EXHIBIT K 

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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-cv-4699 

Judge John Z. Lee 

Magistrate Judge Sunil R. Harjani 

DECLARATION OF DARYL F. SCOTT IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF SCOTT+SCOTT 

ATTORNEYS AT LAW LLP 

 I, Daryl F. Scott, declare and state as follows: 

1. I am a Partner of the law firm of Scott+Scott Attorneys at Law LLP. My firm’s 

resume is attached hereto as Exhibit 1. I submit this Declaration in support of Plaintiffs’ petition 

for an award of attorneys’ fees and reimbursement of costs and expenses in connection with 

services rendered and expenses incurred by my firm in connection with this litigation. 

2. My firm has acted as counsel to Plaintiffs and Plaintiffs’ classes in this action. 

During the period from case inception through October 31, 2020 (the first reporting period 

pursuant to the Court’s Case Management Order No. 4: Common Benefit Fee and Expense 

Protocol [Dkt. 105], my firm conducted the following activities for the common benefit of 

Plaintiffs: drafted, filed, and served an initial complaint, drafted the mediation statement, and 

prepared for and attended mediation. The total number of hours expended on this litigation by my 

firm from case inception through October 31, 2020, is 321.40 hours. The total lodestar for my 

firm in this time period is $251,106.00. 

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3. For the time period November 1, 2020 through February 28, 2022, and at the 

request of Plaintiffs’ Co-Lead Counsel, my firm conducted the following activities for the common 

benefit of Plaintiffs: performed legal research regarding non-BIPA claims, reviewed and analyzed 

the settlement term sheet and the settlement agreement, performed legal research regarding the 

proposed allocation of settlement funds, and prepared for and attended the preliminary settlement 

approval hearing. The total number of hours expended on this litigation by my firm from for the 

time period November 1, 2020 through February 28, 2022, is 14.1 hours. The total lodestar for 

my firm in this time period is$10,420.00. 

4. The total number of hours expended on this litigation by my firm from case 

inception through February 28, 2022, is 335.5 hours. The total lodestar for my firm is $261,526.00. 

My firm’s lodestar figures are based on the firm’s current hourly billing rates. The hourly rates for 

the partners, attorneys and professional support staff in my firm are the same as the usual and 

customary hourly rates charged for their services in contingent billable matters. The total number 

of hours was determined by the examination of contemporaneous, daily time records regularly 

prepared and maintained by my firm and which have been provided to Co-Lead Counsel for their 

review. 

5. Attached hereto as Exhibit 2 is a detailed summary indicating the amount of time 

spent by the partners, attorneys and other professional support staff of my firm who have been 

involved in this litigation, and the lodestar calculation is based on my firm’s current hourly billing 

rates from case inception through February 28, 2022. 

6. As detailed in Exhibit 3, my firm has incurred a total of $624.24 in unreimbursed 

expenses during the period from case inception through February 28, 2022. These expenses do not 

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include my firm’s assessment payments to the common cost litigation fund maintained by CoLead Counsel. 

7. The expenses incurred in this action are reflected on the books and records of my 

firm. These books and records are prepared from expense vouchers, check records and other 

source materials and represent an accurate recordation of the expenses incurred. 

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

foregoing is true and correct. 

 Executed on this 25th day of March 2022 at Richmond, VA. 

 

 _____________________________ 

 Daryl F. Scott 

__________________

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Exhibit 

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I N V E S T I N G 

IN THE LAW

Firm Overview

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+“If we desire respect for

 the law, we must first 

 make the law respectable.”

Louis D. Brandeis - 16 October 1912. +

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WE BELIEVE IN 

BOTH THE SPIRIT 

AND THE LETTER 

OF THE LAW.

+

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+Scott+Scott specializes in the investigation 

and prosecution of complex actions across 

the globe – recovering billions for its clients. 

The Firm has extensive experience litigating 

securities fraud, antitrust, and other complex 

cases and is a pioneer in structured finance 

monitoring for client portfolios. We represent 

individual, institutional and multinational clients 

in the U.S and EU courts, offering a one-stop 

shop for international recoupment. +

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THE FIRM

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Scott+Scott was founded in 1975 and began its securities litigation practice in 1997. The 

Firm has since grown into one of the most respected law firm specializing in the investigation 

and prosecution of complex actions across the United States and in Europe. Today, it is 

comprised of over 125 team members, including over 100 highly experienced attorneys, 

a 30+ paraprofessional team comprised of paralegals and legal assistants, a finance 

manager, institutional investor liaisons, and other office support staff, in addition to an 

IT support and development group, financial analysts, forensic accountants, investment 

consultants, and an in-house investigations department.

Scott+Scott is headquartered in Connecticut and has additional offices in New York, 

London, Amsterdam, Berlin, California, Virginia, Ohio, and Arizona.

Scott+Scott has extensive experience litigating securities fraud, antitrust, and other 

complex cases on behalf of our institutional and individual clients throughout the United 

States, serving as lead counsel in numerous securities class actions since the enactment 

of the Private Securities Litigation Reform Act of 1995 (“PSLRA”) and as lead and co-lead 

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counsel in antitrust, consumer, and other complex litigation. The Firm also represents 

many multinational corporations in foreign jurisdiction litigation in the EU courts.

Scott+Scott’s attorneys are recognized experts and leaders in securities monitoring, 

complex litigation, and corporate governance law. They regularly speak at institutional 

investor educational conferences around the world and before boards of directors and 

trustees responsible for managing institutional investments. Scott+Scott attorneys educate 

institutional investors and governmental entities on the importance of fulfilling fiduciary 

obligations through the adoption of appropriate asset recovery services, as well as 

through the development and enforcement of corporate governance initiatives.

Scott+Scott has been a pioneer in structured finance monitoring of our clients’ portfolios and 

the Firm’s vast experience in structured debt financial litigation has enabled us to provide 

clients with in-depth monitoring of their structured finance products. Structured-finance 

products, like asset-backed securities and collateralized debt obligations, attract investors 

with high returns relative to other fixed-income instruments. However, those returns 

can come with substantial undisclosed risks due to investors’ limited ability to assess 

what they are actually acquiring. Most investors cannot review the assets that underlie 

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securitizations, nor negotiate around the boiler-plate terms that govern securitizations, 

and have very little control over the parties that administer securitizations.

Scott+Scott’s portfolio monitoring service responds to these unique risks. Importantly, 

the Firm does not just track the performance of our clients’ structured-finance positions. 

We analyze it in the context of other data that allows us to understand what drives losses, 

should any occur. Initially, Scott+Scott conducts a review of the overall record of the 

parties that issue and administer our clients’ structured-finance investments, such 

as sponsors, servicers, and trustees. The conduct of those parties reveals whether a 

securitization is suffering from hidden flaws, such as defective underlying assets, for 

which investors should be compensated. In addition, Scott+Scott reviews securitizations’ 

asset-level performance ts and their governing agreements to identify any specific 

instances of those parties breaching their obligations and harming investors. This 

comprehensive approach enables Scott+Scott to identify hard-to-spot wrongdoing and 

hold the appropriate parties responsible, ultimately winning significant recoveries for clients 

who purchased structured-finance products. The Firm has also evaluated and monitored 

debt and debentures originating from private placements and non-public companies, 

including municipal bonds and derivatives for our clients.

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Scott+Scott’s Consumer Practice Group consists of some of the premier advocates 

in the area of consumer protection and has been at the forefront in litigating and 

securing some of the most significant consumer protection settlements on behalf 

of its clients, resulting in hundreds of millions of dollars to class members. The 

Firm’s Consumer Practice Group has attorneys dedicated to three primary areas: 

Data Breach/Data Privacy Litigation, Healthcare and Pharmaceutical Litigation, and 

Consumer Protection Litigation. 

+

CONSUMER 

LITIGATION

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DATA BREACH/DATA PRIVACY LITIGATION

Scott+Scott has extensive experience litigating data privacy and data breach class actions 

advancing cutting-edge legal theories. The Firm has achieved some of the largest recoveries 

in this area and currently serves in a leadership capacity in a number of data privacy and 

data breach class actions, including:

• In re Equifax, Inc. Customer Data Security Breach Litigation, No. 1:17-md-02800 (N.D. 

Ga.) (claims on behalf of financial institutions injured as a result of the 2017 Equifax data 

breach that exposed the personal and financial information of approximately 150 million 

U.S. consumers; preliminary approval of settlement valued at $32.5 million); 

• In re Google Assistant Privacy Litigation, No. 5:19-cv-04286 (N.D. Cal.) (class action 

on behalf of consumers alleging privacy violations whereby Google Assistant records and 

discloses their private confidential communications without consent); 

• Lopez v. Apple Inc., No. 4:19-cv-04577 (N.D. Cal.) (class action on behalf of consumers 

and their minor children alleging privacy violations by Apple through its Siri application); and 

• In re: American Medical Collection Agency, Inc. Customer Data Security Breach 

Litigation, No. 2:19-md-02904 (D.N.J.) (claims on behalf of consumers involving data 

breach of personal information).

Recently, in settling a class action against The Wendy’s Co. involving a breach of personal 

and financial information, the court, in approving the $50 million dollar settlement, noted that 

Scott+Scott and its attorneys demonstrated “very significant experience in these types of 

class actions and in data breach litigation” and that the attorneys “brought to the table an 

incredible wealth of knowledge, was always prepared, really was thorough and 

professional in everything that was provided to the Court.” First Choice Federal Credit 

Union v. The Wendy’s Co., No. 2:16-cv-00506, Transcript at 32 (W.D. Pa. Nov. 6, 2019).

REPRESENTATIVE DATA BREACH/DATA PRIVACY CASES

Additional data privacy and data breach settlements achieved by Scott+Scott for its 

clients include:

• The Home Depot, Inc., Customer Data Security Breach Litigation, MDL No. 2583 

(N.D. Ga.) (co-lead counsel; $27.25 million settlement on behalf of financial institutions 

involving data breach and theft of the personal and financial information of over 40 million 

credit and debit card holders);

• In re Target Corporation Customer Data Security Breach Litigation, MDL No. 2522 

(D. Minn.) ($59 million settlement on behalf of financial institutions injured by the theft 

of sensitive payment card information); 

• Greater Chautauqua Federal Credit Union v. Kmart Corporation, No. 1:15-cv-02228 

(N.D. Ill.) (settlement valued at $13.4 million on behalf of financial institutions injured by 

the theft of sensitive payment card information); and

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• WinSouth Credit Union v. Mapco Express, Inc., No. 3:14-cv-01573 (M.D. Tenn.) (largest 

per dollar per card recovery involving payment card data breach brought on behalf of a 

class of financial institutions).

INSURANCE AND PHARMACEUTICAL LITIGATION

Scott+Scott represents consumers and health and welfare funds throughout the United 

States who have been overcharged in connection with their insurance and pharmaceutical 

transactions. The Firm currently serves in a leadership capacity in a number of insurance 

and pharmaceutical class actions, including:

• Sohmer v. UnitedHealth Group Inc., No. 0:18-cv-03191 (D. Minn.) (co-lead counsel; claims 

on behalf of plan participants alleging overcharge for prescription drug copayments); 

• Negron v. Cigna Corporation, No. 3:16-cv-01702 (D. Conn.) (chair of executive 

committee; claims on behalf of plan participants alleging overcharge for prescription 

drug copayments);

• Forth v. Walgreen Co, Inc., No. 1:17-cv-02246 (N.D. Ill.) (class action on behalf of 

consumers and third party union benefit funds alleging unlawful overcharges for medically 

necessary prescription drugs); and

• Stafford v. Rite Aid Corporation, No. 3:17-cv-01340 (S.D. Cal.) (class action on behalf 

of consumers who were overcharged for prescription drug claims).

REPRESENTATIVE INSURANCE AND PHARMACEUTICAL CASES

Scott+Scott have significant experience litigating against insurance companies and 

pharmaceutical manufacturers. The Firm’s lawyers have obtained some of the largest 

settlements in consumer healthcare litigation, including: 

• In re Managed Care Litig., MDL No. 1334 (S.D. Fla.) (settlements with Aetna, CIGNA, 

Prudential, Health Net, Humana, and WellPoint providing monetary and injunctive 

benefits exceeding $1 billion); and

• In re Prudential Ins. Co. SGLI/VGLI Contract Litigation, MDL No. 2208 (D. Mass.) 

($40 million settlement was achieved on behalf of a class of military service members 

and their families who had purchased insurance contracts).

