NOTICE OF FILING A MOTION TO APPROVE A SETTLEMENT AGREEMENT
Pursuant to the Israeli Class Actions Law, 5766-2006 (the "Class Actions Law")

Pursuant to Sections 18(c) and 25(a)(3) of the Class Actions Law, the public is hereby notified that on September 12, 2025, a motion to approve a settlement agreement (the "Settlement Agreement") was filed with the Central District Court in Lod (the "Court"). The Settlement Agreement was executed in connection with a motion to certify a class action (Class Action (Central) 11665-12-21; the "Certification Motion"), filed by My Parents Ltd. (the "Petitioner") against Google Ireland Limited ("Google").

The Certification Motion pertains to the Google Ads advertising service. The Petitioner, an advertiser using Google Ads, alleged that advertisers received a service different from the one they purchased. According to the allegations, although advertisers requested a Search campaign from which Display ads were excluded, Google in practice also served Display ads and charged them at the cost of Search ads. The Petitioner alleged that, according to Google's definitions in its systems, Search ads are ads that appear following a query typed into Google's search engine, and that the ads actually served and paid for were not such ads.

In response, Google argued that, contrary to the allegations in the Certification Motion, the service that the Members of the Class received matches the service they requested. Google argued in its response to the Certification Motion that the ads referenced by the Petitioner - which were displayed on websites known as "Parked Domains" - are ads served on websites that are external to Google's search engine, known as "Search Partners." According to Google, the ads provided to the Petitioner are Search ads for all intents and purposes, which are displayed to users similarly to Search ads appearing in Google's search engine results - as a result of an active search performed by a user.

For settlement purposes only, and without any admission by any party of the other party's claims, the Parties reached the understandings set forth in the Settlement Agreement, which are summarized below:

Definition of the Class: all persons and entities using Google Ads, with a billing address in Israel, that had at least one Search Campaign in which (a) the Include Google Display Network option was not checked, and (b) the advertiser was charged an amount exceeding 0 NIS for ads that were served on Qualified Pages (Parked Domains and Related Search for Content (RSoC)) pages) ("Members of the Class").

Effective Period for purposes of the Settlement Agreement: with regard to Parked Domains - the period beginning on December 6, 2014 and terminating on October 31, 2024; with regard to RSoC - the period beginning on December 6, 2014 and terminating on May 23, 2025 (the "Effective Period").

Monetary Relief: the Parties agreed that, for settlement purposes only, and without any admission of liability, Google shall pay an amount equal to 33% of the Eligible Spend (as defined in the Settlement Agreement; the "Settlement Amount"). Accordingly, each Eligible Member is entitled to receive an amount equal to 33% of its Personal Eligible Spend (each as defined in the Settlement Agreement). In addition, it was agreed that any NIS amounts charged will be indexed either to a USD/ILS exchange rate of NIS 3.8 per USD 1, or to the relevant historical USD/ILS exchange rate on the date the spend occurred, whichever is higher (based on the Bloomberg index). The additional value generated by this calculation will be added to and included in the Settlement Amount to be distributed among Eligible Members (as defined below).

The Settlement Agreement distinguishes between an "Active Advertiser" (a Member of the Class who has had spend on ads exceeding 0 NIS in at least one of its Google Ads accounts within the twelve (12) months prior to the Approval Date) and an "Inactive Advertiser" (a Member of the Class who has not had such spend).

A Member of the Class will be eligible for compensation if it qualifies for a monetary payment of at least: (a) 1 USD if it is an Active Advertiser (an "Eligible Active Member"); or (b) 10 USD if it is an Inactive Advertiser (an "Eligible Inactive Member"; together: "Eligible Members").

Payment mechanism for Eligible Active Members: payment will be granted by credit applied directly to their Google Ads accounts. Such Members may use the credited funds for continued use of Google Ads or, alternatively, withdraw the credited funds from their accounts, as detailed in the Settlement Agreement.

Payment mechanism for Eligible Inactive Members: Google will send three email messages informing Eligible Inactive Members of their eligibility to receive payment via wire transfer to their bank account, and requesting that they provide the necessary information for payment processing, in accordance with the instructions that will be provided in the email messages.

Remuneration and Attorneys' Fees: the Parties recommended that the remuneration to the Petitioner and the attorneys' fees to its counsel be determined according to tiered percentages of the Settlement Amount, starting at 25% for the first tier and down to 8% for the last tier (subject to a 5% discount on the total amount), plus VAT. In addition, the Parties agreed on reimbursement of expenses in the amount of NIS 87,240 plus VAT.

Waiver of Claims and Res Judicata: subject to approval, the Settlement Agreement will establish res judicata in favor of Google and its affiliated parties (as defined in the Settlement Agreement) vis-a-vis the Petitioner and the Members of the Class with respect to all causes of action asserted in the Certification Motion, the Claim, and the Petitioner's Reply, with regard to ads served on Qualified Pages during the Effective Period, except for Members of the Class who submitted opt-out notices (as defined below) that are approved by the Court (if any).

Filing an Objection or Opting Out: any person included in the Members of the Class, as well as any person or entity listed in Section 18(d) of the Class Actions Law, may file a reasoned objection to the Settlement Agreement with the Court within forty-five (45) days. In addition, by that date, any Member of the Class may request the Court, pursuant to Section 18(f) of the Class Actions Law, to permit it to opt out of the class to which the Settlement Agreement will apply (an "Opt-Out Request"). An Opt-Out Request shall be filed with the Clerk of the Central District Court in Lod, in Class Action 11665-12-21. Any Member of the Class who does not file an Opt-Out Request by the above date will be deemed to have agreed to be included in the class and to be bound by the Settlement Agreement.

The above is only a summary of the Settlement Agreement. In any event of any inconsistency between the above description and the provisions of the Settlement Agreement filed with the Court, the provisions of the Settlement Agreement shall prevail.

Review of the Settlement Agreement: the Settlement Agreement and the motion for its approval are available for review by Members of the Class on the website of Petitioner’s counsel, and at the offices of counsel for both Parties, by prior appointment:

Petitioner’s Counsel - Gil Ron, Keinan & Co., The Museum Tower, 4 Berkovitz St., Tel Aviv 6423806; website: www.ronlaw.co.il.

Google’s Counsel - Fischer (FBC & Co.), 146 Menachem Begin Road, Tel Aviv-Yafo 6492103. Tel.: 03-6941348; Fax: 03-6944242.

In addition, the Settlement Agreement may be reviewed here. Eligible Members may also contact Google via the following link: https://support.google.com/google-ads/gethelp with any questions they may have with respect to the Settlement Agreement.

The text of this notice was approved by the Court and is published pursuant to the Court's decision.