Case 3:24-md-03098-EMC Document 184 Filed 01/02/26 Page 1 of 5 1 Gayle M. Blatt, SBN 122048 Rebekah S. Guyon, SBN 291037 gmb@cglaw.com Rebekah.guyon@gtlaw.com 2 CASEY GERRY GREENBERG TRAURIG LLP 3 FRANCAVILLA BLATT LLP 1840 Century Park East, Suite 1900 110 Laurel Street Los Angeles, CA 90067 4 San Diego, CA 92101 Telephone: (310) 586-7700 Telephone: 619.238.1811 5 Facsimile: 619.544.9232 Stephen L. Saxl (pro hac vice) saxls@gtlaw.com 6 Cari Campen Laufenberg (pro hac vice) One Vanderbilt Avenue 7 claufenberg@kellerrohrback.com New York, NY 10017 KELLER ROHRBACK L.L.P. Telephone: (212) 801-9200 8 1201 Third Avenue, Suite 3400 Seattle, WA 98101 Ian C. Ballon, SBN 141819 9 Telephone: 206.623.1900 ballon@gtlaw.com Facsimile: 206.623.3384 1900 University Avenue, 5th Floor 10 East Palo Alto, CA 94303 11 Norman E. Siegel (pro hac vice) Telephone (650) 328-8500 siegel@stuevesiegel.com Fax: (650) 328-8508 12 STEVE SIEGEL HANSON LLP 460 Nichols Road, Suite 200 Kristin O’Carroll, SBN 312902 13 Kansas City, MO 64112 ocarrollk@gtlaw.com Telephone: 816.714.7100 101 Second Street, Suite 2200 14 Facsimile: 816.714.7101 San Francisco, CA 94105-3668 15 Telephone: (415) 655-1300 Interim Co-Lead Class Counsel 16 Attorneys for Defendant 23andMe, Inc. 17 18 UNITED STATES DISTRICT COURT 19 NORTHERN DISTRICT OF CALIFORNIA 20 IN RE 23ANDME, INC. CUSTOMER DATA CASE NO. 3:24-md-03098-EMC SECURITY BREACH LITIGATION 21 JOINT REQUEST FOR CONTINUANCE OF JANUARY 13, 2026 CASE MANAGEMENT 22 CONFERENCE; [PROPOSED] ORDER 23 Conference Date: January 13, 2026 24 Time: 2:30 p.m. 25 The Honorable Edward M. Chen 26 27 28 Case No. 3:24-md-03098-EMC JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 3:24-md-03098-EMC Document 184 Filed 01/02/26 Page 2 of 5 1 On August 21, 2025, the Court issued an order (ECF No. 182) scheduling a Further Case 2 Management Conference to be held on January 13, 2026 at 2:30 PM and ordering the Parties to file a Joint 3 Case Management Statement by January 6, 2026. The Parties jointly provide the following update and 4 respectfully request a continuance of the Case Management Conference for the reasons set forth below. 5 On April 4, 2025, Defendant ChromeCo, Inc. (f/k/a 23andMe, Inc.) filed a Notice of Suggestion of 6 Pendency of Bankruptcy for 23andMe Holding Co., et al., and Automatic Stay of Proceedings informing 7 this Court that on March 23, 2025, Chrome Holding Co. (f/k/a 23andMe Holding Co.) and certain of its 8 direct and indirect subsidiaries, including ChromeCo, Inc. (collectively, the “Debtors” or “Chrome”), filed 9 voluntary petitions for relief under chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101 et 10 seq, in the United States Bankruptcy Court for the Eastern District of Missouri (the “Bankruptcy Court”). 11 The Debtors’ chapter 11 cases are being jointly administered under the lead case In re Chrome Holding 12 Co.(f/k/a 23andMe Holding Co.), Case No. 25-40976 (collectively, the “Chapter 11 Cases”). 13 On October 2, 2025, the Bankruptcy Court issued an order (i) preliminarily approving a U.S. data 14 breach settlement agreement involving the Debtors and settlement class representatives; (ii) preliminarily 15 certifying the class for settlement purposes only; (iii) approving the form and manner of notice to class 16 members of the class certification and settlement; (iv) scheduling a fairness hearing to consider final approval 17 of the settlement agreement; and (v) granting related relief. A hearing for the Bankruptcy Court to consider 18 the U.S. data breach settlement agreement on a final basis is scheduled to take place on January 20, 2026. 19 On December 5, 2025, the Bankruptcy Court entered its Findings of Fact, Conclusions of Law, and 20 Amended Order Confirming the Modified Fifth Amended Joint Plan of Chrome Holding Co. and Its Debtor 21 Affiliates Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 1696] (the “Confirmation Order”), 22 confirming the Debtors’ Modified Fifth Amended Joint Plan of Chrome Holding Co. and Its Debtor 23 Affiliates Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 1655] (the “Plan”). The Plan 24 provides, among other things, that as of the Effective Date1 and subject to the occurrence of the Effective 25 26 1 As defined in the Plan, the Effective Date means December 5, 2025, or as soon as reasonably practicable thereafter, on which (a) all conditions to the occurrence of the Effective Date have been satisfied or waived 27 pursuant to Article IX.A and Article IX.B of the Plan, (b) no stay of the Confirmation Order is in effect, and (c) the Debtors declare the Plan effective by filing a notice of the occurrence of the Effective Date on the 28 docket of the Chapter 11 Cases. 1 Case No. 3:24-md-03098-EMC JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 3:24-md-03098-EMC Document 184 Filed 01/02/26 Page 3 of 5 1 Date, except as otherwise specifically provided in the Plan or the Confirmation Order, all persons and 2 entities who have held, hold, or may hold claims that are fully satisfied pursuant to the Plan or any claim 3 that is subject to the releases and exculpations set forth in the Plan, which include any claims arising from 4 or related to the 2023 cyber security incident that is the subject of this proceeding, shall be precluded and 5 permanently enjoined on and after the Effective Date from enforcing, pursuing, or seeking any setoff or 6 relief with respect to such claims, except for the receipt of the payments or distributions that are 7 contemplated by the Plan (the “Injunction”). The relief contemplated by the Injunction includes, among 8 other things, commencing or continuing in any manner any action or other proceeding of any kind on 9 account of or in connection with or with respect to any such claims. 10 On December 9, 2025, the post-Effective Date Debtors (the “Wind-Down Debtors”) filed the 11 Amended Notice of (I) Entry of Order Confirming the Modified Fifth Amended Joint Plan of Chrome 12 Holding Co. and Its Debtor Affiliates Pursuant to Chapter 11 of the Bankruptcy Code, (II) Occurrence of 13 Effective Date, and (III) Closing of the Lemonaid Sale Transaction [Docket No. 1709], providing notice of 14 December 5, 2025 as the Effective Date of the Plan. 15 The Final Approval Hearing on the US data breach class settlement is scheduled to be heard in the 16 Bankruptcy Court on January 20, 2026. As such, the Parties request that the Case Management Conference 17 currently scheduled for January 13, 2026 be taken off calendar at this time. The Parties propose to file an 18 updated Status Report on or before February 2, 2026. 19 Dated: January 2, 2026 /s/ Gayle M. Blatt CASEY GERRY FRANCAVILLA BLATT LLP 20 Gayle M. Blatt, SBN 122048 21 110 Laurel Street San Diego, CA 92101 22 Telephone: 619.238.1811; Fax: 619.544.9232 gmb@cglaw.com 23 24 Dated: January 2, 2026 /s/ Cari Campen Laufenberg KELLER ROHRBACK L.L.P. 25 Cari Campen Laufenberg (pro hac vice) 26 1201 Third Avenue, Suite 3400 Seattle, WA 98101 27 Telephone: 206.623.1900; Fax: 206.623.3384 claufenberg@kellerrohrback.com 28 2 Case No. 3:24-md-03098-EMC JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 3:24-md-03098-EMC Document 184 Filed 01/02/26 Page 4 of 5 1 Dated: January 2, 2026 /s/ Norman E. Siegel STUEVE SIEGEL HANSON LLP 2 Norman E. Siegel (pro hac vice) 3 460 Nichols Road, Suite 200 Kansas City, MO 64112 4 Telephone: 816.714.7100; Fax: 816.714.7101 siegel@stuevesiegel.com 5 Interim Co-Lead Class Counsel 6 7 8 Dated: January 2, 2026 /s/ Rebekah S. Guyon GREENBERG TRAURIG, LLP 9 Rebekah S. Guyon, SBN 291037 10 1840 Century Park East, Suite 1900 Los Angeles, CA 90067 11 Telephone: (310) 586-7700 Rebekah.Guyon@gtlaw.com 12 Stephen L. Saxl (pro hac vice) 13 One Vanderbilt Avenue 14 New York, NY 10017 Telephone: (212) 801-8184 15 saxls@gtlaw.com 16 Attorneys for Defendant 23andMe, Inc. 17 18 19 20 21 22 23 24 25 26 27 28 3 Case No. 3:24-md-03098-EMC JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Case 3:24-md-03098-EMC Document 184 Filed 01/02/26 Page 5 of 5 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, and for good cause shown, IT IS ORDERED THAT the 3 January 13, 2026 Further Case Management Conference is vacated at this time. The Parties shall submit 4 an updated Joint Status Report on or before February 2, 2026. 5 6 DATED: 7 8 Hon. Edward M. Chen United States District Court Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 Case No. 3:24-md-03098-EMC JOINT REQUEST FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER