IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS

IN RE: FICO ANTITRUST LITIGATION 

RELATED CASES No. 1:20-CV-2114

Judge Edmond E. Chang 

Magistrate Judge M. David Weisman

This document relates to: 

ALL ACTIONS

PLAINTIFFS’ JOINT OPPOSITION TO

THE CREDIT BUREAUS’ MOTION TO STAY DISCOVERY 
Direct Purchaser Plaintiffs and Indirect Purchaser Plaintiffs (“Plaintiffs”) respectfully 

submit this joint brief in opposition to the Credit Bureaus’ Motion To Stay Discovery (Dkt. 187). 

PRELIMINARY STATEMENT

Discovery does not “cease during the pendency of a motion to dismiss.” SK Hand Tool 

Corp. v. Dresser Indus., Inc., 852 F.2d 936, 945 (7th Cir. 1988). Despite that default rule, the 

Credit Bureaus claim they should be exempted from discovery. But they have failed to carry their 

burden of showing a stay is warranted. They have shown no hardship or inequity that would arise 

from proceeding with discovery, much less the sort of hardship that would overcome the prejudice 

to Plaintiffs from a second stay of discovery. This case has been pending since April 2020, and

the Credit Bureaus (and FICO) have provided no discovery. They have “already had the benefit 

of a lengthy stay.” Robinson v. Walgreen Co., No. 20 CV 50288, 2021 WL 2453069, at *2 

(N.D. Ill. June 16, 2021). Another stay would prejudice Plaintiffs, be contrary to the public interest 

in prosecuting antitrust-law violations, and threaten the efficient and orderly progress of this case. 

The motion should be denied.1

BACKGROUND

I. THE CREDIT BUREAUS REFUSE TO PARTICIPATE IN CASE SCHEDULE NEGOTIATIONS

On September 28, 2023, this Court denied the motion to dismiss the §2 and state-law 

claims against Fair Isaac, granted the motions to dismiss the §1 claims against Fair Isaac and the 

Credit Bureaus, granted Plaintiffs leave to amend their complaints to re-plead the §1 claims, and 

ordered that a proposed case schedule be filed by October 16. Dkt. 173, at 30-31. Accordingly, 

Plaintiffs emailed counsel for Fair Isaac and each Credit Bureau a proposed case schedule and

1 Given the Court’s November 16 ruling that “the Credit Bureaus may be treated as a non-party . . . for 

discovery purposes, starting right now,” Dkt. 198, the only remaining dispute is whether party discovery 

should be stayed as to the Credit Bureaus. For the reasons explained in this brief, it should not.
2 

asked all counsel to “advise when you are available to meet and confer.” Ex. A, at 12 (Oct. 6, 

2023 Email from L. Weinstein). The Credit Bureaus did not respond. FICO, however, sent a 

counterproposal on the schedule to Plaintiffs and counsel for the Credit Bureaus. Ex. A, at 9-12

(Oct. 10, 2023 Email from M. Provance). Yet again, the Credit Bureaus did not respond.2

On October 11, Plaintiffs suggested by email – which included counsel for each Credit 

Bureau – a meet and confer regarding Plaintiffs’ proposal to pursue certification and merits expert 

discovery simultaneously. Ex. B, at 1 (Oct. 11, 2023 Email from L. Weinstein). Again, the Credit 

Bureaus did not respond. Nonetheless, FICO and Plaintiffs continued to copy the Credit Bureaus 

on email communications concerning the case schedule. See, e.g., Ex. A, at 3-6 (Oct. 13, 2023 

Email from M. Provance); Ex. A, at 3 (Oct. 16, 2023 Email from L. Weinstein); Ex. A, at 1 (Oct. 

16, 2023 Email from C. Medvene); Ex. C, at 1 (Oct. 13, 2023 Email from L. Dayton).3

On October 16, 2023, the proposed case schedule was filed. Dkt. 179. The next day, the

Court entered the agreed-upon dates and ruled in Plaintiffs’ favor regarding expert discovery, 

noting that even though “merits expert discovery possibly would go to waste” if certification were 

denied, that concern was outweighed by the fact that “waiting many, many months to start merits 

expert discovery 100% guarantees delay.” Dkt. 180. 

II. PLAINTIFFS AMEND THEIR COMPLAINTS 

On October 30, 2023, Plaintiffs filed amended complaints. Dkts. 184, 185. Unlike the 

prior complaints, Dkts. 121, 122, the amended complaints no longer allege a conspiracy among all

Defendants (i.e., a hub-and-spokes conspiracy). Instead, the amended complaints allege simply 

2 Plaintiffs’ exhibits have been excerpted to remove duplicate e-mails further down the chain. 

3 To the extent the Credit Bureaus complain about missing the single meet and confer over the case schedule 

– which focused on the dispute over expert discovery – their quarrel is with Fair Isaac, not with Plaintiffs. 

Counsel for Fair Isaac sent the calendar invitation and video-call information for that meet and confer and 

did not inform Plaintiffs that they had not invited counsel for the Credit Bureaus. 
3 

that each Credit Bureau agreed with Fair Isaac to an unreasonable “contract . . . in restraint of trade 

or commerce.” 15 U.S.C. § 1; see Dkt. 173, at 13 (holding that the “No Equivalent [Products] 

Provision and the Dynamic Royalty Schedule clauses” in the contracts between each Credit Bureau 

and Fair Isaac “together qualify as sufficient allegations of anticompetitive effects”). The amended 

complaints also incorporate new facts, including facts learned from Fair Isaac’s Answers in this 

case – in particular, that Fair Isaac’s contracts with each Credit Bureau contain the provisions the 

Court held were “sufficient allegations of anticompetitive effects.” See, e.g., Dkt. 184 ¶¶ 116, 118; 

Dkt. 185 ¶¶127, 129. Those contracts are “the unlawful agreement[s]” § 1 requires. Always 

Towing & Recovery, Inc. v. City of Milwaukee, 2 F.4th 695, 704 (7th Cir. 2021). 

III. THE CREDIT BUREAUS REFUSE PLAINTIFFS’ COMPROMISE OFFER

After sitting by, watching case-schedule negotiations occur and watching the Court enter 

the now-operative schedule, on November 1, the Credit Bureaus wrote to Plaintiffs stating that 

they “intend to seek confirmation from the Court that the deadlines the Court entered” “do not 

apply to the Credit Bureaus” and that “no discovery of the Credit Bureaus . . . shall be exchanged 

before the motions to dismiss the amended complaints are decided.” Dkt. 187-1, at 10-11. 

Plaintiffs objected and proposed a compromise: “[T]he Credit Bureaus should be excused 

from party discovery during the pendency of their motion to dismiss if the Credit Bureaus agree 

that, if the motion to dismiss is denied, they will not seek to be excused from deadlines under the 

operative case schedule and they will not seek to be excused from party discovery on the grounds 

that they have completed some third-party discovery.” Dkt. 187-1, at 7. That proposal, Plaintiffs 

explained, would adequately balance Plaintiffs’ need to obtain “discovery from the Credit Bureaus 

promptly as materials in their possession are critical to [Plaintiffs’] prosecution of the case” against 

the Credit Bureaus’ “concern[s] about being burdened with party discovery.” Id. Plaintiffs further 

explained during a November 6 meet and confer with the Credit Bureaus and Fair Isaac that the 
4 

proposal “was to move forward with third-party discovery now and, in the event that the motion 

to dismiss is denied, to have the Credit Bureaus proceed on the schedule the Court has entered,” 

not to engage in two rounds of discovery. Id. at 2. The Credit Bureaus rejected Plaintiffs’ proposal 

without suggesting an alternative or explaining what categories of documents they would view as 

reasonable third-party discovery during the pendency of the motion to dismiss. Id.4

On November 16, the Court entered a briefing schedule for the Credit Bureaus’ stay 

motion. In doing so, the Court ordered that “the Credit Bureaus may be treated as a non-party . . . 

like any other non-party for discovery purposes, starting right now.” Dkt. 198. Plaintiffs thus 

intend to pursue third-party discovery against the Credit Bureaus promptly, during the pendency 

of this motion to stay and the forthcoming motion to dismiss, per the Court’s order.

ARGUMENT

I. THE CREDIT BUREAUS FAIL TO JUSTIFY A SECOND STAY OF DISCOVERY

Discovery does not “cease during the pendency of a motion to dismiss.” SK Hand Tool 

Corp. v. Dresser Indus., Inc., 852 F.2d 936, 945 (7th Cir. 1988). That is the default rule. Filing a 

motion to dismiss “ ‘is not ordinarily sufficient to justify a stay of discovery. Had the Federal 

Rules contemplated that a motion to dismiss under Fed. R. Civ. P. 12(b)(6) would stay discovery, 

the Rules would contain a provision to that effect.’ ” New England Carpenters Health & Welfare 

Fund v. Abbott Labs., No. 12 C 1662, 2013 WL 690613, at *2 (N.D. Ill. Feb. 20, 2013) (collecting 

cases); see also Judge Edmond E. Chang’s Case Procedures, Discovery & Discovery Motions 

(“[T]he pendency of a motion, such as a motion to dismiss, does not necessarily operate as a stay 

of discovery”). As the ones asking the Court to depart from the default rule, the Credit Bureaus 

4 On November 6, while the Credit Bureaus were considering the compromise proposal, Plaintiffs served 

requests for production and interrogatories on all Defendants as required by the operative scheduling order. 
5 

“bear[ ] the burden of proving” that discovery should be stayed. Robinson v. Walgreen Co., No. 

20 CV 50288, 2021 WL 2453069, at *2 (N.D. Ill. June 16, 2021) (citing Ind. State Police Pension 

Tr. v. Chrysler LLC, 556 U.S. 960, 961 (2009)); see Dkt. 187, at 4-5. They must show that a stay 

(i) would not “unduly prejudice or tactically disadvantage” Plaintiffs; (ii) would “simplify the 

issues in question and streamline the trial”; and (iii) would “reduce the burden of litigation on the 

parties and on the court.” Id. at *1. The Credit Bureaus have failed to carry their burden. Their 

proposed stay of discovery “100% guarantees delay.” Dkt. 180. And the motion should be denied. 

First, a stay would “unduly prejudice and disadvantage” Plaintiffs. Robinson, 2021 WL 

2453069, at *2. Under the Credit Bureaus’ proposal, Plaintiffs will not be able to obtain any party 

discovery from the Credit Bureaus until March 2024 at earliest. That would not just hamper 

Plaintiffs’ ability to develop their cases against the Credit Bureaus; it would also frustrate 

Plaintiffs’ ongoing discovery of Fair Isaac, whose contracts and relationships with the Credit 

Bureaus are at the heart of this antitrust litigation. See, e.g., DPP First Am. Compl., Dkt. 184, 

¶¶ 101-145, 156-158; IPP Second Am. Compl., Dkt. 185, ¶¶ 115-162, 171-174. What Plaintiffs 

learn from discovery produced by the Credit Bureaus will necessarily inform what Plaintiffs seek 

in discovery from Fair Isaac. The Credit Bureaus’ assertion (at 5) that Plaintiffs will be unaffected 

by a stay because they “can advance their claims and discovery against FICO” in the meantime is 

thus demonstrably false. Moreover, a stay only heightens the risk that discoverable information 

will be lost through failures to retain relevant documents or because, for example, employees with 

discoverable information leave the Credit Bureaus’ employment and/or the jurisdiction (and 

therefore the subpoena power of the Court). 

Staying discovery would also harm the “genuine public interest in bringing private antitrust 

class actions in order to protect consumers, competition, and businesses.” In re Payment Card 
6 

Interchange Fee & Merch. Disc. Antitrust Litig., No. 05-MD-1720, 2019 WL 6888488, at *21 

(E.D.N.Y. Dec. 16, 2019). Every day that passes is another day that the Credit Bureaus and Fair 

Isaac extract supracompetitive fees from the financial institutions that comprise the putative class 

and harm competition in the relevant markets through their anticompetitive contracts. The Credit 

Bureaus’ desire to avoid the “burden, time and expense” of discovery cannot overcome the harm 

to Plaintiffs and putative class members “resulting from the unnecessary delay in and the inability 

to obtain expeditious resolution of this already protracted litigation.” Youngbloods v. BMG Music, 

No. 07 Civ. 2394, 2011 WL 43510, at *7 (S.D.N.Y. Jan. 6, 2011). 

“ ‘If there is even a fair possibility that the stay will work damage to some one else, the 

party seeking the stay must make out a clear case of hardship or inequity in being required to go 

forward.’ ” Robinson, 2021 WL 2453069, at *2 (quoting Landis v. N. Am. Co., 299 U.S. 248, 254 

(1936)) (alteration omitted). The Credit Bureaus have not made any case for hardship or inequity 

resulting from proceeding to discovery, much less a “clear case.” Id. All the Credit Bureaus offer 

is the unsubstantiated assertion (at 5) that discovery “unquestionably will be expensive and timeconsuming.” They have provided “no clear showing of [their] burden or cost with any anticipated 

discovery.” Abbott Labs., 2013 WL 690613, at *3. 

The Credit Bureaus point out (at 5) that “ ‘having to wait for resolution is not a persuasive 

reason to deny the motion for stay.’ ” That may be true in an ordinary case. But where, as here, 

there has already been a lengthy stay in place, courts recognize that a “second stay . . . would be 

prejudicial.” Robinson, 2021 WL 2453069, at *2; see, e.g., CMG Worldwide Inc. v. Adidas Am., 

Inc., No. 1:17-CV-2356, 2018 WL 7140117, at *3 (S.D. Ind. Sept. 26, 2018) (denying a second

stay on the ground that it “could prejudice the plaintiff’s ability to develop its case, because the 

passage of time tends to erode proof of claims and damages.”). This case has been pending for 
7 

over three years; the Credit Bureaus have “already had the benefit of a lengthy stay.” CMG 

Worldwide, No. 1:17-CV-2356, 2018 WL 7140117, at *3. There is no reason to stay discovery 

again now, just as the case is getting off the ground. 

Second, a stay would not “simplify the issues in question and streamline the trial.” 

Robinson, 2021 WL 2453069, at *1. The cases the Credit Bureaus cite (at 5) presented 

circumstances where the pending motion to dismiss would have resolved the case in its entirety. 

See Calderon v. Procter & Gamble Co., No. 22-cv-3326, 2022 WL 20742696, at *2 (N.D. Ill. Oct. 

6, 2022) (stay “appropriate where the motion to dismiss can resolve the case”); Rodriguez v. Ford 

Motor Co., No. 21 C 2553, 2022 WL 704780, at *1 (N.D. Ill. Mar. 9, 2022) (same). But here – 

whether the Credit Bureaus are parties or not – this litigation will continue at least as to Fair Isaac. 

And regardless of the outcome of the motions to dismiss, the Court will have to assess the 

reasonableness of Fair Isaac’s contracts with each of the Credit Bureaus to resolve the § 2 claim 

against Fair Isaac. See Dkt. 173, at 30-31 (permitting § 2 claims to proceed to discovery on the 

basis of anticompetitive contract provisions). Courts routinely deny stays of discovery in similar 

circumstances. See, e.g., Kelley v. BT Bourbonnais, LLC, No. 1:17-cv-06636, Dkt. 52 (N.D. Ill. 

July 6, 2018) (denying stay “in light of the factual overlap” between part of the case proceeding to 

discovery and part of the case subject to a motion to dismiss); Burlinski v. Top Golf USA, Inc., No. 

1:19-cv-06700, Dkt. 81 (N.D. Ill. Feb. 4, 2021) (stay not warranted where pending ruling “would 

not entirely resolve the case”). 

The Credit Bureaus assert (at 5) that a stay is warranted here because the Court has found 

“a set of claims legally defective,” but they do not cite a single case that suggests the dismissal of 

claims in an earlier version of a complaint warrants a stay of discovery on re-pleaded claims. 

Indeed, courts have denied motions to stay discovery after granting motions to dismiss with leave 
8 

to amend. See, e.g., Kindstrom v. Lake County, 3:22-cv-50041, Dkt. 120 (N.D. Ill. March 6, 2023) 

(striking motions to stay discovery “in light of the anticipated third amended complaint”). 

Third, a stay would not “reduce the burden of litigation on the parties and the Court.” 

Robinson, 2021 WL 2453069, at *2. To the contrary, if the Credit Bureaus’ motion to dismiss is 

denied but the Credit Bureaus have been excused from party discovery during the pendency of the 

motion, the case schedule could be thrown into disarray and resolution of this case could be 

needlessly prolonged. The Credit Bureaus will be subject to discovery one way or the other, 

whether as parties or third parties (indeed, they are now subject to discovery as third parties per 

the Court’s November 16 order). A stay will merely postpone – at the expense of Plaintiffs, the 

public interest, and the Court-ordered schedule – whatever burdens are associated with that 

discovery. While the Credit Bureaus suggest (at 6) that party discovery will be significantly more 

burdensome than third-party discovery, the Federal Rule governing third-party discovery (Rule 

45) “contains no language distinguishing the scope of party discovery from non-party discovery.” 

United States v. AT&T Inc., No. 1:11-cv-01560, 2011 WL 13273135, at *3 (D.D.C. Oct. 29, 2011). 

And though the Credit Bureaus tally up the discovery requests served by Plaintiffs, they nowhere 

argue that the requests are overbroad, unreasonable, or disproportionate to the needs of this 

complex antitrust case. The fact is, they have critical information that is uniquely in their 

possession and relevant to the ongoing case against Fair Isaac as well as the claims against the 

Credit Bureaus. Plaintiffs are entitled to that information now so they can effectively prosecute 

this case. 

Nor will a stay reduce the burdens on the Court. Far from it: A stay risks upsetting the 

already-entered case schedule as explained above. It also creates opportunities for further disputes 

that will require Court resolution, including disputes over what constitutes third-party versus party 
9 

discovery, and disputes over the case schedule if the parties must go back to the well on that after 

the Court’s ruling on the forthcoming motions to dismiss. Courts in this district have recognized 

that “[s]taying discovery as to some, but not all of the Defendants will not operate to simplify th[e] 

case but may result in the need to duplicate depositions, complicate discovery, and frustrate the 

expeditious resolution to this litigation.” Harper v. Cent. Wire, Inc., No. 19 CV 50287, 2020 WL 

5230746, at *2 (N.D. Ill. Sept. 2, 2020). 

The Credit Bureaus spill much ink attempting to persuade the Court to stay discovery based 

on their belief that their forthcoming motion to dismiss will be successful. See Dkt. 187 at 1-2, 

5-6. But that is not a proper basis for staying discovery, as even the cases the Credit Bureaus cite 

recognize. See Robinson, 2021 WL 2453069, at *3 (collecting cases); Dkt. 187 at 4-5 (listing 

factors). Courts have recognized that such arguments are essentially improper requests for “a 

preliminary finding on the likelihood of success on the merits” that have no place in deciding 

whether to stay discovery. Abbott Labs., 2013 WL 690613, at *2. The relevant factors favor 

proceeding with discovery.

II. THE COURT’S ORDERS DO NOT IMPLIEDLY STAY DISCOVERY

Unable to meet their burden under the relevant factors, the Credit Bureaus resort to reading 

the tea leaves in the Court’s prior orders. Dkt. 187, at 6. Those attempts are as unavailing as they 

are unilluminating. 

First, the Credit Bureaus speculate (at 7) that the deadline the Court set for Fair Isaac’s 

Answers and Plaintiffs’ amended complaints “suggest that the Court did not contemplate that filing 

amended complaints would also automatically entitle the Plaintiffs to expand that discovery to 

include the Credit Bureaus.” But the Credit Bureaus forget that the Court operates against the 

backdrop of the defaults set by the Federal Rules of Civil Procedure, under which discovery is not 

automatically stayed during the pendency of a motion to dismiss. 
10 

Second, the Credit Bureaus suggest (at 7) that the Court should have “scheduled this 

[October 17] status report for a date after the Plaintiffs filed amended complaints on October 30, 

2023, so that the Credit Bureaus could participate in the process of negotiating the dates.” But the 

only thing that stopped the Credit Bureaus from negotiating the schedule was their own refusal to 

engage. The Court expressly granted leave to amend; the Credit Bureaus knew there was a risk 

they would be brought back into the case. Now, they are parties who are subject to discovery in 

the ordinary course. 

Finally, the Credit Bureaus assert (at 7) that Plaintiffs are to blame for not “request[ing] 

the Credit Bureaus’ views on any of the discovery deadlines included in the October 16, 2023 Joint 

Status Report.” That claim is not only irrelevant to the stay inquiry, it is patently false. Plaintiffs 

proposed the discovery schedule to “Counsel,” not just counsel for Fair Isaac, and included counsel 

for the Credit Bureaus on all correspondence regarding the case schedule. See p. 2, supra & 

Exs. A-C. The Credit Bureaus made a strategic choice in refusing to provide their views on the 

case schedule; the schedule should not be thrown into disarray because of the Credit Bureaus’ 

litigation tactics. 