CONSUMER PROTECTION LITIGATION

Scott+Scott has been at the forefront in prosecuting consumer protection actions against 

organizations engaging in unfair practices. The Firm currently serves in a leadership 

capacity in a number of consumer protection class actions, including:

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• Aquilina v. Certain Underwriters at Lloyd’s London, No. 1:18-cv-00496 (D. Haw.) 

(representing Hawaii homeowners who were placed into insurance excluding lava 

coverage and suffered devastating losses as a result of the 2018 eruption of Kilauea); and

• Morris v. Apple, Inc., No. 5:20-cv-04812 (N.D. Cal.) (class action on behalf of consumers 

who purchased iTunes gift cards under false pretenses and were not refunded the value 

of the iTunes gift cards).

Representative Consumer Protection Cases:

Over the past decade, Scott+Scott has litigated a number of diverse cases and fought for 

rights of consumers to be treated fairly and equitably. The Firm has achieved significant 

settlements that have protected consumers’ rights and recovered substantial monetary 

benefits, including:

• The Vulcan Society, Inc. v. The City of New York, No. 1:07-cv-02067 (E.D.N.Y.) 

($100 million settlement and significant injunctive relief was obtained for a class 

of black applicants who sought to be New York City firefighters, but were denied or 

delayed employment due to racial discrimination);

• In re Providian Financial Corp. Credit Card Terms Litigation, MDL No. 1301 (E.D. Pa.) 

($105 million settlement was achieved on behalf of a class of credit card holders who 

were charged excessive interest and late charges on their credit cards);

• In re Pre-Filled Propane Tank Marketing & Sales Practices Litigation, MDL No. 2086 

(W.D. Mo.) ($37 million settlement obtained on behalf of class of propane purchasers 

who alleged defendants overcharged the class for under-filled propane tanks);

• Murr v. Capital One Bank (USA), N.A., No. 1:13-cv-01091 (E.D. Va.) ($7.3 million 

settlement pending on behalf of class of consumers who were misled into accepting 

purportedly 0% interest credit card offers); and

• Gunther v. Capital One, N.A., No. 2:09-cv-02966 (E.D.N.Y.) (settlement resulting in 

class members receiving 100% of their damages in case alleging consumers were 

improperly charged undeliverable mail fees).

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+

Scott+Scott represents investors, businesses, and consumers in price-fixing, 

bid-rigging, monopolization, and other restraints of trade cases on both a 

class-wide and individual basis. The Firm’s work for its clients helps ensure that 

markets remain free, open, and competitive. 

Scott+Scott has been recognized by the American Antitrust Institute with an 

Outstanding Antitrust Litigation Achievement in Private Law Practice award in 

2020, 2018, and an honorable mention in 2014. In addition, the 2018 Antitrust Annual 

Report found that in 2018, the Firm had the highest antitrust settlement in the 

country, as well as ranking first nationally in aggregate setttlement amount from 

2013 to 2018, recovering over $3.4 billion. Scott+Scott’s dedicated team of 

antitrust partners have built one of the nation’s top plaintiffs’ firms for antitrust 

actions. Furthermore, our European expansion reflects a commitment and ability to 

pursue claims on a global basis. 

ANTITRUST 

LITIGATION

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CASE EXAMPLES

Antitrust

Antitrust actions in which Scott+Scott currently serves as a lead or co-lead counsel include:

• In re: Foreign Exch. Benchmark Rates Antitrust Litig., No. 13-cv-07789 (S.D.N.Y.) (challenging 

price-fixing of foreign exchange rates; over $2.3 billion in final-approved settlements). 

The largest antitrust settlement of 2018 according to the American Antitrust Institute;

• In re Disposable Contact Lens Antitrust Litig., No. 15-md-02626 (M.D. Fla.) 

(class action alleging illegal anticompetitive policies to eliminate discount pricing by the major 

manufacturers and distributors of disposable contact lenses);

• In re Cattle Antitrust Litig., No. 19-cv-1222 (D. Minn.) (class action challenging conspiracy 

among the nation’s dominant meat packers to suppress fed cattle prices)

• In re European Gov’t Bonds Antitrust Litig., No. 19-cv-02601 (S.D.N.Y) 

(challenging manipulation in the market for European Government Bonds); 

• In re ICE LIBOR Antitrust Litig., No. 19-cv-02002 (S.D.N.Y.) 

(class action alleging anticompetitive conduct in the setting of the ICE LIBOR benchmark rate);

• Deslandes v. McDonalds USA, LLC, No. 17-cv-04857 (N.D. Ill.) (class action challenging 

no-hire agreement among McDonald’s franchisees);

• Butler v. Jimmy John’s Franchise, LLC, No. 18-cv-00133 (S.D. Ill.) (class action challenging 

no-hire agreement among Jimmy John’s franchisees); and

• Blanton v. Domino’s Pizza Franchising LLC, No. 18-cv-13207 (E.D. Mich.) (class action 

challenging no-hire agreement among Domino’s franchisees).

Antitrust cases in which Scott+Scott previously served as lead or co-lead counsel include:

• Dahl v. Bain Capital Partners, LLC, No. 07-cv-12388 (D. Mass.) (challenging bid rigging and 

market allocation of leveraged buyouts by private equity firms; $590.5 million in settlements);

• Alaska Elec. Pension Fund v. Bank of Am. Corp., No. 14-cv-07126 (S.D.N.Y.) (challenging 

price-fixing of the ISDAfix benchmark interest rate; $504.5 million in settlements). 

The 3rd largest antitrust settlement of 2018 according to the American Antitrust Institute;

• In re GSE Bonds Antitrust Litig., No. 19-cv-01704 (S.D.N.Y.) (challenging manipulation in the 

market for bonds issued by Government-Sponsored Entities, e.g., Freddie Mac and Fannie Mae; 

$386 million settlement);

+

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• In re Korean Air Lines Co., Ltd. Antitrust Litig., MDL No. 1891 (C.D. Cal.) (challenging pricefixing/illegal surcharge of ticket prices; $86 million in cash and travel voucher settlements); and

• Mylan Pharms., Inc. v. Warner Chilcott Pub. Ltd. Co., No. 12-cv-03824 (E.D. Pa.) 

(challenging monopolization in the sale of name-brand pharmaceutical on behalf of indirect 

purchaser class; $8 million settlement).

The Firm has aided in the recovery for class members by serving on the executive leadership 

committees in numerous other class action litigation, including:

• In re Payment Card Interchange Fee & Merch. Discount Antitrust Litig., No. 05-md-01720 

(E.D.N.Y.) (challenging price-fixing in the payment cards industry; $6.24 billion settlement 

preliminarily approved);

• Kleen Products LLC v. Int’l Paper Co., No. 10-cv-05711 (N.D. Ill.) (challenging price-fixing of 

containerboard products; over $376 million in settlements);

• In re Lithium Ion Batteries Antitrust Litig., No. 13-md-02420 (N.D. Cal.) 

(challenging price-fixing of lithium-ion batteries on behalf of indirect purchaser class; 

over $113 million in settlements); and

• In re Mexican Gov’t Bonds Antitrust Litig., No. 18-cv-02830 (S.D.N.Y.) (an antitrust class 

action by eight institutional investors prosecuting 10 global financial institutions for colluding to 

fix the prices of debt securities issued by the Mexican Government between 2006 and 2017).

Scott+Scott’s class action antitrust experience includes serving as co-trial counsel in:

• In re Scrap Metal Antitrust Litig., No. 02-cv-00844 (N.D. Ohio) (helped obtain a 

$34.5 million jury verdict, which was subsequently affirmed by the U.S. Court of 

Appeals for the Sixth Circuit); and

• Ross v. Bank of Am. N.A., MDL No. 1409 (S.D.N.Y.) (bench trial involving 

agreement among payment cards to impose arbitration terms on cardholders).

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We pride ourselves on the caliber of legal talent on our 

team. In addition to some of the best and brightest rising 

stars, we have attorneys who have served with distinction 

in the U.S. Department of Justice, been admitted to the 

U.S. Supreme Court, served in OAGs at the state level, 

argued before the UK’s CAT and High Courts, and received 

virtually every accolade offered in our profession.

WORLD-CLASS 

ATTORNEYS

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JOSEPH P. GUGLIELMO

PRACTICE EMPHASIS

Joseph P. Guglielmo represents institutional and individual clients in antitrust, consumer 

and securities litigation in federal and state courts throughout the United States.

EDUCATION 

Catholic University of America (J.D., 1995; B.A., cum laude, 1992; Certificate of Public Policy)

HIGHLIGHTS 

Mr. Guglielmo is a partner in the firm’s New York office and was recognized for his efforts 

representing New York University in obtaining a monumental temporary restraining order of 

over $200 million from a Bernard Madoff feeder fund. Specifically, New York State Supreme 

Court Justice Richard B. Lowe III stated, “Scott+Scott has demonstrated a remarkable 

grasp and handling of the extraordinarily complex matters in this case. The extremely 

professional and thorough means by which NYU’s counsel has litigated this matter has 

not been overlooked by this Court.”

Mr. Guglielmo serves in a leadership capacity in a number of complex antitrust and 

consumer actions, including: In Equifax, Inc. Customer Data Security Breach Litigation, 

No. 1:17-md-2800 (N.D. Ga.), co-lead counsel, claims on behalf of financial institutions 

involving data breach of personal and financial information of approximately 150 million 

consumers, Arkansas Federal Credit Union v. Hudson Bay, No. 1:19-cv-4492-PKC 

(S.D.N.Y.), lead counsel, claims on behalf of financial institutions arising out of data breaches; 

Forth v. Walgreen Co, Inc., No. 1:17-cv-02246 (N.D. Ill.), lead counsel, asserting claims 

on behalf of class of consumers and third-party payers alleging overcharge for medically 

necessary, covered prescription drugs; Sohmer v. UnitedHealth Group Inc., No. 18-cv-03191 

(JNE/BRT) (D. Minn.); co-lead counsel, claims on behalf of plan participants alleging overcharge for copayments; Negron v. Cigna Corporation, No. 3:16-cv-1702 (WWE) (D. Conn.) 

(chair of executive committee, claims on behalf of plan participants involving overcharge 

of copayments for prescription drugs); In re: Disposable Contact Lens Antitrust Litigation, 

No. 3:15-md-2626 (M.D. Fla.), co-lead counsel, claims on behalf of a class of contact lens 

purchasers alleging violations of the antitrust laws; In re: American Airlines Federal Credit 

Union v Sonic Corp., No., CIV-19-208G (N.D. Ohio.), Plaintiffs’ Executive Committee, 

claims on behalf of financial institutions involving data breach of financial information of 

approximately five million consumers; and In re: American Medical Collection Agency, Inc. 

Customer Data Security Breach Litigation, No. 19-md-2904 (D.N.J.), Plaintiffs’ Steering 

Committee, claims on behalf of consumers involving data breach of personal information.

Mr. Guglielmo is also actively involved in In re Foreign Exchange Benchmark Rates Antitrust 

Litigation, No. 1:13-cv-07789-LGS (S.D.N.Y), which involves claims on behalf of purchasers 

of foreign exchange instruments alleging violations of federal antitrust laws.

Mr. Guglielmo has achieved significant victories and obtained numerous settlements for his 

clients. Mr. Guglielmo was co-lead counsel in In re The Home Depot, Inc., Customer Data 

Security Breach Litigation, MDL No. 2583 (N.D. Ga.), where a $27.25 million settlement

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was obtained on behalf of financial institutions involving a data breach and the theft of the 

personal and financial information of over 40 million credit and debit card holders. Mr. 

Guglielmo is counsel in First Choice Federal Credit Union v. The Wendy’s Company, No. 

16-cv-00506 (W.D. Pa.), where a $50 million settlement was obtained. He is also co-lead 

counsel in Veridian Credit Union v. Eddie Bauer LLC, No. 2:17-CV-00356-JLR (W.D. Wa.), 

where a settlement valued at approximately $9.8 million was recently obtained. Previously, Mr. Guglielmo was also a member of the Plaintiffs’ Steering Committee in In re Target 

Corporation Customer Data Security Breach Litigation, MDL No. 2522 (D. Minn.), where 

a $59 million settlement was obtained on behalf of financial institutions involving data 

breach of personal and financial information of approximately 110 million credit and debit 

cardholders. Mr. Guglielmo was also lead counsel in Winsouth Credit Union v. Mapco 

Express Inc., No. 3:14-cv-1573 (M.D. Tenn.), which achieved the largest dollar-per-card 

recovery on behalf of financial institutions involving data breach of credit and debit card 

information. Mr. Guglielmo was one of the principals involved in the litigation and settlement of 

In re Managed Care Litigation, MDL No. 1334 (S.D. Fla.), which included settlements with 

Aetna, CIGNA, Prudential, Health Net, Humana, and WellPoint, providing monetary and 

injunctive benefits exceeding $1 billion. 

Additional cases in which Mr. Guglielmo played a leading role and obtained substantial 

recoveries for his clients include: Love v. Blue Cross and Blue Shield Ass’n, No. 03-cv-21296 

(S.D. Fla.), which resulted in settlements of approximately $130 million and injunctive 

benefits valued in excess of $2 billion; In re Insurance Brokerage Antitrust Litigation, 

MDL No. 1897 (D.N.J.), settlements in excess of $180 million; Valle v. Popular Community 

Bank, No. 653936/2012 (N.Y. Supreme Ct.), $5.2 million settlement on behalf of consumers, 

In re Pre-Filled Propane Tank Marketing and Sales Practices Litigation, MDL No. 2086 

(W.D. Mo.), consumer settlements in excess of $40 million; Bassman v. Union Pacific 

Corp., No. 97-cv-02819 (N.D. Tex.), $35.5 million securities class action settlement; 

Garcia v. Carrion, No. CV 11-1801 (D.P.R.), substantial corporate governance reforms; 

Boilermakers National Annuity Trust Fund v. WaMu Mortgage Pass-Through Certificates, 

No. 09-cv-00037 (W.D. Wash.), $26 million securities class action settlement,

Murr v. Capital One Bank (USA), N.A., No. 13-cv-1091 (E.D. Va.), $7.3 million settlement

pending on behalf of class of consumers who were misled into accepting purportedly 

0% interest offers, and Howerton v. Cargill, Inc., No. 13-cv-00336 (D. Haw.), $6.1 million 

settlement obtained on behalf of class of consumers who purchased Truvia, purported 

to be deceptively marketed as “all-natural.” Mr. Guglielmo was the principle litigator and 

obtained a significant opinion from the Hawaii Supreme Court in Hawaii Medical Association 

v. Hawaii Medical Service Association, 113 Hawaii 77 (Haw. 2006), reversing the trial 

court’s dismissal and clarifying rights for consumers under the state’s unfair competition law.

Mr. Guglielmo lectures on electronic discovery and was a member of the Steering Committee 

of Working Group 1 of the Sedona Conference®, an organization devoted to providing 

guidance and information concerning issues such as discovery and production issues, as 

well as areas focusing on antitrust law, complex litigation, and intellectual property, and a 

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member of the drafting team responsible for the Sedona Principles, Third Edition. Presently, 

Mr. Guglielmo serves on the board of the Advanced eDiscovery Institute at Georgetown 

University Law Center. He is a frequent speaker on electronic discovery issues. Mr. 

Guglielmo was also recognized for his achievements in litigation by his selection to The 

National Law Journal’s “Plaintiffs’ Hot List.” In 2020, Mr. Guglielmo was recognized by 

Super Lawyers as a top Antitrust lawyer in the New York metro area, was named by Who’s 

Who in Legal Litigation: Leading Practitioner-E-Discovery (2020), and was named by 

Lawdragon as one of the 500 Leading Plaintiff Financial Lawyers.

Mr. Guglielmo is also a member of the following associations: District of Columbia Bar 

Association, New York State Bar Association, and American Bar Association.

ERIN GREEN COMITE

PRACTICE EMPHASIS

Erin Green Comite litigates complex class actions throughout the United States, representing 

the rights of shareholders, employees, consumers, and other individuals harmed by corporate 

misrepresentation and malfeasance. 

EDUCATION 

University of Washington School of Law (J.D., 2002); 

Dartmouth College (B.A., magna cum laude, 1994)

HIGHLIGHTS

Ms. Comite is a partner in the firm’s Connecticut office and currently serves in a leadership 

role in a number of complex class actions including: First Choice Federal Credit Union v. 

The Wendy’s Company, No. 16-cv-00506 (W.D. Pa.), co-lead counsel on behalf of financial 

institutions arising out of data breach; In re Arby’s Restaurant Group, Inc. Litigation, 

No. 17-mi-55555 (N.D. Ga.), member of Plaintiffs’ Executive Committee on behalf of financial 

institutions arising out of a data breach, In re Equifax, Inc. Customer Data Security 

Breach Litigation, MDL No. 2800 (N.D. Ga.), chair of law and briefing committee; Forth 

v. Walgreen Co, Inc., No. 1:17-cv-02246 (N.D. Ill.), co-lead counsel, asserting claims 

on behalf of class of consumers alleging overcharge for medically necessary, covered 

prescription drugs; and Aquilina v. Certain Underwriters at Lloyd’s London, No. 1:18-cv00496 (D. Haw.), co-lead counsel, alleging that insurers, brokers, and agents improperly 

steered insureds into surplus lines insurance.

Recently, Ms. Comite has played a significant role in the prosecution of consumer class 

cases such as: In re The Home Depot, Inc., Customer Data Security Breach Litigation, 

MDL No. 2583 (N.D. Ga.) ($27.25 million settlement) and In re Target Corporation Customer 

Data Security Breach Litigation, MDL No. 2522 (D. Minn.) ($59 million settlement), two 

of the largest data breaches impacting consumer personal data to date; Greater Chautauqua 

Federal Credit Union v. Kmart Corp., No. 15-cv-02228 (N.D. Ill.), Chair of the Plaintiffs’ 

Steering Committee ($8.1 million settlement); Morrow v. Ann, Inc., No. 1:16-cv-03340 

(S.D.N.Y.) ($8.1 million settlement); Howerton v. Cargill, Inc., No. 13-cv-00336 (D. Haw.) 

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($6.1 settlement); Murr v. Capital One Bank (USA), N.A., No. 13-cv-1091 (E.D. Va.) ($7.3 

million settlement); and In re Nutella Mktg. & Sales Practices Litigation, No. 11-cv01086 (D.N.J.) ($2.5 million settlement). 

Ms. Comite’s appellate victories in consumer class actions include Nunes v. Saks Inc., 

2019 WL 2305039 (9th Cir. May 30, 2019); Chavez v. Nestle USA, Inc., 511 F. App’x 606 

(9th Cir. 2013) (achieving a reversal of dismissal); and In re Nutella Mktg. & Sales Practices 

Litigation, 589 F. App’x 53 (3d Cir. 2014) (defending settlement from professional objectors).

Since joining Scott+Scott in 2002, she has litigated such cases as In re Priceline.com 

Securities Litigation ($80 million settlement); Schnall v. Annuity and Life Re (Holdings) 

Ltd. ($27 million settlement); and In re Qwest Communications International, Inc.

(settlement obtaining $25 million for the company and achieving corporate governance 

reforms aimed at ensuring board independence). 

While Ms. Comite is experienced in all aspects of complex pre-trial litigation, she is 

particularly accomplished in achieving favorable results in discovery disputes. In Hohider 

v. United Parcel Service, Inc., Ms. Comite spearheaded a nearly year-long investigation 

into every facet of UPS’s preservation methods, requiring intensive, full-time efforts by a 

team of attorneys and paralegals well beyond that required in the normal course of pre-trial 

litigation. Ms. Comite assisted in devising the plan of investigation in weekly conference 

calls with the Special Master, coordinated the review of over 30,000 documents 

that uncovered a blatant trail of deception and prepared dozens of briefs to describe the 

spoliation and its ramifications on the case to the Special Master. In reaction to UPS’s 

flagrant discovery abuses brought to light through the investigation, the Court conditioned 

the parties’ settlement of the three individual ADA cases on UPS adopting and implementing 

preservation practices that passed the approval of the Special Master.

Prior to entering law school, Ms. Comite served in the White House as Assistant to the 

Special Counsel to President Clinton. In that capacity, she handled matters related to the 

White House’s response to investigations, including four independent counsel investigations, 

a Justice Department task force investigation, two major oversight investigations by the House 

of Representatives and the Senate, and several other congressional oversight investigations. 

Ms. Comite’s volunteer activities have included assisting immigrant women, as survivors 

of domestic violence, with temporary residency applications as well as counseling sexual 

assault survivors. Currently, Ms. Comite supports Connecticut Children’s Medical 

Center and March of Dimes/March for Babies.

MICHELLE CONSTON

PRACTICE EMPHASIS

Michelle Conston’s practice focuses on antitrust litigation.

ADMISSIONS

The Second Circuit Court of Appeals; The Sixth Circuit Court of Appeals; Southern District 

of New York; Eastern District of Michigan; States of New York, New Jersey and Florida

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EDUCATION 

Marist College (B.A. Journalism, magna cum laude, 2010); University of Miami School of 

Law (J.D., magna cum laude, 2013)

ACCOLADES

Selected to Superlawyers® Rising Stars List in Antitrust Litigation in 2018-2020. Law360 

“Ones to Watch” 2021. 

HIGHLIGHTS

Ms. Conston is an associate in Scott+Scott’s New York office and devotes much of her 

time representing investors in cases involving the manipulation of financial benchmarks 

by numerous major banks, including In re Foreign Exchange Benchmark Rates Antitrust 

Litig., No. 13-cv-7789 (S.D.N.Y), In re GSE Bonds Antitrust Litig., No. 19-cv-01704 

(S.D.N.Y.), and In re European Government Bonds Antitrust Litig., No. 19-cv-2601 

(S.D.N.Y.). Ms. Conston also works on cases against pizza restaurants Papa John’s and 

Domino’s alleging that their no-poach agreements with their franchisees are per se illegal 

under the antitrust laws. In re: Papa John’s Employee and Franchisee Employee Antitrust Litig., No. 18-cv-00828 (E.D. Ky.) and Blanton v. Domino’s Pizza Franchising LLC, 

No. 18-cv-13207 (E.D. Mich.). 

During law school, Ms. Conston served as a judicial intern for the Honorable Stephen T. 

Brown, the Chief Magistrate Judge of the United States District Court for the Southern 

District of Florida. Ms. Conston also served as a certified legal intern for the United States 

Attorney’s Office for the Southern District of Florida.

Prior to joining Scott+Scott, Ms. Conston represented institutional investors, hedge funds, 

and individual investors in complex class action litigation arising under the Commodity 

Exchange Act, Sherman Act, RICO Act, and common law. She was heavily involved 

in litigating actions alleging the manipulation of the London Interbank Offered Rate 

(“LIBOR”) for several currencies by large financial institutions (e.g., Laydon v. Mizuho 

Bank, Ltd., No. 12-cv-3419 (S.D.N.Y.) and Sullivan v. Barclays plc, No. 13-cv-00281 

(S.D.N.Y.), as well as an action alleging manipulation of the daily London Silver Fixing by 

the Fixing Banks and several other financial institutions (In re London Silver Fixing, Ltd., 

Antitrust Litig., No. 14-md-02573 (S.D.N.Y.).

CAREY ALEXANDER

PRACTICE EMPHASIS

Carey Alexander prosecutes complex consumer class actions with a focus on deceptive 

pricing and data breach litigation.

ADMISSIONS

United States Courts of Appeal: Ninth Circuit; United States District Courts: Southern, 

Eastern and Western Districts of New York, Districts of Connecticut, Colorado, Eastern 

District of Wisconsin and Northern District of Illinois; State of New York

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EDUCATION

St. John’s University School of Law (J.D., magna cum laude, 2012); 

Skidmore College (B.A., 2004)

HIGHLIGHTS 

Mr. Alexander is an associate in the firm’s New York office and has worked closely with 

the leadership teams steering numerous class actions, including:

• In re Equifax, Inc., Customer Data Security Breach Litig., No. 1:17-md-2800 (N.D. 

Ga.) (member of the Plaintiffs’ Coordination and Discovery Committee);

• First Choice Federal Credit Union v. The Wendy’s Co., No. 2:16-cv-506 (W.D. Pa.) 

(settlement valued at $50 million); and

• Morrow v. Ann Inc., No. 1:16-cv-3340 (S.D.N.Y.) (settlement valued at $7.1 million).

During law school, Mr. Alexander served as Associate Managing Editor of the St. John’s 

Law Review. Mr. Alexander’s student note, Abusive: Dodd–Frank Section 1031 and the 

Continuing Struggle to Protect Consumers, 85 St. John’s L. Rev. 1105 (2012), has been 

cited in judicial opinions and several legal journals, including the Harvard Law Review. 

