Alphabet Securities Litigation

The Notice was issued pursuant to Rule 23 of the Federal Rules of Civil Procedure and the Order of the United States District Court for the Northern District of California, entered on May 18, 2026, certifying the above-captioned action as a class action. If you received a Notice, it was sent to notify you that you may be a member of the Class whose rights could be affected.

The purpose of this Notice is to inform Class Members of: (a) the pendency of the captioned class action; (b) the certification of the Class; and (c) the right to be excluded from the Class. This Action has not been settled and continues to be litigated. Accordingly, no claim form needs to be filed at this time.

The Class Representatives in this action are Lead Plaintiffs Menora Mivtachim Insurance Ltd. and Menora Mivtachim Pensions and Gemel Ltd. (“Menora”) and additional Named Plaintiffs AMI - Government Employees Provident Fund Management Company Ltd. and City of Fort Lauderdale Police & Fire Retirement System, whom the Court has appointed to represent the Class.

The Defendants in this action are Alphabet, Google LLC, and Sundar Pichai (collectively, the “Defendants”).

This is an action for violations of Section 10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder and Section 20(a) of the Exchange Act. The Second Amended Class Action Complaint (“SAC”) alleges that on September 14, 2020, in a written response to Congress following CEO Pichai’s Congressional testimony, Google and Pichai made the following false and misleading statement about how Google’s advertising technology products worked: “[t]he channel through which a bid is received does not otherwise affect the determination of the winning bidder." The Court found that the SAC sufficiently alleged that this representation was materially false and misleading when made. ECF No. 108 at 8–10. The Court also found that the SAC sufficiently alleged that this representation was made with scienter (that is, an intent to deceive, manipulate, or defraud) based on a number of circumstantial factors. ECF No. 108 at 10–12.

The Defendants deny all claims and wrongdoing asserted in the SAC and any liability arising out of the conduct alleged therein. The Defendants filed an answer to the SAC on May 1, 2025, denying all material allegations and asserting multiple defenses.

The Court has not made any determination about whether the Defendants engaged in any alleged misconduct or wrongdoing.

On March 16, 2023, plaintiff AMI - Government Employees Provident Fund Management Company Ltd. filed a putative securities class action complaint against defendants Alphabet Inc., Sundar Pichai, Ruth M. Porat, and Philipp Schindler. ECF No. 1. Two motions for appointment as lead plaintiff were filed. ECF Nos. 19, 22. On May 30, 2023, the only other movant withdrew his motion (ECF No. 27), and on June 9, 2023, the Court appointed Menora as Lead Plaintiff and Pomerantz LLP as lead counsel. ECF No. 29.

Defendants filed a motion to dismiss Plaintiffs’ first Amended Complaint on September 21, 2023. ECF No. 58. Plaintiffs opposed that motion and briefing was completed on December 11, 2023. ECF Nos. 60, 67. A hearing on this motion took place on April 16, 2024. The Court ruled on Defendants’ motion to dismiss on September 3, 2024, (ECF No. 86), granting the motion with leave to amend the complaint. After Plaintiffs filed the SAC, Defendants moved to dismiss the complaint on November 8, 2024. ECF No. 93. Briefing was completed on January 21, 2025. ECF Nos. 98, 101. After a hearing on the motion to dismiss the SAC on March 4, 2025, the Court issued an Order on March 24, 2025, granting in part and denying in part Defendants’ motion to dismiss the SAC. ECF No. 108. Plaintiffs filed a motion for class certification. ECF No. 134. Defendants opposed and the class certification motion was fully briefed on April 2, 2026, when Defendants requested to file a surreply that the Court ultimately permitted. ECF Nos. 142, 148, 149-1, 168. The Court held oral argument on April 14, 2026 (ECF No. 153). It granted class certification on May 18, 2026. ECF No. 168. The Court certified the Class, appointed the Plaintiffs as Class Representatives and Pomerantz LLP as Class Counsel. Id. Certification of the Class means that the action was legally recognized as a Class Action pursuant to Rule 23 of the Federal Rules of Civil Procedure. The class definition is as follows:

All persons and entities other than Defendants, members of the immediate family of the Individual Defendant, Alphabet Inc.’s (“Alphabet” or the “Company”) subsidiaries and affiliates; any person who is or was an officer or director of the Company or any of the Company’s subsidiaries or affiliates during the Class Period; any entity in which any Defendant has a controlling interest; and the legal representatives, heirs, successors, and assigns of any such excluded person or entity, who purchased or otherwise acquired Alphabet’s Class A and/or Class C shares between September 15, 2020 and January 23, 2023, both dates inclusive (the “Class Period”) on (i) any stock exchanges located in the United States, (ii) on any alternative trading systems located in the United States, or (iii) pursuant to other domestic transactions, seeking to recover damages caused by Defendants’ violations of the federal securities laws and to pursue remedies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”) and Rule 10b-5 promulgated thereunder, against Alphabet, Google LLC (“Google”), and Sundar Pichai.

If you purchased or otherwise acquired shares of Alphabet Class A and/or Class C stock during the period of September 15, 2020 through January 23, 2023, both dates inclusive, you may be a member of the Class.

The Court has not made any determination about whether the Defendants engaged in any alleged misconduct or wrongdoing.

The Court has not ruled on the merits of Class Representatives’ claims or on Defendants’ denials or other defenses, and this case has not been settled. If you received a Notice, it was intended only to inform you that a class action is currently in progress. There is no assurance that a judgment in favor of the Class will be granted.

No. If you are a Class Member and wish to remain a Class Member, you do not need to do anything at this time other than to retain your documentation reflecting your transactions and holdings in Alphabet Class A and/or Class C stock. You will be bound by the lawsuit and may be eligible to participate in the benefits if there is a recovery.

If you are a Class Member and wish to be excluded from the Class, you must state so in writing. Your exclusion request must be postmarked no later than September 16, 2026 and must state:

1. The name, telephone number, and address of the person or entity requesting exclusion;
2. A statement that such person or entity requests exclusion from the Class in this Action;
3. The number of Alphabet Class A and/or Class C shares purchased or acquired, and the date the shares were purchased or acquired; and
4. Must be signed by that person or entity requesting exclusion from the Class.

Requests for exclusion must be transmitted by first class mail or overnight delivery service to the Notice Administrator at the following address:

The Class is represented by:

Copies of the Notice and other Court documents can be obtained from the Important Documents page of this website. If you have any questions about this case or your membership in the Class, please contact the Notice Administrator at: