UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

LEAD PLAINTIFF’S UNOPPOSED MOTION FOR: (I) PRELIMINARY APPROVAL

OF CLASS ACTION SETTLEMENT; (II) CERTIFICATION OF THE SETTLEMENT

CLASS; AND (III) APPROVAL OF NOTICE OF SETTLEMENT

LAZAR MACOVSKI, Individually and On 

Behalf of All Others Similarly Situated,

Plaintiff,

v.

GROUPON, INC., RICH WILLIAMS, and 

MELISSA THOMAS,

Defendants.

Case No. 1:20-cv-02581

Honorable Matthew F. Kennelly

Case: 1:20-cv-02581 Document #: 108 Filed: 06/27/22 Page 1 of 4 PageID #:1293
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Court-appointed Lead Plaintiff Fadi E. Rahal hereby respectfully moves the Court for an 

Order: (i) preliminarily approving the proposed settlement with Defendants Groupon, Inc., Rich 

Williams, and Melissa Thomas; (ii) certifying a settlement class as provided for in the 

Stipulation and Agreement of Settlement dated June 24, 2022; (iii) approving the form and 

method for giving notice to members of the settlement class; and (iv) scheduling a final approval 

hearing. Defendants do not oppose the relief requested by this motion. 

The motion is based on this motion; the memorandum of law in support thereof; the 

Declaration of Leanne H. Solish, Esq. in Support of Lead Plaintiff’s Unopposed Motion for: (I) 

Preliminary Approval of Class Action Settlement, (II) Certification of the Settlement Class, and 

(III) Approval of Notice of Settlement; all exhibits thereto; the [Proposed] Order Preliminarily 

Approving Settlement and Providing for Notice; all pleadings and papers filed herein; arguments 

of counsel; and any other matters properly before the Court. 

Dated: June 27, 2022 Respectfully Submitted, 

GLANCY PRONGAY & MURRAY LLP

/s/ Leanne H. Solish

Robert V. Prongay

Kara M. Wolke 

Leanne H. Solish

Garth A. Spencer

1925 Century Park East, Suite 2100

Los Angeles, CA 90067

Telephone: (310) 201-9150

Email: rprongay@glancylaw.com

kwolke@glancylaw.com

lsolish@glancylaw.com

gspencer@glancylaw.com

KIRBY MCINERNEY LLP

Ira M. Press 

Thomas W. Elrod 

Andrew M. McNeela 

250 Park Avenue, Suite 820

Case: 1:20-cv-02581 Document #: 108 Filed: 06/27/22 Page 2 of 4 PageID #:1294
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New York, NY 10177

Telephone: (212) 371-6600

Email: ipress@kmllp.com

telrod@kmllp.com

amcneela@kmllp.com

Co-Lead Counsel for Lead Plaintiff

POMERANTZ LLP

Louis C. Ludwig

10 South LaSalle Street, Suite 3505

Chicago, IL 60603

Telephone: (312) 377-1181

Email: lcludwig@pomlaw.com

Liaison Counsel for Lead Plaintiff

Case: 1:20-cv-02581 Document #: 108 Filed: 06/27/22 Page 3 of 4 PageID #:1295
PROOF OF SERVICE 

 I, the undersigned say: 

 I am not a party to the above case and am over eighteen years old. 

 On June 27, 2022, I served true and correct copies of the foregoing document, by posting 

the document electronically to the ECF website of the United States District Court for the 

Northern District of Illinois, for receipt electronically by the parties listed on the Court’s Service 

List. 

 I affirm under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed on June 27, 2022. 

 

 s/ Leanne H. Solish 

Leanne H. Solish 

Case: 1:20-cv-02581 Document #: 108 Filed: 06/27/22 Page 4 of 4 PageID #:1296