Before joining the bar, Mr. Alexander served as an editor of the widely acclaimed consumeradvocacy blog The Consumerist. He also served as a policy advisor to the Bronx Borough 

President and worked as part of the National Campaign to Restore Civil Rights.

Mr. Alexander has been recognized on the Super Lawyers New York Metro Rising Stars 

list from 2016 – 2021.

ALEX OUTWATER

PRACTICE EMPHASIS

Alex Outwater’s practice focuses on complex antitrust and consumer class actions.

EDUCATION

University of San Diego School of Law (J.D., 2008); 

University of California - Santa Barbara (B.A., Italian Cultural Studies, 1999)

HIGHLIGHTS

• Indiana State District Council of Laborers & HOD Carriers Pension and Welfare Fund 

v. Omnicare, Inc., No. 2:06-cv-00026-WOB-CJS (E.D. Ky.): ($20 million settlement)

• In Re Tesla Motors, Inc. Stockholder Litigation, No. 12711-VCS (Del. Ch.): an action 

alleging Elon Musk, as Tesla’s controlling stockholder, and Tesla’s Board of Directors, 

breached fiduciary duties to Tesla shareholders in connection with Tesla’s $2.6 billion 

acquisition of SolarCity (a company in which Musk held a substantial interest)

SEAN RUSSELL

PRACTICE EMPHASIS

Mr. Russell is an attorney in Scott+Scott’s San Diego office where he focuses on complex 

antitrust litigation and class actions.

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ADMISSIONS

United States District Courts: Southern and Central Districts of California, Eastern District 

of Michigan; State of California

EDUCATION

University of San Diego School of Law (Masters of Taxation, 2016); Thomas Jefferson School 

of Law (J.D., cum laude, 2015); University of California, Davis (B.A., Economics, 2008)

HIGHLIGHTS 

During law school, Mr. Russell was Chief Articles Editor of the Thomas Jefferson Law Review and a Moot Court Competitor. He also served as an extern to the Honorable William 

V. Gallo of the U.S. District Court for the Southern District of California. 

REPRESENTATIVE CASES

Represented class plaintiffs in Veridian Credit Union v. Eddie Bauer LLC, No. 2:17-cv00356 (W.D. Wash.) which resulted in a $9.8 million settlement.

Represented class plaintiffs in In re Foreign Exchange Benchmark Rates Antitrust Litigation, 

No. 1:13-cv-07789 (S.D.N.Y.), an action challenging collusion regarding foreign exchange rates 

which resulted in a $2.3 billion settlement.

Represented class plaintiffs in Alaska Electrical Pension Fund v. Bank of America Corporation, 

No. 1:14-cv-07126 (S.D.N.Y.), an action challenging collusion regarding the setting of the 

ISDAfix benchmark interest rate that resulted in a $504.5 million settlement.

In re: American Airlines Federal Credit Union v Sonic Corp., No., CIV-19-208G (N.D. 

Ohio.), Plaintiffs’ Executive Committee, claims on behalf of financial institutions involving 

data breach of financial information of approximately five million consumers.

Actively involved in In re UnitedHealth Group PBM Litigation, No. 0:16-cv-3352 (D. 

Minn.) asserting ERISA and deceptive trade practice claims on behalf of nationwide class 

plan participants involving overcharge of co-payments for prescription drugs;

Actively involved in Josten v. Rite Aid Corp., No. 3:18-cv-00152 (S.D. Cal.), an action 

challenging Rite Aid’s reporting of artificially higher prices for certain generic drugs to 

private and government insurance programs.

Actively involved in numerous No-Poach cases where the franchisor and franchisee entered 

into agreements that prohibited the franchisees from soliciting or hiring the employees of 

other franchisees or the franchisor, including Deslandes v. McDonald’s USA, LLC, No. 1:17-

cv-04857 (N.D. Ill.); Conrad v. Jimmy John’s Franchise, LLC, No 3:18-cv-00133 (S.D. Ill.), 

In re: Papa John’s Employee and Franchisee Employee Antitrust Litigation, No. 3:18-cv00825, and Blanton v. Domino’s Pizza Franchising LLC, No. 2:18-cv-13207 (E.D. Mich.).

JOSEPH A. PETTIGREW

PRACTICE EMPHASIS

Joseph A. Pettigrew’s practice areas include securities, antitrust, shareholder derivative 

litigation, and other complex litigation.

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ADMISSIONS

States of California and Maryland; United States Supreme Court; United States District 

Courts: Central, Northern, and Southern Districts of California, District of Maryland

EDUCATION

University of San Diego School of Law (J.D., 2004); Carleton College (B.A., Art History, 

cum laude, 1998)

HIGHLIGHTS 

Mr. Pettigrew is an attorney who works across multiple S+S offices. His work includes the 

following cases: Dahl v. Bain Capital Partners, LLC, No. 07-cv-12388 (D. Mass.); In re Tile 

Shop Holdings, Inc. Stockholder Deriv. Litigation, C.A. No. 10884-VCG (Del. Ch.); and In 

re Robinhood Financial Svs. Litigation, No. 20-cv-1026 (N.D. Cal.). 

Mr. Pettigrew has served on the board and as legal counsel to several nonprofit arts organizations.

ANJA RUSI

PRACTICE EMPHASIS

Ms. Rusi’s practice focuses on complex consumer class actions with a focus on deceptive 

pricing and data breach litigation. She also represents governmental entities who are 

bringing actions against pharmaceutical manufacturers and distributors in opioid litigation, other than in Connecticut. 

Ms. Rusi also represents clients in various Connecticut state court matters including 

negligence, contractual disputes, and probate administration. 

ADMISSIONS

United States District Court for the District of Connecticut; State of Connecticut

EDUCATION

Fairfield University (B.A., 2013); Western New England School of Law (J.D., 2016) 

HIGHLIGHTS

Ms. Rusi is an associate in the firm’s Connecticut office. Prior to joining the firm, Ms. Rusi 

worked for a midsized firm in Hartford representing clients in a broad range of areas including 

contract and commercial litigation, real estate litigation, and insurance law. 

