IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE: TIKTOK, INC., CONSUMER 

PRIVACY LITIGATION, 

This Document Relates to All Cases 

MDL No. 2948 

Master Docket No. 20 C 4699 

Judge John Z. Lee 

Magistrate Judge Sunil R. Harjani 

MEMORANDUM IN SUPPORT OF APPOINTMENT OF 

KATRINA CARROLL AND JONATHAN M. JAGHER AS CO-LEAD COUNSEL 

 Cafferty Clobes Meriwether & Sprengel LLP (“CCMS”), counsel for Plaintiff in the action 

originally styled L.B. v. TikTok, Inc. et al., 1:20-cv-02889 (N. D. Ill., filed May 13, 2020), 

respectfully submits this memorandum in support of (1) Katrina Carroll of Carlson Lynch LLP 

and Jonathan Jagher of Freed Kanner London & Millen LLC’s joint application for appointment 

as Co-Lead Counsel (“Proposed Co-Lead Counsel”), and (2) the appointment of a Plaintiffs’ 

Steering Committee consisting of Robert Foote (Foote, Mielke, Chavez & O’Neil, LLC); Michael 

Gervais (Susman Godfrey LLP); Joseph Guglielmo (Scott+Scott Attorneys at Law LLP); Tina 

Wolfson (Ahdoot & Wolfson, PC) and James Zouras (Stephan Zouras, LLP). 

 CCMS has, since this action’s inception, worked closely with Proposed Co-Lead Counsel 

and others to consolidate and organize the various actions originally filed within this District. 

CCMS thus can attest to Proposed Co-Lead Counsel’s tireless efforts to manage this litigation with 

only one goal in mind: to secure expansive and meaningful relief for the putative Class. Indeed, it 

is precisely because of the undersigned’s first-hand experience working with Proposed Co-Lead 

Counsel that CCMS urged this Court to appoint Katrina Carroll Temporary Interim Lead Counsel 

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pending transfer and centralization by the Judicial Panel on Multidistrict Litigation. See E.R. v. 

TikTok, Inc. et al. 1:20-cv-02810, ECF No. 12 (May 21, 2020 “Consent by All Parties to 

Consolidate Cases and Uncontested Motion for Appointment of Temporary Interim Lead Counsel 

Pending MDL Proceedings”). 

The Court ultimately appointed Ms. Carroll to that role and, respectfully, Proposed CoLead Counsel’s efforts over the ensuing months have justified that decision. Proposed Co-Lead 

Counsel repeatedly has worked late into the night to investigate Defendants’ alleged malfeasance 

and the ever-shifting political and regulatory landscape within which it operates, secure transfer of 

these now-consolidated actions to this District and engage Defendants in settlement discussions 

that, given the grit and determination Proposed Co-Lead Counsel have demonstrated, undoubtedly 

will exceed the expectations of the Class and Court alike. Their efforts should be applauded. 

However, it is the manner in which Proposed Co-Lead Counsel have moved this litigation towards 

a successful conclusion that merits commendation and their appointment as Co-Lead Counsel. 

Proposed Co-Lead Counsel has opted for an inclusive approach. They have leveraged the 

substantial collective experience of all Plaintiffs’ counsel who wished to participate in prosecuting 

this action by assigning each tasks suited to their unique expertise, and consistently solicited input 

with respect to any and all strategic decisions. Nowhere is their collaborative philosophy more 

evident than in their successful efforts to engage Defendants in settlement discussions, which 

required Proposed Co-Lead Counsel to secure the participation of counsel for Plaintiffs in actions 

pending across the country, and whose interests may not necessarily have aligned. 

In Case Management Order No. 1, the Court noted that among the criteria for appointment 

as lead counsel are “counsel’s willingness to commit to a time-consuming project [and] ability to 

work cooperatively with others . . . .” MDL Docket, ECF No. 4. Proposed Co-Lead Counsel check 

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both boxes. They have proven themselves dedicated to the task at hand (and ahead), and willing 

and able to collaborate with all counsel for the benefit of Plaintiffs and the Class. Accordingly, 

CCMS respectfully submits that this Court should appoint Katrina Carroll and Jonathan Jagher as 

Co-Lead Counsel, and appoint a Plaintiffs’ Steering Committee consisting of Robert Foote; 

Michael Gervais; Joseph Guglielmo; Tina Wolfson and James Zouras. 

Dated: September 8, 2020 Respectfully submitted, 

/s/ Daniel O. Herrera 

Jennifer W. Sprengel 

Daniel O. Herrera 

Nickolas J. Hagman 

CAFFERTY CLOBES MERIWETHER 

& SPRENGEL LLP

150 S. Wacker, Suite 3000 

Chicago, Illinois 60606 

Telephone: 312-782-4880 

Facsimile: 318-782-4485 

jsprengel@caffertyclobes.com 

dherrera@caffertyclobes.com 

nhagman@caffertyclobes.com 

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CERTIFICATE OF SERVICE 

I, Daniel O. Herrera, an attorney, hereby certify that on September 8, 2020, service of the 

Memorandum in Support Of Appointment of Katrina Carroll and Jonathan M. Jagher as CoLead Counsel was accomplished pursuant to ECF as to Filing Users and I shall comply with LR 

5.5 as to any party who is not a Filing User or represented by a Filing User. 

 s/ Daniel O. Herrera 

 Daniel O. Herrera 

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