VAILLANCOURT V. DOORDASH: AUTHORIZATION OF A CLASS ACTION FOR SETTLEMENT PURPOSES ONLY

NOTICE OF HEARING TO APPROVE THE SETTLEMENT

Class Action Settlement Notice Regarding the calculation of sales taxes applicable to orders made by DashPass subscribers on the DoorDash Canada Platform

Quebec Superior Court file number: 500-06-001220-231

This notice is issued in accordance with a Quebec Superior Court judgment dated October 17th, 2024, (File No: 500-06-001220-231) authorizing a class action against DoorDash Technologies Canada Inc. (“DoorDash”) for settlement purposes only and ordering that DoorDash contact Class Members by email.

A settlement (the “Settlement”) has been reached, subject to approval of the Superior Court of Quebec, between Thomas Vaillancourt (the “Plaintiff”) and DoorDash in the context of a class action lawsuit commenced by the Plaintiff against DoorDash (the “Class Action”) alleging that DoorDash incorrectly calculated sales taxes on transactions made by DashPass subscribers, contrary to the Consumer Protection Act (the “CPA”).

DoorDash disagrees with the Plaintiff’s interpretation of the CPA and maintains that it was at all times compliant with CPA requirements. The Settlement has been entered for the sole purpose of avoiding the costs and disruption of protracted litigation.

This Settlement may affect your rights, whether you act or not. Please read this notice carefully

BASIC INFORMATION

Why have I received the email inviting me to review this notice?

You are receiving this notice because you are a Quebec resident, and you placed an order for delivery through the DoorDash Canada Platform while being a DashPass subscriber during the Class Period (August 25th 2019 to May 8th 2023). You could be eligible to receive benefits under the Settlement;

The purpose of this notice is to inform you that the Plaintiff and DoorDash have reached a Settlement putting an end to the Class Action. All concerned parties believe that the Settlement is a fair and equitable means of resolving the dispute; Plaintiff and DoorDash will ask the Superior Court of Quebec to approve it.

The Superior Court of Quebec will hold a hearing to determine whether it will approve the Settlement. You may attend the hearing, which will take place on January 15th, 2025, at 9h15, in room 17.09 of the Montreal Courthouse, located at 1 Notre-Dame Street East in Montreal.

What was the purpose of the Class Action?

Plaintiff alleges that DoorDash incorrectly calculated sales taxes on transactions made by DashPass subscribers, the whole act being contrary to the CPA.

These allegations have not been proven in Court and are vigorously denied by DoorDash, whose position is that it has complied at all times with all applicable legislation and that the interpretation of the applicable legislation advanced by the Plaintiff is unfounded, unsustainable and unsupported by the relevant facts.

Who are the class members?

You are a Class Member if you meet all of the following conditions:

  1. You are a Quebec resident;
  2. Between August 25, 2019 and May 8, 2023, you placed an order on the DoorDash Canada Platform while being a DashPass subscriber and paid sales taxes on said order.

SETTLEMENT SUMMARY

What does the settlement provide for?

Without any admission of liability or wrongdoing, and expressly denying the same, for the purpose of avoiding the costs and disruption of protracted litigation, DoorDash agrees to:

● Make available to Class Members who have an active DoorDash account 357,000 $1.00 credits granted automatically on each of the first 357,000 orders placed by Class Members that do not contain alcohol from a date to be determined until all 357,000 Credits have been applied.

If your DoorDash account is no longer active, you can make a request to reactivate your DoorDash account by writing to cansettlementsupport@doordash.com by December 31st, 2024.

In exchange, Class Members (i) acknowledge that the foregoing is in full and complete settlement of the claims of the Class Members; and (ii) agree to give up any claims they have against DoorDash arising from the display of prices, charges and/or fees on the DoorDash Canada Platform, including claims advanced in the Class Action.

OPTING OUT

If you do not wish to be bound by this Settlement for any reason whatsoever, you must take steps to exclude yourself from the Class, which will result in your exclusion from the Settlement

What happens if I exclude myself?

If you exclude yourself:

  1. You will not receive any benefits under the Settlement;
  2. You will not be bound by the Class Action and could exercise valid rights of action; and
  3. You will not be able to object to this Settlement.

What happens if I do not exclude myself?

If you do not exclude yourself:

  1. You may be eligible to receive benefits under this Settlement;
  2. You will be bound by the Class Action;
  3. You will give up the right to take your own legal action against DoorDash; and
  4. You will be able to object to the Settlement.

If you do not exclude yourself and the Settlement is approved, you give up the right to take legal action against DoorDash in respect of the charges paid to DoorDash for the period of August 25th 2019 to May 8th 2023 that were described by DoorDash as sales taxes.

How do I exclude myself?

To exclude yourself, you must send to the clerk of the Superior Court of Quebec, a duly signed request for exclusion containing the following information:

  1. The Court docket number of the Class Action: Vaillancourt v. DoorDash Technologies Canada Inc. C.S.M. 500-06-001220-231;
  2. Your name and contact information;
  3. Your email address associated with your DoorDash account; and
  4. A declaration stating that you wish to exclude yourself from this Class Action.

Unless filed in person at this address, the Request for Exclusion must be sent to the following address and received by the Court before December 31st, 2024:

Greffe de la Cour supérieure du Québec
PALAIS DE JUSTICE DE MONTRÉAL
1 Notre-Dame Street East
Room 1.120
Montreal, Quebec, H2Y 1B5

Reference:
Vaillancourt v. DoorDash Technologies Canada Inc.
500-06-001220-231

The Request for Exclusion must also be transmitted to Class Counsel by electronic mail at (ep@perrieravocats.com) or by regular mail at this address:

Perrier Avocats
Mtre Eric Perrier
10500 Boul. Saint-Laurent
Montréal, QC, H3L 2P4

OBJECTION TO THE SETTLEMENT

You can tell the Court that you do not agree with this Settlement.

How can I tell the Court that I do not agree with this Settlement?

To present your objection to the Court, you must appear at the hearing that will be held on January 15th 2025, at 9h15, in room 17.09 of the Montreal Courthouse, located at 1 Notre-Dame Street East in Montreal.

Do I need a lawyer in order to object to the Settlement?

No. You can object to the Settlement without a lawyer. If you wish to be represented by a lawyer, you may hire one at your own expense.

If I object to the Settlement and it is approved, will I still be eligible for a Redeemable Credit?

Yes. If, despite your objection, the Settlement is still approved, you can still receive the Redeemable Credit if you are eligible.

FOR MORE INFORMATION

How can I obtain more information?

For more information and access to the text of the Settlement, the schedules and the various forms, please go to the Registre des actions collectives:

https://www.registredesactionscollectives.quebec/fr/Consulter/ApercuDemande?NoDossier=500-06-001220-231

Who represents me?

You may contact Class Counsel for more information:

Perrier Avocats
Mtre Eric Perrier
10500 Boul. Saint-Laurent
Montréal, QC, H3L 2P4

In case of discrepancies between this notice and the Settlement, the Settlement shall prevail.

No Class Member other than the representative plaintiff or an intervenor may be required to pay legal costs arising from the Class Action.

The publication and dissemination of this notice has been approved by the Superior Court of Québec