EXHIBIT 1

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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

THI MILLER, individually and on behalf of 

all others similarly situated,

Plaintiff,

v.

RED BULL NORTH AMERICA, INC., a 

California corporation,

Defendant.

Case No. 12-cv-04961

[Hon. Judge St. Eve]

DECLARATION OF JAY EDELSON

Pursuant to 28 U.S.C. § 1746, I Jay Edelson, hereby declare and state as follows: 

1. I am over the age of eighteen and am fully competent to make this declaration. I 

make this declaration based upon personal knowledge unless otherwise indicated. If called upon 

to testify, I could and would competently do so.

2. I am an attorney admitted to practice in the State of Illinois and in the United 

States District Court for the Northern District of Illinois, and other federal district courts. I am 

making this declaration in support of Plaintiff’s Uncontested Motion for Approval of Attorney’s 

Fees, Expenses, and Incentive Award.

3. I am the Managing Partner of the law firm Edelson LLC. Edelson LLC was 

retained by Plaintiff Thi Miller for the purpose of bringing this litigation and I, along with other 

members of my firm, have been appointed Class Counsel in this case.

4. My firm has extensive experience prosecuting class actions and other complex 

litigation of similar nature, scope, and complexity, and also has intimate knowledge of the law in 

the field of cellular telephony and has been a pioneer in the field of consumer class actions 

involving the transmission unauthorized text messages under the TCPA. The first federal Circuit 

Court opinion authorizing consumer suits for unauthorized text messages was litigated by the 

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predecessor firm to Edelson LLC, and subsequent reported opinions in federal courts in 

California, Illinois, and other federal districts around the country have also been secured by the 

attorneys at Edelson LLC. Edelson LLC and its predecessors have litigated and settled several 

substantial text message class actions under the TCPA, including: Weinstein v. The Timberland; 

Co., et al. (N.D. Ill. 2008); Satterfield v. Simon & Schuster (N.D. Cal. 2010); Lozano v. 

Twentieth Century Fox (N.D. Ill. 2011); Kramer v. Autobytel (N.D. Cal. 2011); and Rojas v. 

Career Education Corporation (N.D. Ill. 2012). 

5. A true and accurate copy of the Edelson LLC Firm Resume is attached hereto as 

Exhibit 1-A.

6. At the time of filing this case, I was aware that my firm would spend hundreds, if 

not thousands, of hours on attorney time in contested litigation with no guarantee of success.

7. Defendant Red Bull North America, Inc. (“Red Bull”) retained the law firm of 

Kirkland & Ellis LLP, a national law firm, to represent them in this case.

8. Over the past year, members of my firm have spent over 877 hours representing 

the Plaintiff and the Settlement Class without any compensation. Performing work on this case 

required my firm to forgo other potential matters and employment.

9. Following their Rule 26(f) conference, the Parties exchanged initial disclosures, 

and Plaintiff propounded discovery on Defendant and other third parties. It was at this juncture 

that the Parties agreed to attempt to resolve this litigation through private mediation. In the 

weeks leading up to mediation, the Parties informally exchanged certain documents and other 

information that would be needed to effectively engage in the mediation process.

10. On November 6-7, 2012, the Parties met for a formal mediation with former 

District Judge Wayne Andersen. After two days of mediation, additional exchanges of 

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information, and several rounds of arm’s-length negotiations—all with the assistance of Judge 

Andersen—the Parties made a great deal of progress toward a classwide settlement, but were still 

unable to come to terms. Certain issues remained unresolved, and while the Parties agreed to 

continue talking, they did not commit to any further mediation sessions. 

11. After several additional rounds of negotiations (all at arm’s-length and presided 

over by Judge Andersen) that took place over the course of the next two months, the Parties 

agreed to another in-person mediation session, which took place on January 10, 2013. Although 

the Parties were able to agree on the principal terms of class relief at that time, they reached an 

impasse on remaining issues. 

12. Judge Andersen convened another mediation session on February 25, 2013. With 

Judge Andersen’s assistance, the Parties were able to resolve all remaining issues. Notably, 

however, the Parties did not agree—much less even discuss— any amount of attorneys’ fees 

payable to Class Counsel. Rather, Class Counsel—determined to not delay the relief to the Class 

with continued negotiations over attorneys’ fees— agreed to simply file a fee petition with the 

Court and committed to not seek more than $2,000,000 in attorneys’ fees and costs.

13. On June 13, 2013—the deadline to file their fee petition—and again with Judge 

Andersen’s assistance through separate telephone conferences, the Parties finally came to an 

agreement on attorneys’ fees and costs in the amount of $1,275,000.00, subject to Court 

approval.

14. Class Counsel’s requested fee award represents only 21% of the $6,000,000 made 

available to fund the Settlement.

15. Awarding fees based on a percentage of the overall fund made available to the 

Class is supported by Plaintiff’s retainer agreement with Class Counsel, as well as fee awards in 

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similar class actions within this District. A true and accurate copy of Plaintiff Miller’s executed 

retention letter with Edelson LLC is attached hereto as Exhibit 1-B.

16. By taking this case on a contingency basis and not being paid by the hour, my 

firm had an incentive to conduct our efforts efficiently. So too, being responsible for advancing 

all expenses, we had an incentive not to expend funds unnecessarily.

17. The retainer agreement between Class Counsel and Plaintiff contains a 

contingency fee arrangement whereby Plaintiff previously agreed that a “fair award of attorneys’ 

fees from a fund recovered for the class would be one-third of the total recovery plus 

reimbursement of all costs.” (See Ex. B.)

18. I believe that my firm assumed a significant risk of non-payment in initiating and 

prosecuting this case given the novelty of the legal issues involved and the vigorous defense that 

Defendant and its highly skilled counsel were prepared to mount should the litigation have 

proceeded on.

19. Class Counsel was also threatened with the possibility that Red Bull would 

ultimately prevail on its “direct relationship” argument—i.e., that each Class Member consented 

to receive future text messages when they voluntarily provided Red Bull with their cell phone 

numbers. Further, Class Counsel’s fronting of attorney time and the costs of litigation in this case 

on a fully contingent basis was especially risky because the issue of whether the TCPA applies to 

text messages has yet to be presented to the Seventh Circuit. Equally untested is whether the 

type of equipment used to transmit en masse text messages falls within the TCPA’s statutory 

definition of “automatic telephone dialing system.”

20. As is the general practice of most law firms, each of the attorneys and law clerks 

at Edelson LLC are responsible for keeping track of their billable time. The majority of these 

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records are centralized in a billing management software program, to which all employees have 

access, known as “Freshbooks.” 

21. The attorney rates listed are the same as those Class Counsel charges to their 

hourly clients, and are comparable to (or less than) those charged by attorneys in Chicago with 

similar background or experience. Moreover, these rates have been approved as reasonable by 

several judges in this District, as well as in other federal courts throughout the country, in both 

TCPA cases and other class action litigation.

22. The rates charged for our attorneys are the same rates we use for hourly clients, 

which comprise a material part of the firm’s revenues. The hours, rates, and experience of the 

particular attorneys from my firm involved in this matter are provided in the chart below: 

ATTORNEY

(Position)

YEARS OF 

PRACTICE

HOURS RATE TOTAL

Jay Edelson 

(Managing Partner)

16 114.7 $675.00 $77,422.50

Rafey S. Balabanian 

(Partner) 

7 96.1 $550.00 $52,855.00

Ari J. Scharg 

(Associate)

4 308.5 $425.00 $131,112.50

Eve-Lynn Rapp

(Associate)

3 80.8 $390.00 $31,512.00

Megan Lindsey 

(Associate)

1 57.1 $335.00 $19,128.50

Amir Missaghi 

(Incoming Associate)

N/A 220.0 $215.00 $47,300.00

Estimated Time Remaining $80,000.00

TOTAL $439,330.50

23. Based on my experience, I anticipate that approximately 200 hours equaling about 

$80,000.00 of additional attorney and non-attorney time will be required through final approval 

and administration of the settlement, should it be approved by the Court. The attorneys handling 

this matter must still draft a final approval motion, prepare and attend the final fairness hearing, 

contend with any potential objectors, continue to communicate with Class Members, and handle 

various issues related to claims administration.

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24. In addition to this amount, Edelson LLC has also incurred $16,480.02 in 

unreimbursed costs and expenses, which includes costs related to the initial filing, discovery, 

subpoena production, mediation, transportation, and large copying jobs. A true and accurate 

copy of my firm’s expense records are attached as Exhibit 1-C. My firm does not typically 

charge for such things as Westlaw or LexisNexis research, which we adhered to in this case.

25. Until the settlement was reached, there was no pre-existing agreement or 

discussion concerning an award or the potential for an award in exchange for the Class 

Representative’s involvement in the case.

26. Nonetheless, Ms. Miller contributed her own time and effort in pursuing both her 

individual claim as well as the class claims, exhibiting a willingness to participate and undertake 

the responsibilities and risks attendant with bringing a representative action. Early in the case, 

Ms. Miller even relinquished control of her personal cell phone (which received the text 

messages at issue) so that Class Counsel could create a mirror image of its hard drive and 

preserve relevant evidence.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 13, 2013, at Chicago, Illinois,

Jay Edelson

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EXHIBIT 1-A

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EDELSON LLC FIRM RESUME

EDELSON LLC is a plaintiff’s class action and commercial litigation firm with attorneys in 

Illinois, Colorado, and California. 

Our attorneys have been recognized as leaders in these fields by state and federal 

legislatures, national and international media groups, the courts, and our peers. Our reputation 

for leadership in class action litigation has led state and federal courts to appoint us lead counsel 

in many high-profile class action suits, including the recent Thomas the Tank Engine lead paint 

class actions, the AT&T mobile content class actions, the home equity credit reduction cases, 

and privacy class actions involving T-Mobile, Facebook, and Netflix. We have testified before 

the United States Senate on class action issues and have repeatedly been asked to work on 

federal and state legislation involving cellular telephony, privacy and other issues. Our attorneys 

have appeared on dozens of national and international television and radio programs to discuss 

our cases and class action and consumer protection issues more generally. Our attorneys speak 

regularly at seminars on consumer protection and class action issues, lecture on class actions at 

law schools and are asked to serve as testifying experts in cases involving class action and 

consumer issues. 

PLAINTIFFS’ CLASS AND MASS ACTION PRACTICE GROUP

EDELSON LLC is a leader in plaintiffs’ class and mass action litigation, with a particular 

emphasis on technology class actions, and has been called a “class action ‘super firm’” by a 

national organization. (Decalogue Society of Lawyers, Spring 2010.) As has been recognized 

by federal courts, our firm has an “extensive histor[y] of experience in complex class action 

litigation, and [is a] well-respected law firm[] in the plaintiffs’ class action bar.” In re Pet Food 

Prod. Liab. Litig., MDL Dkt. No. 1850, No. 07-2867 (NLH) (D.N.J. Nov. 18, 2008). A leading 

arbitrator concurred: “The proof of [the firm’s] experience, reputation, and abilities is 

extraordinary. . . . Each [of their cases] elaborates on the experience and unique success [they] 

have had in achieving leading roles in the area of 'technology consumer protection class 

actions.'” (Arbitration award in mobile content class action settlement, August 6, 2009) In 

appointing our firm interim co-lead in one of the most high profile cases in the country, a federal 

court pointed to our ability to be “vigorous advocates, constructive problem-solvers, and civil 

with their adversaries." -In Re JPMorgan Chase Home Equity Line of Credit Litig., No. 10 C 

3647 (N.D. Ill, July 16, 2010). 

We have been specifically recognized as "pioneers in the electronic privacy class action 

field, having litigated some of the largest consumer class actions in the country on this issue." In 

re Facebook Privacy Litig., No. C 10-02389 (N.D. Cal) (order appointing the firm interim colead of privacy class action); see also In re Netflix Privacy Litigation, 5:11-cv-00379 (N.D. Cal. 

Aug. 12, 2011) (appointing the sole lead counsel due, in part, to its “significant and particularly 

specialized expertise in electronic privacy litigation and class actions[.]”) 

We have several sub-specialties within our plaintiffs’ class and mass action practice 

group: 

Consumer Technology Class Actions: We have established the key precedent under the 

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Telephone Consumer Protection Act concerning text message spam, resulting in multiple 

eight figure settlements in recent years. We have prosecuted over 100 cases involving 

mobile content, settling numerous nationwide class actions, including against industry 

leader AT&T Mobility, collectively worth over a hundred million dollars. 

Representative Settlements:

• McFerren v. AT&T Mobility, LLC, No. 08-CV-151322 (Fulton County 

Sup. Ct., GA): Lead counsel class action settlement involving 16 related 

cases against largest wireless service provider in the nation. “No cap” 

settlement provided virtually full refunds to a nationwide class of 

consumers who alleged that unauthorized charges for mobile content were 

placed on their cell phone bills.

• Paluzzi v. Cellco Partnership, No. 07 CH 37213 (Cook County, Illinois): 

Lead counsel in class action settlement involving 27 related cases alleging 

unauthorized mobile content charges. Case settled for $36 million.

• Lozano v. 20th Century Fox, No. 09-cv-05344 (N.D. Ill): Lead counsel in 

class action alleging that defendants violated federal law by sending 

unsolicited text messages to cellular telephones of consumers. Case 

settled for $16 million.

• Gray v. Mobile Messenger Americas, Inc., No. 08-CV-61089 (S.D. Fla.): 

Lead counsel in case alleging unauthorized charges were placed on cell 

phone bills. Case settled for $12 million.

• Parone v. m-Qube, Inc. No. 08 CH 15834 (Cook County, Illinois): Lead 

counsel in class action settlement involving over 2 dozen cases alleging 

the imposition of unauthorized mobile content charges. Case settled for 

$12.254 million.

• Rojas v CEC, No. 1:10-cv-05260 (N.D. Ill): Lead counsel in class action 

alleging that defendants violated federal law by sending unsolicited text 

messages to cellular telephones of consumers. Case settled for 

$19,999,400.

• Kramer v. B2Mobile, et al, No. 0-cv-02722-CW (N.D. Cal.): Lead 

counsel in class action alleging that defendants violated federal law by 

sending unsolicited text messages to cellular telephones of consumers. 

Case settled for $12.2 million.

• Satterfield v. Simon & Schuster, No. C 06 2893 CW (N.D. Cal.). Co-lead 

counsel in class action alleging that defendants violated federal law by 

sending unsolicited text messages to cellular telephones of consumers. 

Case settled for $10 million.

• Williams, et al. v. Motricity, Inc. et al., Case No. 09 CH 19089 (Cook 

County, Illinois): Lead counsel in class action settlement involving 24 

cases alleging the imposition of unauthorized mobile content charges. 

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Case settled for $9 million.

• VanDyke v. Media Breakaway, LLC, No. 08 CV 22131 (S.D. Fla.): Lead 

counsel in class action settlement alleging unauthorized mobile content 

charges. Case settled for $7.6 million.

• Weinstein, et al. v. Airit2me, Inc., Case No. 06 C 0484 (N.D. Ill): Co-lead 

counsel in class action alleging that defendants violated federal law by 

sending unsolicited text messages to cellular telephones of consumers. 

Case settled for $7 million.

• Gresham v. Cellco Partnership, No. BC 387729 (Los Angeles Sup. Ct.): 

Lead counsel in case alleging unauthorized charges were placed on cell 

phone bills. Settlement provided class members with full refunds.

• Duffy v. Nevis Mobile, LLC, No. 08 CH 21376 (Cook County, IL): Class 

counsel in certified class action against mobile content provider for 

unauthorized mobile content charges resulting in default judgment over 

$10 million.

• Zurakov v. Register.com, No. 01-600703 (New York County, NY): Colead counsel in a class action brought on behalf of an international class of 

over one million members against Register.com for its deceptive practices 

in registering Internet domain names. Settlement required Register.com to 

fully disclose its practices and provided the class with relief valued in 

excess of $17 million.

Privacy/Data Loss Class Actions: We have litigated numerous class actions involving 

issues of first impression against Facebook, Apple, Netflix, Sony, Red Box, Pandora, 

Sears, Storm 8, Google, T-Mobile, Microsoft and others involving the failure to protect 

customers’ private information, some resulting from security breaches. 

Representative Cases:

• In re Netflix Privacy Litigation, 5:11-cv-00379 (N.D. Cal.): Sole lead 

counsel in suit alleging that defendant violated the Video Privacy 

Protection Act by illegally retaining customer viewing information. $9 

million dollar cy pres settlement has been preliminarily approved.

• In re Facebook Privacy Litigation, 10-cv-02389 (N.D. Cal.): Appointed 

co-lead counsel in suit alleging that Facebook unlawfully shared its users' 

sensitive personally identifiable information with Facebook's advertising 

partners. 

• Standiford v. Palm, No. 5:09-cv-05719-LHK (N.D. Cal.): Sole lead 

counsel in data loss class action, resulting in $640,000 settlement.

• In re Zynga Privacy Litigation, 10-cv-04680 (N.D. Cal.): Appointed colead counsel in suit against gaming application designer for the alleged 

unlawful disclosure of its users' personally identifiable information to 

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advertisers and other third parties.

• Gaos v. Google, 10-cv-04809 (N.D. Cal.): Part of a team of attorneys in 

suit alleging that Google unlawfully disclosed its users' search queries to 

website owners and other third parties.

• In re Sidekick Litig., No. C 09-04854-JW (N.D. Cal.): Co-lead counsel in 

cloud computing data loss case against T-Mobile and Microsoft. 

Settlement provided the class with potential settlement benefits valued at 

over $12 million.

• Abrams v. Facebook, Inc., No. 07-05378 (N.D. Cal.): Lead counsel in 

injunctive settlement concerning the transmission of allegedly 

unauthorized mobile content.

• Desantis v. Sears, 08 CH 00448 (Cook County, IL): Lead counsel in 

injunctive settlement alleging national retailer allowed purchase 

information to be publicly available through the internet.

Products Liability Class Actions: We have been appointed lead counsel in state and 

federal products liability class settlements, including a $30, million settlement resolving 

the “Thomas the Tank Engine” lead paint recall cases and a $32 million settlement 

involving the largest pet food recall in the history of the United States and Canada.

Representative Settlements:

• Barrett v. RC2 Corp., No. 07 CH 20924 (Cook County, IL): Co-lead 

counsel in lead paint recall case involving Thomas the Tank toy trains. 

Settlement is valued at over $30 million and provided class with full cash 

refunds and reimbursement of certain costs related to blood testing.

• In re Pet Food Products Liability Litig., No. 07-2867 (D. N.J.): Part of 

mediation team in class action involving largest pet food recall in United 

States history. Settlement provided $24 million common fund and $8 

million in charge backs.

Banking Class Actions: EDELSON LLC has been at the forefront of class action 

litigation arising in the aftermath of the federal bailouts of the banks. Its suits include 

claims that the certain banks unlawfully suspended home credit lines based on pre-textual 

reasons, and that certain banks have failed to honor loan modification programs. We 

achieved the first federal appellate decision in the country recognizing the right of 

borrowers to enforce HAMP trial plans under state law. The court noted that "Prompt 

resolution of this matter is necessary not only for the good of the litigants but for the 

good of the Country." Wigod v. Wells Fargo Bank, N.A., 673 F.3d 547, 586 (7th Cir. 

2012) (Ripple, J., concurring).

Representative Cases:

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• Hamilton v. Wells Fargo Bank, N.A., 4:09-cv-04152-CW (N.D. Cal.). 

Lead counsel in class actions challenging Wells Fargo’s suspensions of 

home equity lines of credit. Nationwide settlement restores access to over 

$1 billion in credit and provides industry leading service enhancements 

and injunctive relief.

• In re JP Morgan Chase Bank Home Equity Line of Credit Litig., 10-cv3647 (N.D. Ill.): Court appointed interim co-lead counsel in nationwide 

putative class action alleging illegal suspensions of home credit lines.

• Levin v. Citibank, N.A., C-09-0350 MMC (N.D. Cal.): Court appointed 

interim co-lead counsel in nationwide putative class action alleging illegal 

suspensions of home credit lines. Preliminarily-approved settlement 

restores hundreds of millions of dollars in credit in addition to cash 

payments.

• Wigod v. Wells Fargo, No. 10-cv-2348 (N.D. Ill.): suing to enforce 

HAMP trial plans.

• Settled numerous consumer class actions alleging fraud or other 

unconscionable behavior by banks and other lenders.

General Consumer Protection Class Actions: We have successfully prosecuted 

countless class action suits against computer software companies, technology companies, 

health clubs, dating agencies, phone companies, debt collectors, and other businesses on 

behalf of consumers.

Representative Settlements:

• Van Tassell v. UMG, No. 1:10-cv-2675 (N.D. Ill): Lead counsel in 

negative option marketing class action. Case settled for $2.85 million.

• McK Sales Inc. v. Discover Bank, No. 1:10-cv-02964 (N.D. Ill): Lead 

counsel in class action alleging deceptive marketing aimed at small 

businesses. Case settled for $6 million.

• Farrell v. OpenTable, No 3:11-cv-01785-si (N.D. Cal.): Lead counsel in 

gift certificate expiration case. Settlement netted class over $3 million in 

benefits.

• Ducharme v. Lexington Law, No. 10-cv-2763-crb (N.D. Cal): Lead 

counsel in CROA class action. Settlement resulted in over $6 million of 

benefits to the class.

• Drymon v. Cyberdefender, No. 11 CH 16779 (Cook County, IL): Lead 

counsel in class action alleging that defendant deceptively designed and 

marketed its computer repair software. Case settled for $9.75 million.

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• Pulcini v. Bally Total Fitness Corp., No. 05 CH 10649 (Cook County, IL): 

Co-lead counsel in four class action lawsuits brought against two health 

clubs and three debt collection companies. A global settlement provided 

the class with over $40 million in benefits, including cash payments, debt 

relief, and free health club services.

• Kozubik v. Capital Fitness, Inc., 04 CH 627 (Cook County, IL): Co-lead 

counsel in state-wide suit against a leading health club chain, which settled 

in 2004, providing the over 150,000 class members with between $11 

million and $14 million in benefits, consisting of cash refunds, full debt 

relief, and months of free health club membership.

• Kim v. Riscuity, No. 06 C 01585 (N.D. Ill): Co-lead counsel in suit 

against a debt collection company accused of attempting to collect on 

illegal contracts. The case settled in 2007, providing the class with full 

debt relief and return of all money collected.

• Jones v. TrueLogic Financial Corp., No. 05 C 5937 (N.D. Ill): Co-lead 

counsel in suit against two debt collectors accused of attempting to collect 

on illegal contracts. The case settled in 2007, providing the class with 

approximately $2 million in debt relief.

• Fertelmeyster v. Match.com, No. 02 CH 11534 (Cook County, IL): Colead counsel in a state-wide class action suit brought under Illinois 

consumer protection statutes. The settlement provided the class with a 

collective award with a face value in excess of $3 million.

• Cioe v. Yahoo!, Inc., No. 02 CH 21458 (Cook County, IL): Co-lead 

counsel in a state-wide class action suit brought under state consumer 

protection statutes. The settlement provided the class with a collective 

award with a face value between $1.6 million and $4.8 million. 

Insurance Class Actions: We have prosecuted and settled multi-million dollar suits 

against J.C. Penney Life Insurance for allegedly illegally denying life insurance benefits 

under an unenforceable policy exclusion and against a Wisconsin insurance company for 

terminating the health insurance policies of groups of self-insureds.

Representative Settlements:

• Holloway v. J.C. Penney, No. 97 C 4555, (N.D. Ill.): One of the primary 

attorneys in a multi-state class action suit alleging that the defendant 

illegally denied life insurance benefits to the class. The case settled in or 

around December of 2000, resulting in a multi-million dollar cash award 

to the class.

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• Ramlow v. Family Health Plan (Wisc. Cir. Ct., WI): Co-lead counsel in a 

class action suit challenging defendant's termination of health insurance to 

groups of self-insureds. The plaintiff won a temporary injunction, which

was sustained on appeal, prohibiting such termination and eventually 

settled the case ensuring that each class member would remain insured.

Mass/Class Tort Cases: Our attorneys were part of a team of lawyers representing a 

group of public housing residents in a suit based upon contamination related injuries, a 

group of employees exposed to second hand smoke on a riverboat casino, and a class of 

individuals suing a hospital and national association of blood banks for failure to warn of 

risks related to blood transfusions.

Representative Cases:

• Aaron v. Chicago Housing Authority, 99 L 11738, (Cook County, IL): 

Part of team representing a group of public housing residents bringing suit 

over contamination-related injuries. Case settled on a mass basis for over 

$10 million.

• Januszewski v. Horseshoe Hammond, No. 2:00CV352JM (N.D. Ind.): 

Part of team of attorneys in mass suit alleging that defendant riverboat 

casino caused injuries to its employees arising from exposure to secondhand smoke.

The firm's cases regularly receive attention from local, national, and international media. 

Our cases and attorneys have been reported in the Chicago Tribune, USA Today, the Wall Street 

Journal, the New York Times, the LA Times, by the Reuters and UPI news services, and BBC 

International. Our attorneys have appeared on numerous national television and radio programs, 

including ABC World News, CNN, Fox News, NPR, and CBS Radio, as well as television and 

radio programs outside of the United States. We have also been called upon to give 

congressional testimony and other assistance in hearings involving our cases.

GENERAL COMMERCIAL LITIGATION

Our attorneys have handled a wide range of general commercial litigation matters, from 

partnership and business-to-business disputes, to litigation involving corporate takeovers. We 

have handled cases involving tens of thousands of dollars to “bet the company” cases involving 

up to hundreds of millions of dollars. Our attorneys have collectively tried hundreds of cases, as 

well as scores of arbitrations and mediations. All of our attorneys have regularly practiced in 

state and federal trial and appellate courts.

OUR ATTORNEYS

JAY EDELSON is the founder and Managing Partner of EDELSON LLC. He has been 

recognized as a leader in class actions, technology law, corporate compliance issues and 

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consumer advocacy by his peers, the media, state and federal legislators, academia and courts 

throughout the country.

Jay has been appointed lead counsel in numerous state, federal, and international class actions, 

resulting in hundreds of millions of dollars for his clients. He is regularly asked to weigh in on 

federal and state legislation involving his cases. He testified to the U.S. Senate about the largest 

pet food recall in the country's history and is advising state and federal politicians on consumer 

issues relating to the recent federal bailouts, as well as technology issues, such as those involving 

mobile marketing. Jay also counsels companies on legal compliance and legislative issues in 

addition to handling all types of complex commercial litigation.

Jay has litigated class actions that have established precedent concerning the ownership rights of 

domain name registrants, the applicability of consumer protection statutes to Internet businesses, 

and the interpretation of numerous other state and federal statutes including the Telephone 

Consumer Protection Act and the Video Privacy Protection Act. As lead counsel, he has also 

secured settlement in cases of first impression involving Facebook, Microsoft, AT&T and 

countless others, collectively worth hundreds of millions of dollars. 

In addition to technology based litigation, Jay has been involved in a number of high-profile 

"mass tort" class actions and product recall cases, including cases against Menu Foods for selling 

contaminated pet food, a $30 million class action settlement involving the Thomas the Tank toy 

train recall, and suits involving damages arising from second-hand smoke.

In 2009, Jay was named one of the top 40 Illinois attorneys under 40 by the Chicago Daily Law 

Bulletin. In giving Jay that award, he was heralded for his history of bringing and winning 

landmark cases and for his “reputation for integrity” in the “rough and tumble class action 

arena.” In the same award, he was called “one of the best in the country” when it “comes to legal 

strategy and execution.” Also in 2009, Jay was included in the American Bar Association’s “24 

hours of Legal Rebels” program, where he was dubbed one of “the most creative minds in the 

legal profession” for his views of associate training and firm management. In 2010, he was 

presented with the Annual Humanitarian Award in recognition of his “personal integrity, 

professional achievements, and charitable contributions” by the Hope Presbyterian Church. In 

2011, he was selected as an Illinois Super Lawyer and, separately, as a top Illinois class action 

lawyer by Benchmark Plaintiff.

Jay is frequently asked to participate in legal seminars and discussions regarding the cases he is 

prosecuting, including serving as panelist on national symposium on tort reform and, separately, 

serving as a panelist on litigating high-profile cases. He has also appeared on dozens of 

television and radio programs to discuss his cases. He has taught classes on class action law at 

Northwestern Law School and The John Marshall Law School, and has co-chaired a 2-day 

national symposium on class action issues. He has been an adjunct professor, teaching a seminar 

on class action litigation at Chicago-Kent College of Law since 2010.

Jay is a graduate of Brandeis University and the University of Michigan Law School.

RYAN D. ANDREWS is a Partner at EDELSON LLC, and the Chair of the Telecommunications 

Practice Group. Mr. Andrews has been appointed class counsel in numerous state and federal 

Case: 1:12-cv-04961 Document #: 51-1 Filed: 06/13/13 Page 16 of 28 PageID #:282
class actions nationwide that have resulted in nearly $100 million dollars in refunds to 

consumers, including Satterfield v. Simon & Schuster, Inc., No. C 06 2893 CW (N.D. Cal.), 

Gray v. Mobile Messenger Americas, Inc., No. 08-CV-61089 (S.D. Fla.), Lofton v. Bank of 

America Corp., No. 07-5892 (N.D. Cal.), Paluzzi v. Cellco Partnership, No. 07 CH 37213 (Cook 

County, Ill.), Parone v. m-Qube, Inc. No. 08 CH 15834 (Cook County, Ill.), and Kramer v. 

Autobytel, Inc., No. 10-cv-2722 (N.D. Cal. 2010).

In addition, Mr. Andrews has achieved groundbreaking court decisions protecting consumers 

through the application of the Telephone Consumer Protection Act to emerging text-messaging 

technology. Representative reported decisions include: Lozano v. Twentieth Century Fox, 702 F. 

Supp. 2d 999 (N.D. Ill. 2010), Satterfield v. Simon & Schuster, Inc. 569 F.3d 946 (9th Cir. 

2009), and Kramer v. Autobytel, Inc., 759 F. Supp. 2d 1165 (N.D. Cal. 2010), In re Jiffy Lube 

Int’l Text Spam Litig, --- F. Supp. 2d ---, No. 11-md-2261, 2012 WL 762888 (S.D. Cal. March 9, 

2012).

Mr. Andrews received his J.D. with High Honors from the Chicago-Kent College of Law and 

was named Order of the Coif. Recently, Mr. Andrews has returned to Chicago-Kent as an 

Adjunct Professor of Law, teaching a third-year seminar on Class Actions. While in law school, 

Mr. Andrews was a Notes & Comments Editor for The Chicago-Kent Law Review, as well as a 

teaching assistant for both Property Law and Legal Writing courses. Mr. Andrews externed for 

the Honorable Joan B. Gottschall in the United State District Court for the Northern District of 

Illinois, and earned CALI awards for the highest grade in five classes.

A native of the Detroit area, Mr. Andrews graduated from the University of Michigan, earning 

his B.A., with distinction, in Political Science and Communications.

Mr. Andrews is licensed to practice in Illinois state courts, the United States District Court for 

the Northern District of Illinois, the U.S. Court of Appeals for the Seventh Circuit, and the U.S. 

Court of Appeals for the Ninth Circuit.

RAFEY S. BALABANIAN is a Partner and Group Chair at EDELSON LLC. Rafey focuses his 

practice on prosecuting consumer technology class actions, banking class actions, and general 

consumer class actions. He is also co-chair of EDELSON LLC’s business litigation group. 

On the plaintiff’s side, Rafey has been the court appointed lead counsel in numerous high-stakes 

class action litigation and has obtained settlements in excess of $50 million. 

On the business litigation side, Rafey has represented individual and corporate clients in a wide 

variety of complex cases, including commercial disputes seeking damages of $60 million and 

several “bet the company” cases.

Rafey has first-chaired both jury and bench trials, engaged in extensive motion practice, and 

acted as lead counsel in several mediations and arbitrations.

Rafey received his J.D. from the DePaul University College of Law in 2005. While in law 

school, Rafey received a certificate in international and comparative law and earned the CALI 

award for the highest grade in advanced trial advocacy. Rafey received his B.A. in History, with 

distinction, from the University of Colorado – Boulder in 2002.

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STEVEN LEZELL WOODROW is a Partner and Group Chair at EDELSON LLC and the firm’s 

hiring attorney. Steven has successfully litigated and settled a number of consumer protection 

cases through trial, engaged in extensive motion practice, drafted appellate briefs, prosecuted 

class actions and participated in multi-session mediations. 

Prior to joining the firm, Steven was a litigator at a Chicago boutique focusing on consumer 

protection matters, real estate disputes, fraudulent transfers in bankruptcy and the prosecution of 

white-knight mortgage fraud cases. 

Steven received his J.D. from Chicago-Kent College of Law with High Honors, Order of Coif, 

while earning his certificate in litigation and alternative dispute resolution. During law school, he 

served as a Judicial Extern for the Honorable Ann C. Williams on the Seventh Circuit Court of 

Appeals and as President of the Student Bar Association. Steven also served as a Notes and 

Comments Editor for THE CHICAGO-KENT LAW REVIEW and represented Chicago-Kent at the 

National Sports Law Moot Court Competition in New Orleans in 2004. Steven was awarded the 

ABA-ALI Scholarship and Leadership Award for best representing the combination of 

leadership and scholarship in his graduating class and also received the Lowell H. Jacobson 

Memorial Scholarship, which is awarded competitively to a student from one of the law schools 

in the Seventh Circuit to recognize personal commitment and achievement.

Steven received his B.A. in Political Science, with Distinction, from the University of 

Michigan—Ann Arbor in 2002.

SEAN P. REIS is Of Counsel to EDELSON LLC. Sean is an experience trial attorney and 

business litigator. Sean has experience in a wide-range of litigation matters, including those 

involving trade secrets, real estate fraud, employment, and consumer issues. Sean has tried 

sixteen cases, including several multi-week jury trials.

Prior to joining EDELSON LLC, Sean was trained at an international law firm and later founded 

his own practice. In 1993, Sean graduated from University of California at San Diego with a 

degree in quantative economics. Following that Sean graduated from Rutgers University School 

of Law, Newark, where he was the business editor of the Rutgers Law Review and where he 

received the graduation for appellate advocacy.

DAVID DALE is an Associate at EDELSON LLC, where he focuses on plaintiff’s privacy class 

actions and litigation.

David received his J.D., magna cum laude, from the John Marshall School of Law, where he was 

a member of the Law Review, Trial Advocacy Council, and a Teaching Assistant for Prof. 

Rogelio Lasso in several torts courses. While in law school, David served as a judicial extern to 

the Honorable James F. Holderman, Chief Judge of the United States District Court for the 

Northern District of Illinois.

David attended the University of Missouri, where he graduated with a B.J. in Journalism in 2004. 

Prior to choosing law school, David worked in the fields of marketing, advertising and public 

relations for the University of Missouri.

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CHRISTOPHER L. DORE is an Associate at EDELSON LLC and a member of the Technology 

and Privacy Practice Group. Chris focuses his practice on emerging consumer technology issues, 

as well as prosecuting unsolicited text message and online fraud cases.

Chris has been appointed class counsel in multiple class actions, including ground breaking 

technology, text-spam, and fraudulent marketing cases. (Turner v. Storm8, LLC, (09-cv-05234) 

(N.D. Cal.) and Espinal v Burger King Corporation, (09-20982) (S.D. Fla.)).

Prior to joining EDELSON LLC, Chris worked for two large defense firms in the areas of 

employment and products liability.

Chris graduated magna cum laude from The John Marshall Law School, where he served as the 

Executive Lead Articles for the Law Review, as well as a team member for the D.M. Harish 

International Moot Court Competition in Mumbai, India. Chris has since returned to his alma 

mater to lecture on current issues in class action litigation.

Before entering law school, Chris received his Masters degree in Legal Sociology, graduating

magna cum laude from the International Institute for the Sociology of Law, located in Onati, 

Spain. Chris received his B.A. in Legal Sociology from the University of California, Santa 

Barbara.

CHANDLER GIVENS is an Associate at EDELSON LLC, where his practice focuses on 

technology and privacy class actions. His lawsuits have centered on fraudulent software 

development, unlawful tracking of consumers through mobile devices and computers, and illegal 

data retention.

Chandler graduated from the University of Pittsburgh School of Law. While in law school, he 

was a research assistant for Cyberlaw Professor Dr. Kevin Ashley, and a judicial extern for the 

Honorable David S. Cercone of the United States District Court for the Western District of 

Pennsylvania. Chandler received CALI awards for the highest course grades in Negotiations as 

well as Telecommunications Law. He graduated cum laude from Virginia Tech, with a B.S. in 

business information technology, with a focus on computer-based decision support 

systems. Chandler sits on the ABA committees for Information Security and e-Discovery.

Before joining the legal profession, Chandler worked as a systems analyst. He is regularly 

invited to speak on issues ranging from network security to consumer privacy and Internet fraud. 

Chandler currently leads a team of technology investigative researchers at the firm.

Prior to starting with the firm, Chandler interned at the Virginia Attorney General’s Office and 

the U.S. Department of Justice in Washington, D.C. 

ALICIA HWANG is an Associate at EDELSON LLC. Alicia practices in the area of consumer 

class action and general litigation.

Alicia received her J.D. from the Northwestern University School of Law in May 2012, where 

she was an articles editor for the Journal of Law and Social Policy. During law school, Alicia 

was a legal intern for the Chinese American Service League, served as president of the Asian 

Pacific American Law Student Association and the Student Animal Legal Defense Fund, and 

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was Chair of the Student Services Committee. She also worked as a student in the Northwestern 

Entrepreneurship Law Clinic and Complex Civil Litigation and Investor Protection Clinic. 

Prior to joining EDELSON LLC, Alicia worked as an Executive Team Leader for the Target 

Corporation, as well as a public relations intern for a tourism-marketing agency in London.

Alicia graduated magna cum laude from the University of Southern California, earning her B.A. 

in Communication in 2007. She is a member of the Phi Beta Kappa honor society. 

NICK LARRY is an Associate at EDELSON LLC. Nick practices in the area of consumer class 

action and general litigation.

Nick received his J.D., cum laude, from Northwestern University School of Law, where he was a 

senior editor of the Northwestern University Journal of International Law and Business.

Nick attended Michigan State University, where he graduated with a B.A. in General Business 

Administration/Pre-law in 2008 and played on the school’s rugby team.

MEGAN LINDSEY is an Associate at EDELSON LLC. Megan practices in the area of consumer 

class action, focusing on complex class actions in the banking industry.

Prior to joining EDELSON LLC, Megan worked for several years as a commercial loan 

underwriter and portfolio officer at Merrill Lynch, Pierce, Fenner & Smith. Megan also worked 

as an analyst in the troubled asset group at Bank of America, helping to monitor and restructure 

high-risk loans.

Megan received her J.D. from Chicago-Kent College of Law in May 2011. During law school 

Megan externed for the Honorable Judge Bauer in the Seventh Circuit Court of Appeals and 

served as Vice President-Evening Division of the Student Bar Association and Vice President of 

the Moot Court Honor Society. Megan also represented Chicago-Kent at the National First 

Amendment Moot Court Competition in Nashville, Tennessee and the National Cultural Heritage 

Law Moot Court Competition in Chicago, Illinois, and earned the CALI award for obtaining the 

highest grade in Legal Writing I, Legal Writing II and Trial Advocacy II courses.

Megan graduated with High Honors from DePaul University in July 2005, earning her B.S. in 

Finance.

DAVID I. MINDELL is an Associate at EDELSON LLC. David practices in the area of 

technology and privacy class actions.

David has worked on cases involving fraudulent software products, unlawful collection and 

retention of consumer data, and mobile-device privacy violations. David also serves as a 

business consultant to private companies at all stages of development, from start-up to exit.

Prior to joining EDELSON LLC, David co-founded several technology companies that reached 

multi-million dollar valuations within 12 months of launch. David has advised or created 

strategic development and exit plans for a variety of other technology companies.

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While in law school, David was a research assistant for University of Chicago Law School 

Kauffman and Bigelow Fellow, Matthew Tokson, and for the predominate cyber-security 

professor, Hank Perritt at the Chicago-Kent College of Law. David’s research included 

cyberattack and denial of service vulnerabilities of the Internet, intellectual property rights, and 

privacy issues.

David has given speeches related to his research to a wide-range of audiences.

JOHN OCHOA is an Associate at EDELSON LLC. John’s practice focuses on consumer class 

action litigation. 

John graduated magna cum laude from the John Marshall Law School in May, 2010 and served 

as Managing Editor for the John Marshall Law Review. His student Comment, which examines 

bicycling and government tort immunity in Illinois, appears in Vol. 43, No. 1 of the JOHN 

MARSHALL LAW REVIEW. While in law school, John took advantage of various scholastic 

opportunities, serving as a research assistant, externing with Judge Thomas Hoffman at the 

Illinois Court of Appeals, and competing in the ABA National Appellate Advocacy Competition. 

John was awarded a Herzog scholarship for his academic performance and earned CALI awards 

for the highest grade in Torts, Property, and Administrative Law.

He received his B.A. with Honors in Political Science from the University of Iowa in 2004. 

EVE-LYNN RAPP is an Associate at EDELSON LLC. Eve-Lynn focuses her practice in the areas 

of consumer and technology class action litigation.

Prior to joining EDELSON LLC, Eve-Lynn was involved in numerous class action cases in the 

areas of consumer and securities fraud, debt collection abuses and public interest litigation. EveLynn has substantial experience in both state and federal courts, including successfully briefing 

issues in both the United States and Illinois Supreme Courts.

Eve-Lynn received her J.D. from Loyola University of Chicago-School of Law, graduating cum 

laude, with a Certificate in Trial Advocacy. During law school, Eve-Lynn was an Associate 

Editor of Loyola’s International Law Review and externed as a “711" at both the Cook County 

State’s Attorney’s Office and for Cook County Commissioner Larry Suffredin. Eve-Lynn also 

clerked for both civil and criminal judges (The Honorable Judge Yvonne Lewis and Plummer 

Lott) in the Supreme Court of New York.

Eve-Lynn graduated from the University of Colorado, Boulder, with distinction and Phi Beta 

Kappa honors, receiving a B.A. in Political Science.

BENJAMIN H. RICHMAN is an Associate at EDELSON LLC and is a member of the firm’s 

Corporate Governance and Business Litigation Practice Group. He handles plaintiff’s-side 

consumer class actions, focusing mainly on technology-related cases, represents corporate 

defendants in class actions, and handles general commercial litigation matters.

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On the plaintiff’s side, Ben has brought industry-changing lawsuits involving the marketing 

practices of the mobile industry, print and online direct advertisers, and Internet companies. He 

has successfully prosecuted cases involving privacy claims and the negligent storage of 

consumer data. His suits have also uncovered complex fraudulent methodologies of Web 2.0 

companies, including the use of automated bots to distort the value of consumer goods and 

services. In total, his suits have resulted in hundreds of millions of dollars to consumers.

