Mobley v. Workday, Inc.

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
DEREK MOBLEY,
Plaintiff,
v.
WORKDAY, INC.,
Defendant.
Case No. 23-cv-00770-RFL
ORDER APPROVING NOTICE PLAN
Re: Dkt. Nos. 204, 205
Plaintiffs have submitted a proposed timeline for the notice plan and additional
information about the plan. (Dkt. No. 204.) Workday has raised several objections to the
proposal. (Dkt. No. 205.) Having reviewed the parties’ submissions, the notice plan is
APPROVED, as described in this Order.
Timeline. Plaintiffs’ proposed timeline is approved, with the following modifications:
December 1–12, 2025 Design webpage; complete instructions on
how to opt-in & contact counsel for
assistance;
December 17, 2025 Complete webpage; provide access to
Workday;
December 17–19, 2025 Meet and confer regarding any remaining
disputes;
December 19, 2025 If necessary, submit joint statement to the
Court regarding any remaining disputes;
December 29, 2025 – January
6, 2026
Complete all prep for media dissemination
launch;
January 6, 2026 – March 7,
2026
Launch media dissemination of notice &
opt-in process; all opt-in consent forms
must be submitted by collective members
to Plaintiffs’ counsel and dated no later
than March 7, 2026;
March 23, 2026 Complete filing of consolidated opt-in
consent forms with the Court.
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Consolidated Opt-In Form. After the time to opt in has closed, Plaintiffs’ counsel shall file a
single PDF document containing the first page of all of the opt-in consent to join forms they
received between January 6, 2026 and March 7, 2026. The PDF may be broken into sub-parts if
necessary to comply with ECF file size restrictions. During the notice period, Plaintiffs’ counsel
shall not file individual consent to join forms on the docket.
Website URL. The URL “workdaycase.com” is approved. The URL accurately describes the
website and is not misleading or likely to confuse users.
Social Media Profiles. To the extent there is a dispute regarding the language used for the
“bios,” “overviews,” “taglines,” and any pinned posts, Plaintiffs must use the previously
approved short form notice language, but Plaintiffs are free to select any version of the approved
short form notice language they prefer. However, Plaintiffs may not “reus[e] different
combinations of the same words,” they must use the actual language approved. The profiles
shall not link directly to any pdf documents—users should be routed to the hosted website to
avoid confusion. For Organization Type, where available “Public & Government Service”
should be selected. For LinkedIn, Plaintiffs’ counsel shall select either “Privately Held” or
“Partnership” depending on which best reflects counsel’s organizational structure.
Social Media Ads. The Court has already approved short form notice language, including
headlines and descriptions. Plaintiffs must use the previously approved short form notice
language and may not “reus[e] different combinations of the same words.” Plaintiffs’ proposed
images (Dkt. No. 204 at 34–37) are approved for use in the social media ads and profiles.
IT IS SO ORDERED.
Dated: December 2, 2025
RITA F. LIN
United States District Judge
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