Hajny

I. BACKGROUND

A. The Lawsuits Filed Against Defendants Volkswagen is a subsidiary of a car manufacturer, and Audi is a trademark of Volkswagen and a luxury car brand. Shift Digital provided Volkswagen and Audi with marketing and data management services. The record shows that defendants were sued in three separate class action lawsuits for an alleged data breach affecting approximately 3,177,000 consumers—Wynne v. Audi of America, LLC (N.D.Cal. 2021, No. 4:21-cv- 08518-DMR) (Wynne); Villalobos v. Volkswagen Group of America, Inc. (D.N.J. 2021, No. 2:21-cv-13049-JMV-JBC) (Villalobos); and Hajny v. Volkswagen Group of America, Inc. (D.N.J. 2021, No. 2:21-cv-13442-JMV- JBC) (Hajny). Wynne filed her action in June 2021 in the Superior Court for Marin County, and defendants removed the case to the Northern District of California. Wynne’s complaint asserted a claim for violations of the California Consumer Privacy Act of 2018 (CCPA), Civil Code section 1798.100 et seq. Shortly after Wynne filed her action, the Villalobos and Hajny actions were filed in the District of New Jersey and then consolidated as In Re: Volkswagen Data Incident Litigation (D.N.J. 2021, No. 4:21-cv-08518)…