Ms. Rusi practices in varied Connecticut state court matters as well as federal class actions 

and has been recognized as a “Rising Star” by Connecticut Super Lawyers (2021).

Scott+Scott’s attorneys are currently licensed to practice in various federal and state jurisdictions throughout the United States and remain in good standing before their respective state bars for 

purposes of pro hac vice admission to any state or federal court. The Firm’s officers, partners, principals, agents, and employees have never been disciplined, admonished, or warned by the court 

or had any license, registration, charter, certification, or any similar authorization to engage in the legal profession suspended or revoked for any reason.

Case: 1:20-cv-04699 Document #: 197-28 Filed: 03/31/22 Page 29 of 35 PageID #:4006
U.S. News & World Report “Best Law Firms”

The Firm is currently ranked by U.S. News & World Report as a “Best Law Firm” 

in commercial litigation in the New York region.

American Antitrust Institute

The 2018 Antitrust Annual Report recognized In re Foreign Currency Benchmark 

Rates Antitrust Litigation as the #1 settlement of 2018, as well as ranking the 

FIrm #1 nationally for aggregate settlements: 2013-2018.

Global Competition Review 

At the 6th Annual Global Competition Review (“GCR”) Awards, Scott+Scott won 

for Litigation of the Year – Cartel Prosecution, which recognized the Firm’s efforts 

in the foreign exchange settlements in the United States, a landmark case in 

which major banks conspired to manipulate prices paid in the $5.3 trillion-perday foreign exchange market and have thus far settled for more than $2 billion. 

Law 360 Glass Ceiling Report

Scott+Scott is recognized as one of the top law firms in the nation for female 

attorneys by the legal publication Law360. The Glass Ceiling Report honors firms 

that “are demonstrating that the industry’s gender diversity goals can turn into a 

measurable result, and boost the number of women at all levels of a law firm.1, 

2” This selection highlights the importance Scott+Scott places on diversity and 

inclusion within the Firm.

Center for Constitutional RIghts

Scott+Scott was the recipient of the 2010 Center for Constitutional Rights’ Pro Bono 

Social Change Award for its representation of the Vulcan Society, an association of 

African-American firefighters, in challenging the racially discriminatory hiring practices 

of the New York City Fire Department. 

ACCOLADES

1 https://www.law360.com/articles/1310926

https://www.law360.com/articles/1162859/the-best-law-firms-for-female-attorneys.

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+

© 2021 Scott+Scott Attorneys at Law LLP

+ New York

+ London

+ Amsterdam

+ Berlin

+ California 

+ Connecticut

+ Virginia

+ Ohio

Scott+Scott + The Helmsley Building + 230 Park Ave, 17th Floor + New York, NY 10169 + United States + www.scott-scott.com 

Case: 1:20-cv-04699 Document #: 197-28 Filed: 03/31/22 Page 31 of 35 PageID #:4008
Exhibit 

Case: 1:20-cv-04699 Document #: 197-28 Filed: 03/31/22 Page 32 of 35 PageID #:4009
Firm Name:

Categories: TITLE:

ATTORNEYS(P, A)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS 

HOURS

CURRENT 

HOURS

CUMULATIVE 

HOURS

Erin Green Comite (P) 1.00 8.50 0.70 0.90 0.00 11.10 11.10 

Joseph Guglielmo (P) 0.20 43.40 2.00 0.60 52.10 4.50 0.00 102.80 102.80 Carey Alexander (A) 3.80 0.40 0.00 4.20 4.20 Hal Cunningham (A) 4.20 2.70 0.00 6.90 6.90 Joseph Pettigrew (A) 1.00 2.00 82.80 7.50 28.50 25.00 0.00 146.80 146.80 

0.00 0.00 0.00 

SUB-TOTAL 1.00 3.20 0.00 0.00 138.90 0.00 0.00 0.00 13.30 0.60 84.00 30.80 0.00 0.00 0.00 0.00 271.80 271.80 

NON-ATTORNEYS(LC, SPL, PL)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS 

HOURS

CURRENT 

HOURS

CUMULATIVE 

HOURS

Ellen DeWan (SPL) 38.30 0.00 38.30 38.30 Kaitlin Steinberger (PL) 1.10 0.90 0.40 0.00 2.40 2.40 

Kelly Hogan (PL) 3.00 1.50 2.50 0.00 7.00 7.00 Kimberly Jager (PL) 15.00 1.00 0.00 16.00 16.00 

0.00 0.00 0.00 

SUB-TOTAL 0.00 0.00 0.00 0.00 57.40 0.00 0.00 0.00 0.00 0.00 2.40 3.90 0.00 0.00 0.00 0.00 63.70 63.70 GRAND TOTAL: 1.00 3.20 0.00 0.00 196.30 0.00 0.00 0.00 13.30 0.60 86.40 34.70 0.00 0.00 0.00 0.00 335.50 335.50 

1) Legal Research2) Investigation / Factual Research3) Discovery  (Written / Deposition Taking &  Defending / Meet & Confer / etc. )4) Document Review (Including for depo prep, class cert, experts, liability issues,  jurisdictional issues, and meetings 

re doc review)

5) Pleadings, Briefs & Motions (Drafting, Research, Serving & Filing)6) Class Certification7) Summary Judgment8) Appeals9) Court Appearance and Prep10) Experts 

11) Settlements & Mediation12) Case Management13) Class Notice 14) Trial Prep  (Exhibit & Witness List/Jury Instruction/  Vior Dire/Opening Statements/Closing  Arguments/Demonstratives/etc.)15) Trial

(P(A(L(S(P

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2

TIME REPORT SUMMARY AT CURRENT RATES

Scott+Scott Attonerys at Law LLP Reporting Period: Inception through February 28, 2022

 556281 

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Exhibit 

Case: 1:20-cv-04699 Document #: 197-28 Filed: 03/31/22 Page 34 of 35 PageID #:4011
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees

Experts/consultants

Federal Express / UPS /Ontrac $156.72

Postage / U.S. Mail

Service of Process

Messenger/delivery

Hearing Transcripts

Investigation

PACER $445.02

Photocopies - in House $22.50

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous

TOTAL EXPENSES $624.24

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 3 

EXPENSE REPORT SUMMARY

FIRM NAME: Scott+Scott Attonerys at Law LLP

REPORTING PERIOD: Inception through February 28, 2022

2

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