On the defense side, Ben has represented large institutional lenders in the defense of employment 

class actions. He also routinely represents technology companies in a wide variety of both class 

action defense and general commercial litigation matters.

Ben received his J.D. from The John Marshall Law School, where he was an Executive Editor of 

the Law Review and earned a Certificate in Trial Advocacy. While in law school, Ben served as 

a judicial extern to the Honorable John W. Darrah of the United States District Court for the 

Northern District of Illinois, in addition to acting as a teaching assistant for Prof. Rogelio Lasso 

in several torts courses. Ben has since returned to the classroom as a guest-lecturer on issues 

related to class actions, complex litigation and negotiation. He also lectures incoming law 

students on the core first year curriculums. Before entering law school, Ben graduated from 

Colorado State University with a B.S. in Psychology.

Ben is the director of EDELSON LLC’S Summer Associate Program.

ARI J. SCHARG is an Associate at EDELSON LLC. He handles technology-related class 

actions, focusing mainly on cases involving the unlawful geo-locational tracking of consumers 

through their mobile devices, the illegal collection, storage, and disclosure of personal 

information, fraudulent software products, data breaches, and text message spam. His 

settlements have resulted in tens of millions of dollars to consumers, as well as industrychanging injunctive relief. Ari has been appointed class counsel by state and federal courts in 

several nationwide class action settlements, including Webb v. Cleverbridge, et al., 11-cv-4141 

(N.D. Ill.), Missaghi v. Blockbuster, 11-cv-2559 (D. Minn.), Ledet v. Ascentive, 11-cv-294 (E.D. 

Penn.), and Drymon v. CyberDefender, 11 CH 16779 (Cook Cnty, Illinois), and was appointed 

sole-lead class counsel in Loewy v. Live Nation, 11-cv-4872 (N.D. Ill.), where the court praised 

his work as “impressive” and noted that he “understand[s] what it means to be on a team that’s 

working toward justice.” Ari was selected as an Illinois Rising Star (2013) by Super Lawyers.

Prior to joining the firm, Ari worked as a litigation associate at a large Chicago firm, where he 

represented a wide range of clients including Fortune 500 companies and local municipalities. 

His work included representing the Cook County Sheriff’s Office in several civil rights cases and 

he was part of the litigation team that forced Craigslist to remove its “Adult Services” section 

from its website.

Ari is very active in community groups and legal industry associations. He is a member of the 

Board of Directors of the Chicago Legal Clinic, an organization that provides legal services to 

low-income families in the Chicago area. Ari acts as Outreach Chair of the Young Adult 

Division of American Committee for the Shaare Zedek Medical Center in Jerusalem, and is 

actively involved with the Anti-Defamation League.

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Ari received his B.A. in Sociology from the University of Michigan – Ann Arbor and graduated 

magna cum laude from The John Marshall Law School where he served as a Staff Editor for THE 

JOHN MARSHALL LAW REVIEW and competed nationally in trial competitions. During law 

school, he also served as a judicial extern to The Honorable Judge Bruce W. Black of the U.S. 

Bankruptcy Court for the Northern District of Illinois.

BEN THOMASSEN is an Associate at EDELSON LLC and is a member of the Banking and 

Financial Services Practice Group. 

Ben received his J.D., magna cum laude, from Chicago-Kent College of Law, where he also 

earned his certificate in Litigation and Alternative Dispute Resolution and was named Order of 

the Coif. At Chicago-Kent, Ben was Vice President of the Moot Court Honor Society and 

competed in both the ABA National Appellate Advocacy and National Moot Court 

Competitions. Among other scholarships and awards, Ben earned seven CALI awards for the 

highest grade in Appellate Advocacy, Business Organizations, Conflict of Laws, Family Law, 

Personal Income Tax, Property, and Torts.

Before his legal career, Ben worked in and around the Chicago and Washington, D.C. areas, 

including freelance and firm-based work as a website designer/developer, and many years 

experience as a film projectionist and media technician for commercial theatres, museums, and 

educational institutions. Ben received his Bachelor of Arts, summa cum laude, from St. Mary’s 

College of Maryland and his Master of Arts from the University of Chicago. 

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EXHIBIT 1-B

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EXHIBIT 1-C

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Invoice #: 0000089

Date: June 13, 2013

Amount Due USD: $16,480.02

Subtotal: 16,480.02

Total: 16,480.02

Amount Paid: -0.00

Balance Due USD: $16,480.02

This invoice was sent using

Item Description Unit Cost ($) Quantity Price ($)

Expense [Miller v. Red Bull 06/05/13] Mediation 1,155.00 1 1,155.00

Expense [Miller v. Red Bull 04/05/13] Mediation: JAMS 1,058.75 1 1,058.75

Expense [Miller v. Red Bull 03/13/13] Copies/Binding/Production: Verity

Group

42.00 1 42.00

Expense [Miller v. Red Bull 01/31/13] Mediation: JAMS 1,338.75 1 1,338.75

Expense [Miller v. Red Bull 01/07/13] FedEx 24.50 1 24.50

Expense [Miller v. Red Bull 01/07/13] Mediation: JAMS - Wayne Anderson 5,099.03 1 5,099.03

Expense [Miller v. Red Bull 11/07/12] Hotel: Megan Lindsey 463.24 1 463.24

Expense [Miller v. Red Bull 11/07/12] Taxi & Parking, DIA Parking 63.00 1 63.00

Expense [Miller v. Red Bull 11/01/12] Copies/Binding/Production: 24 seven

discovere

44.15 1 44.15

Expense [Miller v. Red Bull 10/31/12] Service of Process: LaSalle Process

Servers - Subpoena to Neustar

210.00 1 210.00

Expense [Miller v. Red Bull 10/16/12] Subpoena: Neustar, Inc. 40.00 1 40.00

Expense [Miller v. Red Bull 10/15/12] Mediation: JAMS, Inc. 6,150.00 1 6,150.00

Expense [Miller v. Red Bull 10/12/12] Flight: Megan Lindsey 791.60 1 791.60

INVOICE Edelson LLC

350 North LaSalle

Suite 1300

Chicago IL 60654

United States

Class Action Cases

@edelson.com @edelson.com

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