sean Wilson v. Playtika, LTD, et al., No. 3:18-cv-05277-RBL (W.D. Wash.). The person who sued, Sean Wilson, is one of the “Class Representatives.” The companies that got sued, Playtika, LTD

and Caesars Interactive Entertainment, LLC, are called the “Defendants.”

2. What is a class action?

In a class action, one or more people called Class Representatives sue on behalf of a group or a “class” of people who

have similar claims. In a class action, the Court resolves the issues for all Class Members, except for those who choose

to exclude themselves from the Class.

3. What is this lawsuit about?

The lawsuit claims that Defendants violated Washington’s gambling laws and Washington’s Consumer Protection Act

through the sale of virtual chips in the following social casino-style games: Slotomania, House of Fun, Caesars

Casino/Caesars Slots, and Vegas Downtown Slots. Defendants deny all claims and that they violated any law.

4. Why is there a Settlement?

The Court has not decided whether the Plaintiff or the Defendants should win this case. Instead, both sides agreed to

a Settlement. That way, they avoid the uncertainties and expenses associated with ongoing litigation, and Settlement

Class Members will get compensation now rather than years from now, if at all.

More information about the Settlement and the lawsuit are available in the “Documents” section of the Settlement

Website, or by accessing the Court docket in this case, for a fee, through the Court’s Public Access to Court Electronic

Records (PACER) system at https://ecf.wawd.uscourts.gov, or by visiting the office of the Clerk of the Court for the

United States District Court for the Western District of Washington, Tacoma Courthouse, between 9:00 a.m. and 4:00

p.m., Monday through Friday, excluding Court holidays.

WHO’S INCLUDED IN THE SETTLEMENT

5. How do I know if I am in the Settlement Class?

The Court decided that everyone who fits this description and chooses not to request to be excluded is a member of

the Settlement Class:

All persons who, on or before August 31, 2020, played Slotomania, House of Fun, Caesars Casino/Caesars Slots, or

Vegas Downtown Slots while located in the state of Washington. Excluded from the Settlement Class are (1) any Judge

or Magistrate presiding over this Action and members of their families, (2) the Defendants, Defendants’ subsidiaries,

parent companies, successors, predecessors, and any entity in which the Defendants or their parents have a controlling

interest and their current or former officers, directors, and employees, (3) persons who properly execute and file a

timely request for exclusion from the Settlement Class, and (4) the legal representatives, successors or assigns of any

such excluded persons.

If you are not sure whether you are included, you can call the Settlement Administrator at 1-844-412-1946. Or you

can get free help by calling the lawyers appointed to represent Class Members in this case at 1-888-852-8116.


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THE SETTLEMENT BENEFITS

6. What does the Settlement provide?

If approved by the Court, Defendants will establish a Settlement Fund totaling $38,000,000. Settlement Class

Member Payments, as well as the cost to administer the Settlement, the cost to inform people about the Settlement,

any attorneys’ fees and costs awarded by the Court, and any incentive award to the Class Representatives

approved by the Court will also come out of this fund.

7. How much will my payment be?

If you are member of the Settlement Class you may submit a Claim Form to receive a portion of the Settlement Fund.

The exact amount of your payment can’t be determined at this time, but you can get an estimate by visiting the

Settlement Website. The amount of your payment will depend on, among other things, (1) the total dollar amount of

in-game purchases you made while playing Slotomania, House of Fun, Caesars Casino/Caesars Slots, and Vegas

Downtown Slots, with those who spent more money receiving a higher percentage back, and (2) how many Settlement

Class Members file valid Claims. If you would like more information about how Settlement Payments are determined,

visit www.playtikasettlement.com

8. When will I get my payment?

You should receive a check or electronic payment from the Settlement Administrator within 60 days after the

Settlement has been finally approved and/or after any appeals process is complete. The hearing to consider the final

approval of the Settlement is scheduled for February 11, 2021, at 1:30 pm PT. If you select to receive your payment

via check, please keep in mind that checks will expire and become void 90 days after they are issued. If appropriate,

funds remaining from the initial round of uncashed checks, or electronic payments that cannot be processed, may be

used for a second distribution to Settlement Class Members and/or may be donated to the Legal Foundation of

Washington.