CONCLUSION

For the foregoing reasons, Plaintiffs respectfully request that the Court deny any stay of 

discovery and require the Credit Bureaus to comply with the existing case schedule if the Court 

denies the Credit Bureaus’ forthcoming motion to dismiss.5

5 Fair Isaac, to date, has not moved to stay discovery and has taken no position on the stay the Credit 

Bureaus seek. See Dkt. 187-1, at 8-9. To the extent Fair Isaac takes a different position in its November 

20 statement, Plaintiffs respectfully request the right to respond to its arguments in writing. For now, 

Plaintiffs object to any stay of discovery as to Fair Isaac, even if the Court grants a stay of party discovery

as to the Credit Bureaus, given that the Court has already held that the § 2 and state-law claims against Fair 

Isaac may proceed to discovery, and the § 2 and state-law allegations in the amended complaints are 

essentially unchanged from the prior pleadings. 
11 

Dated: November 20, 2023

 /s/ Steven F. Molo 

Steven F. Molo 

Lauren F. Dayton 

MOLOLAMKEN LLP

300 North LaSalle Street, Suite 5350

Chicago, IL 60654 

Telephone: 312-450-6700 

smolo@mololamken.com 

ldayton@mololamken.com 

Lauren M. Weinstein 

Robert Y. Chen

MOLOLAMKEN LLP

600 New Hampshire Avenue, N.W., 

Suite 500 

Washington, DC 20037 

Telephone: 202-556-2000 

lweinstein@mololamken.com 

rchen@mololamken.com 

Liaison Counsel for Direct Purchaser 

Plaintiffs and the Proposed 

Direct Purchaser Class

George A. Zelcs

Randall P. Ewing, Jr. 

Ryan Z. Cortazar 

KOREIN TILLERY, LLC

205 North Michigan Avenue, 

Suite 1950 

Chicago, IL 60601 

Telephone: 312-641-9750 

gzelcs@koreintillery.com 

rewing@koreintillery.com 

rcortazar@koreintillery.com

Jennifer W. Sprengel

CAFFERTY CLOBES MERIWETHER &

SPRENGEL LLP

150 South Wacker, Suite 3000 

Chicago, IL 60606 

Telephone: 312-782-4880 

jsprengel@caffertyclobes.com 

Respectfully Submitted, 

 /s/ Carmen Medici 

Carmen Medici (pro hac vice) 

SCOTT+SCOTT 

ATTORNEYS AT LAW LLP

600 West Broadway, Suite 3300 

San Diego, CA 92101 

Telephone: 619-798-5319 

cmedici@scott-scott.com 

Joseph P. Guglielmo (N.D. Ill. 2759819) 

Michelle E. Conston (pro hac vice) 

Anna Hunanyan (pro hac vice) 

SCOTT+SCOTT

ATTORNEYS AT LAW LLP

The Helmsley Building 

230 Park Avenue, 17th Floor 

New York, NY 10169 

Telephone: 212-223-6444 

jguglielmo@scott-scott.com 

mconston@scott-scott.com 

ahunanyan@scott-scott.com 

Patrick McGahan (pro hac vice) 

SCOTT+SCOTT

ATTORNEYS AT LAW LLP

156 S. Main St. 

Colchester, CT 06415 

Telephone: 860-531-2606 

pmcgahan@scott-scott.com 

Interim Lead Class Counsel for Direct 

Purchaser Plaintiffs and the Proposed 

Direct Purchaser Class

Christopher M. Burke

Walter Noss

Yifan (Kate) Lv

KOREIN TILLERY PC

707 Broadway, Suite 1410 

San Diego, CA 92101 

Telephone: 619-625-5620 

cburke@koreintillery.com 

wnoss@koreintillery.com 

klv@koreintillery.com
12 

Barbara J. Hart (pro hac vice) 

GRANT & EISENHOFER

485 Lexington Ave., 29th Floor 

New York, NY 10017 

Telephone: 646-722-8526 

bhart@gelaw.com 

Paul E. Slater

Joseph M. Vanek

Michael G. Dickler

Matthew T. Slater

SPERLING & SLATER, P.C.

55 West Monroe Street, Suite 3200 

Chicago, IL 60603 

Telephone: 312-641-3200 

pes@sperling-law.com 

jvanek@sperling-law.com 

mdickler@sperling-law.com 

mslater@sperling-law.com 

Guillaume Buell (pro hac vice) 

THORNTON LAW FIRM LLP

1 Lincoln Street, 13th Floor 

Boston, MA 02111

Telephone: 617-720-1333 

gbuell@tenlaw.com 

Daniel E. Gustafson (pro hac vice) 

Daniel C. Hedlund (pro hac vice) 

Michelle J. Looby (pro hac vice) 

Joshua J. Rissman

Ling S. Wang

GUSTAFSON GLUEK PLLC

Canadian Pacific Plaza

120 South Sixth Street, Suite 2600 

Minneapolis, MN 55402 

Telephone: 612-333-8844 

dgustafson@gustafsongluek.com 

dhedlund@gustafsongluek.com 

mlooby@gustafsongluek.com 

jrissman@gustafsongluek.com 

lwang@gustafsongluek.com 

Linda P. Nussbaum

Susan Schwaiger

NUSSBAUM LAW GROUP, P.C.

1211 Avenue of the Americas, 40th Floor 

New York, NY 10036 

Telephone: 917-438-9102 

lnussbaum@nussbaumpc.com 

sschwaiger@nussbaumpc.com

Michael L. Roberts 

Karen Sharp Halbert

ROBERTS LAW FIRM, P.A.

20 Rahling Circle

Little Rock, AR 72223 

Telephone: 501-821-5575 

mikeroberts@robertslawfirm.us 

karenhalbert@robertslawfirm.us

Gregory S. Asciolla (pro hac vice) 

Karin E. Garvey (pro hac vice) 

Robin A. van der Meulen (pro hac vice) 

Matthew J. Perez (pro hac vice) 

Jonathan S. Crevier (pro hac vice) 

DICELLO LEVITT LLP

485 Lexington Avenue, Suite 1001 

New York, NY 10017 

Telephone: 646-933-1000 

gasciolla@dicellolevitt.com

kgarvey@dicellolevitt.com 

rvandermeulen@dicellolevitt.com 

mperez@dicellolevitt.com

jcrevier@dicellolevitt.com

Marvin A. Miller

Lori A. Fanning

MILLER LAW LLC

115 South LaSalle Street, Suite 2910 

Chicago, IL 60603 

Telephone: 312-332-3400 

mmiller@millerlawllc.com 

lfanning@millerlawllc.com
13 

Dennis Stewart (pro hac vice) 

GUSTAFSON GLUEK PLLC

600 B Street, 17th Floor 

San Diego, CA 92101 

Telephone: 619-595-3200 

dstewart@gustafsongluek.com 

Kenneth A. Wexler

Melinda J. Morales

WEXLER BOLEY & ELGERSMA LLP

311 s. Wacker Dr., Suite 5450 

Chicago, IL 60606 

Telephone: 312-346-2222 

kaw@wexlerwallace.com 

mjm@wexlerwallace.com 

Scott A. Martin

Irving Scher 

Jeanette Bayoumi

HAUSFELD LLP

33 Whitehall Street, 14th Floor 

New York, NY 10004 

Telephone: 646-357-1100 

smartin@hausfeld.com 

ischer@hausfeld.com 

jbayoumi@hausfeld.com 

Gary F. Lynch 

CARLSON LYNCH LLP

1133 Penn Avenue, 5th Floor 

Pittsburgh, PA 15222 

Telephone: 412-322-9243 

glynch@carlsonlynch.com 

Katrina Carroll

CARLSON LYNCH LLP

111 W. Washington Street, Suite 1240 

Chicago, IL 60602 

Telephone: 312-750-1265 

kcarroll@carlsonlynch.com 

Counsel for Direct Purchaser Plaintiffs and 

the Proposed Direct Purchaser Class 

Charles F. Barrett (pro hac vice)

NEAL & HARWELL, PLC

1201 Demonbreun Street, Suite 1000 

Nashville, TN 37203 

Telephone: 615-244-1713 

cbarrett@nealharwell.com

Don Barrett (pro hac vice forthcoming)

BARRETT LAW GROUP, P.A.

404 Court Square 

P.O. Box 927 

Lexington, MS 39095 

Telephone: 662-834-2488 

dbarrett@barrettlawgroup.com 

donbarrettpa@gmail.com

Richard R. Barrett (pro hac vice forthcoming) 

BARRETT LAW GROUP, P.A.

