Rodriguez v. Google LLC 19 20-cv-04688-RS (N.D. Cal. Jan. 3, 2024) according to Google, require it to identify each class member and contravene its own policy “against joining pseudonymous data with user accounts” to delete this data. Opp. at 25. This argument is unavailing. Plaintiffs seek deletion of all sWAA-off data collected. Indeed, if Google were conducting “basic record-keeping” of its users' data, then it should know which of its users toggled sWAA off and which did not - a *19 feature by Google and, therefore, under its control.4 Plaintiffs contend that Google should delete sWAA-off data Google itself admits to collecting, albeit only for record-keeping purposes. Further, Google fails to raise any arguments against three out of four Plaintiffs' requests, and Plaintiffs have convincingly identified “the general contours” of the class-wide injunctive relief they seek. Parsons v. Ryan, 754 F.3d 657, 689-90 fn. 35 (9th Cir. 2014). Google may raise these arguments again at summary judgment should it wish to do so, but at this stage, Plaintiffs have met their burden. Class certification is granted under 23(b)(2). 4 Google states that it conducts “basic record-keeping” of its users' data because, even when a user's sWAA is turned off, it will “(1) log the fact that it has served an ad alongside a pseudonymous device identifier for accounting purposes, and (2) attribute conversion events to those ad serving records.” Opp at 5. B. Daubert Motion as to Michael J. Lasinski Google moves to exclude the opinion of Michael J. Lasinski, Plaintiff's damages expert, relying on Fed.R.Evid. 702 and Daubert. Dkt. at 330. Lasinski opines that discovery can be used to establish monetary relief sought by Plaintiffs class-wide. Lasinski Rep. 1. As discussed above, Lasinski provided two sub-models under Plaintiffs' unjust enrichment theory (Scenarios One and Two) and one model for actual damages. Lasinski's unjust enrichment analyses “quantify the portion of Google's U.S. App Promo, AdMob, and Ad Manager app ads revenues and attendant profits attributable to the alleged wrongful conduct” under two scenarios, discussed further below. Lasinski Rep. ¶ 77. For much of his analysis, Lasinski relies on the opinions of Jonathan Hochman, Plaintiffs' technical expert, and Mark Keegan, Plaintiffs' survey expert. I. Unjust Enrichment 20 Under Scenario One, Lasinski calculates Google's unjust enrichment as equal to “(a) Google's U.S. App Promo revenues and attendant profits from signed-in, WAA/sWAA-Off users attributable to conversion tracking with GA4F plus [(b)] the portion of Google's U.S. AdMob and [(c)] Ad Manager app ads revenues and attendant profits from signed-in, WAA/sWAA-Off users attributable to conversion tracking.” Id. ¶ 82-91 (describing methods of calculating the proportion *20 of Google's U.S. App Promo net revenue from signed-in, WAA/sWAA-off users attributable to conversion tracking). Per Scenario 1, damages equate to $558.8 million. In Scenario Two, Lasinski calculates (a) “the revenues and attendant profits attributable to conversion tracking quantified under Scenario One plus [(b)] an additional measure of AdMob and Ad Manager app ads revenues and attendant profits attributable to the serving and monetization of ads to WAA/sWAA-Off users.” Id. ¶ 113. The additional measure here adds the value to Google derived from served ads from methods other than conversions. Scenario Two calculates damages totaling $664.3 million. II. Actual damages To generate a model for his actual damages calculation, Lasinski considered: (a) Google's payments for user data, (b) Users' willingness to pay to prevent data collection; and (c) Research organizations' willingness to pay for data collection.” Id. ¶ 132. Lasinski looked to the Ipsos Screenwise Panel, a consumer research study conducted by Google since 2012 to “collect information about how 12