HOW TO GET BENEFITS

9. How do I get a payment?

If you are a Settlement Class Member and you want to receive a payment, you must complete and submit a valid Claim

Form by January 4, 2021. Claim Forms can be found and submitted online, or you may request that a Claim Form be

sent to you in the mail (and which you can then submit by mail). To submit a Claim Form online or to request a paper

copy, go to www.playtikasettlement.com or call toll free, 1-844-412-1946.

We encourage you to submit your Claim electronically. Not only is it easier and more secure, but it is completely free

and takes only minutes!

REMAINING IN THE SETTLEMENT

10. What am I giving up if I stay in the Settlement Class?

If the Settlement becomes final, you will give up your right to sue the Defendants for the claims being resolved by this

Settlement. The specific claims you are giving up against the Defendants are described in the Settlement Agreement

in Section 1.27. You will be “releasing” the Defendants and certain related parties (collectively, the “Released

Parties”), described in Section 1.28 of the Settlement Agreement. Unless you exclude yourself (see Question 14), you

are releasing the claims, regardless of whether you submit a Claim or not. The Settlement Agreement is available

through the documents section on the Settlement Website at www.playtikasettlement.com.

The Settlement Agreement describes the Released Claims with specific descriptions, so read it carefully. If you have

any questions you can talk to the lawyers listed in Question 12 for free by calling 1-888-852-8116, or you can, of

course, talk to your own lawyer if you have questions about what this means.

11. What happens if I do nothing at all?


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If you do nothing, you won’t get any monetary benefits from this Settlement. But, unless you exclude yourself, you

won’t be able to bring or participate in any other lawsuit against the Defendants for the claims being resolved by this

Settlement.

THE LAWYERS REPRESENTING YOU

12. Do I have a lawyer in the case?

The Court has appointed a group of lawyers at the firm Edelson PC to represent the Settlement Class. Those lawyers— Jay Edelson, Rafey Balabanian, Todd Logan, Alexander G. Tievsky, and Brandt Silver-Korn —are called “Class

Counsel.” They are experienced in handling similar class action cases. More information about these lawyers, their

law firm, and their experience is available at www.edelson.com. They believe, after conducting an extensive

investigation, that the Settlement Agreement is fair, reasonable, and in the best interests of the Settlement Class. You

will not be charged for these lawyers. If you want to be represented by your own lawyer in this case, you may hire one

at your expense.

The Court also appointed Plaintiff Sean Wilson, who has played at least one of the social casino-style games in

Question 3, as one of the Class Representatives.

13. How will the lawyers be paid?

Class Counsel attorneys’ fees and costs will be paid from the Settlement Fund in an amount to be determined and

awarded by the Court. The fee petition will seek no more than 30% of the Settlement Fund. The Court may award less

than this amount.

Subject to approval by the Court, each Class Representative may be paid an “Incentive Award” from the Settlement

Fund for helping to bring and settle this case. No Class Representative will ask for more than $5,000 as an Incentive

Award.

EXCLUDING YOURSELF FROM THE SETTLEMENT

14. How do I get out of the Settlement?

To exclude yourself from the Settlement, you must email, mail, or otherwise deliver a letter ( request for exclusion)

stating that you want to be excluded from the “Sean Wilson v. Playtika, LTD, et al., No. 3:18-cv-05277-RBL (W.D.

Wash.)” case. Your letter or request for exclusion must include your (a) name (b) telephone number (c) U.S. Mail

address, (d) email address, (e) User IDs and/or email addresses associated with Slotomania, House of Fun, Caesars

Casino/Caesars Slots, and Vegas Downtown Slots, and (f) your signature. You must email or mail your exclusion

request no later than January 4, 2021, to:

Wilson v Playtika, LTD

c/o Settlement Administrator

PO Box 190

Warminster, PA 18974-0190

[email protected]

15. If I don’t exclude myself, can I sue the Defendants for the same thing later?

No. Unless you exclude yourself, you give up any right to sue the Defendants for the claims being resolved by this

Settlement.