2086 Old Taylor Road, Suite 1011 

Oxford, MS 38655 

Telephone: 662-380-5018 

rrb@rrblawfirm.net

Michael P. Lehmann (SBN 77152) 

Christopher Lebsock (SBN 184546) 

HAUSFELD LLP

600 Montgomery Street, Suite 3200 

San Francisco, CA 94111

Telephone: 415-633-1908 

mlehmann@hausfeld.com 

clebsock@hausfeld.com

Hilary K. Scherrer

Paul Gallagher

HAUSFELD LLP

1700 K Street, N.W., Suite 650 

Washington, D.C. 20006 

Telephone: 202-540-7200 

hscherrer@hausfeld.com 

pgallagher@hausfeld.com 
14 

 /s/ Garrett D. Blanchfield 

Garrett D. Blanchfield (pro hac vice) 

Brant D. Penney (pro hac vice) 

Roberta A. Yard (pro hac vice forthcoming) 

REINHARDT WENDORF &

BLANCHFIELD

332 Minnesota Street, Suite W-1050 

St. Paul, MN 55101 

Telephone: 651-287-2100 

g.blanchfield@rwblawfirm.com 

b.penney@rwblawfirm.com 

r.yard@rwblawfirm.com

Jeffrey J. Corrigan (pro hac vice) 

William G. Caldes (pro hac vice) 

Jeffrey L. Spector (pro hac vice) 

Icee N. Etheridge (pro hac vice) 

SPECTOR ROSEMAN & KODROFF, P.C.

2001 Market Street, Suite 3420 

Philadelphia, PA 19103 

Telephone: 215-496-0300 

JCorriganf@srkattorneys.com 

BCaldes@srkattorneys.com 

JSpector@srkattorneys.com 

IEtheridge@srkattorneys.com 

Interim Co-Lead Counsel for Indirect 

Purchaser Plaintiffs and the Proposed 

Indirect Purchaser Class 

Jonathan M. Jagher (pro hac vice

forthcoming)

FREED KANNER LONDON &

MILLEN LLC

923 Fayette Street

Conshohocken, PA 19428 

Telephone: 610-234-6487 

jjagher@fklmlaw.com

David McLafferty (pro hac vice forthcoming)

MCLAFFERTY LAW FIRM, P.C.

923 Fayette Street

Conshohocken, PA 19428 

Telephone: 610-940-4000, ext. 12 

dmclafferty@mclaffertylaw.com

Charles R. Watkins (3122790)

GUIN, STOKES & EVANS, LLC

321 South Plymouth Court 

Suite 1250 

Chicago, IL 60604 

Telephone: 312-878-8391 

charlesw@gseattorneys.com

Liaison Counsel for Indirect Purchaser 

Plaintiffs and the Proposed Indirect 

Purchaser Class

Michael S. Smith (pro hac vice) 

Gregory P. Hansel (pro hac vice) 

Randall B. Weill (pro hac vice) 

Elizabeth F. Quinby (pro hac vice) 

PRETI FLAHERTY, BELIVEAU &

PACHIOS LLP

One City Center, P.O. Box 9546 

Portland, ME 04101 

Telephone: 207-791-3000 

msmith@preti.com

ghansel@preti.com 

rweill@preti.com

equinby@preti.com 

Brian P. Murray (pro hac vice forthcoming) 

Lee Albert (pro hac vice forthcoming)

GLANCY PRONGAY & MURRAY LLP

230 Park Avenue,

Suite 358 

New York, NY 10169 

Telephone: 212-682-5340 

bmurray@glancylaw.com 

lalbert@glancylaw.com 

Douglas A. Millen 

FREED KANNER LONDON & 

MILLEN LLC

2201 Waukegan Road, Suite 130 

Bannockburn, IL 60015 

Telephone: 224-632-4500 

dmillen@fklmlaw.com 
15 

Michael J. Boni (pro hac vice forthcoming) 

Joshua D. Snyder (pro hac vice forthcoming) 

John E. Sindoni (pro hac vice forthcoming) 

BONI, ZACK & SNYDER LLC

15 St. Asaphs Road 

Bala Cynwyd, PA 19004 

Telephone: 610-822-0200 

mboni@bonizack.com 

jsnyder@bonizack.com 

jsindoni@bonizack.com 

Counsel for Indirect Purchaser Plaintiffs and 

the Proposed Indirect Purchaser Class

Simon B. Paris, Esq.

(pro hac vice forthcoming) 

Patrick Howard, Esq. 

(pro hac vice forthcoming) 

SALTZ MONGELUZZI & 

BENDESKY, P.C.

1650 Market Street, 52nd Floor 

Philadelphia, PA 19103 

Telephone: 215-575-3985 

sparis@smbb.com 

phoward@smbb.com