16. If I exclude myself, can I get anything from this Settlement?

No. If you exclude yourself, you should not submit a Claim Form to ask for benefits because you won’t receive any.

OBJECTING TO THE SETTLEMENT

17. How do I object to the Settlement?


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You can ask the Court to deny approval by filing an objection. You can’t ask the Court to order a different Settlement;

the Court can only approve or reject the Settlement being proposed. If the Court denies approval, no Settlement

Payments will be sent out and the lawsuit will continue. If that is what you want to happen, you must object.

Any objection to the proposed settlement must be in writing. If you file a timely written objection, you may, but are

not required to, appear at the Final Approval Hearing, either in person or through your own attorney. If you appear

through your own attorney, you are responsible for hiring and paying that attorney. If you want to appear and speak at

the Final Approval Hearing to object to the Settlement, with or without a lawyer (explained below in answer to

Question Number 21), you must say so in your letter or brief. All written objections and supporting papers must

include: (i) all User ID(s) associated with Slotomania, House of Fun, Caesars Casino/Caesars Slots, and/or Vegas

Downtown Slots, (ii) all email address(es) associated with Slotomania, House of Fun, Caesars Casino/Caesars

Slots, and/or Vegas Downtown Slots, (iii) current telephone number, U.S. Mail address, and email address, (iv) the

specific grounds for the objection, (v) all documents or writings that the Settlement Class Member desires the Court

to consider, (vi) the name and contact information of any and all attorneys representing, advising, or in any way

assisting the objector in connection with the preparation or submission of the objection or who may profit from the

pursuit of the objection, and (vii) a statement indicating whether the objector intends to appear at the Final Approval

Hearing (either personally or through counsel, who must file an appearance or seek pro hac vice admission). All written

objections must be emailed or otherwise delivered to Class Counsel and Defendants’ Counsel, and filed with the Court

before January 4, 2021.

Class Counsel will file with the Court and post on this website its request for attorneys’ fees by December 14, 2020.

18. What’s the difference between objecting and excluding myself from the Settlement?

Objecting simply means telling the Court that you don’t like something about the Settlement. You can object only if

you stay in the Settlement Class. Excluding yourself from the Settlement Class is telling the Court that you don’t want

to be part of the Settlement Class. If you exclude yourself, you have no basis to object because the case no longer

affects you.

THE COURT’S FINAL APPROVAL HEARING

19. When and where will the Court decide whether to approve the Settlement?

The Court will hold the Final Approval Hearing on February 11, 2021, at 1:30 pm PT. The purpose of the hearing will

be for the Court to determine whether to approve the Settlement as fair, reasonable, adequate, and in the best interests

of the Settlement Class; to consider Class Counsel’s request for attorneys’ fees and expenses; and to consider the

request for an Incentive Award to the Class Representatives. At that hearing, the Court will be available to hear any

objections and arguments concerning the fairness of the Settlement.

The hearing may be postponed to a different date or time without notice, so it is a good idea to check

www.playtikasettlement.com or call 1-844-412-1946 to confirm the hearing date. If, however, you timely objected to

the Settlement and advised the Court that you intend to appear and speak at the Final Approval Hearing, you will

receive notice of any change in the date of such Final Approval Hearing.

20. Do I have to come to the hearing?

No. Class Counsel will answer any questions the Court may have. But, you are welcome to come at your own expense.

If you send an objection or comment, you don’t have to come to Court to talk about it. As long as you filed and mailed

your written objection on time, the Court will consider it. You may also pay another lawyer to attend, but it’s not

required.

21. May I speak at the hearing?

Yes. You may ask the Court for permission to speak at the Final Approval Hearing. To do so, you must include in

your letter or brief objecting to the Settlement a statement saying that it is your “Notice of Intent to Appear in Sean


6


Wilson v. Playtika, LTD, et al., No. 3:18-cv-05277-RBL (W.D. Wash.).” It must include your name, address, telephone

number and signature as well as the name and address of your lawyer, if one is appearing for you. Your objection and

notice of intent to appear must be filed with the Court and sent no later than January 4, 2021.

GETTING MORE INFORMATION

22. Where do I get more information?

This Notice summarizes the Settlement. More details are in the Settlement Agreement. You can get a copy of the

Settlement Agreement at www.playtikasettlement.com. You can also get information about this case by accessing the

Court docket, for a fee, through the Court’s Public Access to Court Electronic (PACER) system at

https://ecf.wawd.uscourts.gov, or by visiting the office of the Clerk of the Court for the United States District Court

for the Western District of Washington, Tacoma Courthouse, between 9:00 a.m. and 4:00 p.m., Monday through

Friday, excluding Court holidays. You may also write with questions to the Settlement Administrator, Wilson v

Playtika, LTD c/o Settlement Administrator, PO Box 190, Warminster, PA 18974-0190. And you can call the

Settlement Administrator at 1-844-412-1946 or Class Counsel at 1-888-852-8116, if you have any questions. Before

doing so, however, please read this Notice carefully.

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE ABOUT THIS

SETTLEMENT OR THE CLAIMS PROCESS. All questions regarding the Settlement or claims process should be

directed to the Settlement Administrator or to Class Counsel.


[[POSTAL CODE AREA]]

<<FirstName>> <<LastName>> <<BusinessName>> <<Address>> <<Address2>> <<City>>, <<ST>> <<Zip>>-<<zip4>>

FIRST-CLASS MAILU S POSTAGE PAID

CITY, ST PERMIT NO XXXX

Postal Service: Please do not mark barcode <<Barcode>> Class Member ID: <<Refnum>>

COURT AUTHORIZED NOTICE OF CLASS ACTION AND PROPOSED SETTLEMENT

If you have played Slotomania, House of Fun, Caesars Casino/Caesars

Slots, or Vegas Downtown Slots while in the State of Washington, you may be

part of a class action settlement.

By Order of the Court

Dated: November 9, 2020

Wilson v Playtika, LTDc/o Settlement AdministratorP.O. Box 190Warminster, PA 18974-0190


A Settlement has been reached in a class action lawsuit against Playtika, LTD and Caesars Interactive Entertainment, LLC (“Defendants”), alleging claims under Washington state law based on the sale of virtual chips in the following social casino-style games: Slotomania, House of Fun, Caesars Casino/Caesars Slots, and Vegas Downtown Slots Defendants deny all claims and that they violated any law, but have agreed to the Settlement to avoid the uncertainties and expenses associated with continuing the case Am I a Settlement Class Member? Our records indicate you may be a Settlement Class Member Settlement Class Members are persons in the state of Washington who played Slotomania, House of Fun, Caesars Casino/Caesars Slots, or Vegas Downtown Slots on or before August 31, 2020 More information is available at www playtikasettlement com What Can I Get? If approved by the Court, Defendants will establish a Settlement Fund totaling $38,000,000 to pay all valid Claims submitted by the Settle-ment Class, together with Notice and Administration Expenses as well as any attorneys’ fees, costs, and incentive awards to the Class Representatives awarded by the Court If you are entitled to relief, you may submit a Claim to receive a share of the Settlement Fund Your share will depend on, among other things, (1) the total dollar amount of in-game purchases you made while playing Slotomania, House of Fun, Caesars Casino/Caesars Slots, and Vegas Downtown Slots, with those who spent more money receiving a higher percentage back and (2) how many Settlement Class Members file valid Claims You can find more information about the Settlement Fund, and estimate your share of the Settlement Fund, at www playtikasettlement com How Do I Get a Payment? You must complete and submit a valid Claim Form by January 4, 2021 To submit a Claim Form online or to request a paper copy, go to www playtikasettlement com or call toll free 1-844-412-1946

What are My Other Options? You may choose to exclude yourself from the Class by sending a letter by mail or email to the Settlement Administrator no later than January 4, 2021 If you exclude yourself, you will not receive a Settlement Payment, but you keep any rights you may have to sue Defendants over the legal claims raised in the lawsuit You and/or your lawyer also have the right to object to the proposed Settlement Your written objection must be filed no later than January 4, 2021 Specific instructions about how to object to, or exclude yourself from, the Settlement are available at www playtikasettlement com If you file a Claim or do nothing, and the Court approves the Settlement, you will be bound by all of the Court’s orders and judgments in this case In addition, your claims relating to the allegations in this case against Defendants and any other Released Parties will be released Who Represents Me? The Court has appointed lawyers from Edelson PC to represent the Settlement Class These attorneys are called “Class Counsel ” You will not be charged for these lawyers Plaintiff Sean Wilson is a Settlement Class Member and the Court appointed him as one of the “Class Representatives ” You can be represented by your own lawyer at your expense

When Will the Court Consider the Proposed Settlement? The Court will hold the Final Approval Hearing at 1:30 pm PT, on February 11, 2021 At that hearing, the Court will: hear any objections to the fairness of the Settlement; determine the fairness of the Settlement; consider Class Counsel’s request for attorneys’ fees and costs; and decide whether to approve incentive awards to the Class Representatives of up to $5,000 each from the Settlement Fund Class Counsel will be paid from the Settlement Fund in an amount to be determined by the Court Class Counsel will seek no more than 30% of the Settlement Fund; the Court may award less than these amounts How Do I Get More Information? For more information, including the Notice, Claim Form and Settlement Agreement go to www playtikasettlement com, contact the Playtika Settlement Administrator at 1-844-412-1946, or call Class Counsel at 1-888-852-8116 PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE ABOUT THIS SETTLEMENT OR THE CLAIMS PROCESS All questions regarding the Settlement or Claims process should be directed to the Settlement Administrator or to Class Counsel


FROM: [email protected]

TO: [email protected]

RE: LEGAL NOTICE OF CLASS ACTION

If you played Slotomania, House of Fun, Caesars Casino/Caesars Slots, or Vegas

Downtown Slots while in the State of Washington, you may be part of a class action

settlement.

A Federal Court authorized this Notice. You are not being sued. This is not a solicitation from a lawyer.

A Settlement has been reached in a class action lawsuit against Playtika, LTD and Caesars Interactive

Entertainment, LLC (“Defendants”), alleging claims under Washington State law based on the sale of virtual

chips in the following social casino-style games: Slotomania, House of Fun, Caesars Casino/Caesars Slots, and

Vegas Downtown Slots. Defendants deny all claims and that they violated any law, but have agreed to the

Settlement to avoid the uncertainties and expenses associated with continuing the case.

Am I a Settlement Class Member?

Our records indicate that you may be a Settlement Class Member. Settlement Class Members are persons in the

State of Washington who played Slotomania, House of Fun, Caesars Casino/Caesars Slots, or Vegas Downtown

Slots on or before August 31, 2020. More information is available at www.playtikasettlement.com.

What can I get?

If approved by the Court, Defendants will establish a Settlement Fund totaling $38,000,000 to pay all valid Claims

submitted by the Settlement Class, together with notice and Administration Expenses as well as any attorneys’

fees, costs, and incentive awards to the Class Representatives awarded by the Court. If you are entitled to relief,

you may submit a Claim to receive a share of the Settlement Fund. Your share will depend on, among other

things, (1) the total dollar amount of in-game purchases you made while playing Slotomania, House of Fun,

Caesars Casino/Caesars Slots, and Vegas Downtown Slots, with those who spent more money receiving a higher

percentage back, and (2) how many Settlement Class Members file valid Claims. You can find more information,

and estimate your share of the Settlement Fund, at www.playtikasettlement.com .

How do I get a payment?

You must complete and submit a valid Claim Form by January 4, 2021. To submit a Claim Form online or to

request a paper copy, go to www.playtikasettlement.comor call toll free 1-844-412-1946.

What are my other options?

You may choose to exclude yourself from the Settlement Class by sending a letter by mail or email to the

Settlement Administrator no later than January 4, 2021. If you exclude yourself, you will not receive a Settlement

Payment, but you keep any rights you may have to sue Defendants over the legal claims raised in the lawsuit.

You and/or your lawyer also have the right to object to the proposed settlement. Your written objection must be

filed no later than January 4, 2021. Specific instructions about how to object to, or exclude yourself from, the

Settlement are available at www.playtikasettlement.com If you file a Claim or do nothing, and the Court approves

the Settlement, you will be bound by all of the Court’s orders and judgments in this case. In addition, your claims

relating to the allegations in this case against Defendants and any other Released Parties will be released.


Who represents me?

The Court has appointed lawyers from Edelson PC to represent the Settlement Class. These attorneys are called

“Class Counsel.” You will not be charged for these lawyers. If you want to be represented by your own lawyer in

this case, you may hire one at your expense. Plaintiff Sean Wilson is a Settlement Class Member and the Court

appointed him as one of the “Class Representatives.”

When will the Court consider the proposed settlement?

The Court will hold the Final Approval Hearing at 1:30 pm PT, on February 11, 2021. At that hearing, the Court

will: hear any objections to the fairness of the Settlement; determine the fairness of the Settlement; consider Class

Counsel’s request for attorneys’ fees and costs; and decide whether to approve incentive awards to the Class

Representative of up to $5,000 each from the Settlement Fund. Class Counsel will be paid from the Settlement

Fund in an amount to be determined and awarded by the Court. Class Counsel will seek no more than 30% of the

Settlement Fund; the Court may award less than these amounts.

How do I get more information?

For more information, including the Notice, Claim Form and Settlement Agreement go to

www.playtikasettlement.com, contact the Settlement Administrator at 1-844-412-1946, or call Class Counsel at 1-

888-852-8116.

PLEASE DO NOT TELEPHONE THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE ABOUT THIS

SETTLEMENT OR THE CLAIMS PROCESS. All questions regarding the Settlement or Claims process should be

directed to the Settlement Administrator or to Class Counsel.


*3115000000000* 3 1 1 5 0 0 0 0 0 0 0 0 0

WILSON V PLAYTIKA, LTD, SETTLEMENT CLAIM FORM

THIS CLAIM FORM MUST BE SUBMITTED ONLINE OR POSTMARKED BY JANUARY 4, 2021. THE CLAIM FORM MUST BE SIGNED AND MEET ALL CONDITIONS OF THE SETTLEMENT AGREEMENT.

The Settlement Administrator will review your Claim Form. If accepted, you will receive a share of the Settlement Fund. This process takes time, please be patient. If you have any questions, or would like to estimate your share of the Settlement Fund, visit: www.playtikasettlement.com.

Instructions. Fill out each section of this form and sign where indicated. To find your User ID(s), find the About page in the App, and then look in the bottom left corner.

First Name Last Name

Street Address

City

____________________________________________________________

State

___ ___

ZIP Code

____ ____ ____ ____ ____

Email Address

_______________________________________________________________________

Phone Number

( ____ ____ ____ ) ____ ____ ____ - ____ ____ ____ ____

Slotomania User ID(s) (only complete if you have played this game)

House of Fun User ID(s) (only complete if you have played this game)

Caesars Casino User ID(s) (only complete if you have played this game)

Vegas Downtown Slots User ID(s) (only complete if you have played this game)

All email addresses associated with Slotomania, House of Fun, Caesars Casino/Caesars Slots and/or Vegas Downtown Slots accounts.

_____________________________________________________________ _____________________________________________________________

_____________________________________________________________ _____________________________________________________________

_____________________________________________________________ _____________________________________________________________

All email addresses associated with Facebook (App Center), Apple (App Store), Google (Play Store), Amazon, Microsoft, and Samsung accounts from which you played Slotomania, House of Fun, Caesars Casino/Caesars Slots, and/or Vegas Downtown Slots.

_____________________________________________________________ _____________________________________________________________

_____________________________________________________________ _____________________________________________________________

_____________________________________________________________ _____________________________________________________________

Settlement Class Member Affirmation: By submitting this Claim Form you affirm under penalty of perjury that, to the best of your knowledge, the User ID(s) and email address(es) listed above are yours.

Signature: ____________________________________________ Date: ____ ____/ ____ ____/ ____ ____

If you would like receive an electronic payment please submit your Claim Form through Settlement Website at www.playtikasettlement.com.

*31150* *CF* *Page 1 of 1* 31150 CF Page 1 of 1
