EXHIBIT BB 

Case: 1:20-cv-04699 Document #: 197-45 Filed: 03/31/22 Page 1 of 12 PageID #:4482
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 PETER E. COOPER IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF LAWRENCE KAMIN, 

LLC 

 I, PETER E. COOPER, declare and state as follows: 

1. I am a Member of the law firm of LAWRENCE KAMIN, LLC. 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 at the direction of Co-Lead Counsel for Plaintiffs, Ekwan Rhow of Bird, Marella, Boxer, 

Wolpert, Nessim, Drooks, Lincenberg & Rhow, P.C.: 

x Researched, coordinated and drafted pleadings and appeared in Court concerning the 

consolidation and rationalization of class action litigation regarding TikTok, including 

violations of the Illinois Biometric Information Privacy Act (“BIPA”) pending among 

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various U.S. District Courts for consolidation as MDL in the U.S. District Court for the 

Northern District of Illinois. 

The total number of hours expended on this litigation by my firm from case inception through 

October 31, 2020, is 75.30 hours. The total lodestar for my firm in this time period is $40,350.00. 

3. 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. 

4. As detailed in Exhibit 3, my firm has incurred a total of $16.90 in unreimbursed 

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

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

5. 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 25 day of March, 2022 at Chicago, Illinois. 

 

 Peter E. Cooper 

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Exhibit 

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1 

FIRM RESUME 

Lawrence Kamin, LLC (“Lawrence Kamin”) has concentrated on the representation of the securities industry 

since the stock market crash of 1929. For over 90 years of dynamic change and restructuring, Lawrence Kamin has 

been actively representing securities, futures and derivatives firms and professionals. 

The Firm has decades of experience advising on the formation, organization, operation, capitalization and 

compliance procedures of broker-dealers, investment advisors and other financial service firms. We’re called upon 

to assist companies on various supervisory and compliance matters, including the design and implementation of 

compliance systems and internal controls, counsel on the requirements of the federal and state securities laws and 

the intricate rules and regulations of self-regulatory organizations and exchanges, regulatory exams, and internal 

investigations and defending enforcement actions when potential violations have occurred. We also represent 

broker-dealers, investment advisors and their affiliated personnel in regulatory compliance matters, including 

investigations and enforcement proceedings. Many of our securities attorneys have backgrounds working at the 

Securities and Exchange Commission or various stock markets and exchanges, and all have worked with regulators 

for decades. This experience often provides a twofold benefit: We can anticipate the focus of regulatory inquiries, 

and our credibility with regulators allows us to achieve prompt and satisfactory resolutions. 

Lawrence Kamin’s experience has permeated virtually every area of the Federal and State Securities Laws. 

Lawrence Kamin has assisted financial professionals in the creation, formation, reorganization, operation, 

registration, compliance of securities related business, including proprietary trading firms, money management 

firms, broker-dealers, and investment advisors, prepare operating agreements, and advise on related regulatory 

and organizational issues, provide assistance in registration, and help prepare firm filings. The Firm has 

represented advisers, fund managers, sponsors and investors with respect to money management issues. We 

have advised clients on investment management opportunities, including structuring hedge funds and private 

equity funds, and has consulted on the regulatory issues related to private fund management. 

The Firm has represented issuers of and investors in private placement offerings and financing, prepared securities 

offering materials, including disclosure documents and subscription agreements, assist clients in the preparation or 

revision of company documents, and provide advice on the filings necessary to comply with federal and state 

securities laws, including Form 10-K disclosures. 

Lawrence Kamin also has been a part of the rich history of the nation’s commodities and futures trading and is 

among the highly-regarded futures and derivatives firms in Chicago. As the futures and derivatives markets have 

diversified and shifted to international exchanges and virtual markets, the Firm’s practice evolved to address new 

investment contracts in expanded markets. Lawrence Kamin attorneys have represented clients in the 

organization and registration of new FCMs, introducing brokers, proprietary trading firms and money managers 

such as CTAs and CPOs, through the design and implementation of financial controls and compliance systems, to 

the sale or liquidation of brokerage firms, Lawrence Kamin attorneys assist clients in identifying their objectives 

and implementing strategies to accomplish them. 

Lawrence Kamin has advised firms and traders regarding electronic trading and market making, prepared 

proprietary trading agreements, counselled on risk management concerns and regulatory issues that arise in 

upstairs trading and remote market making. The Firm has advised clients in the areas of capital and margin 

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2 

regulation, clearance and settlement, correspondent and clearing arrangements and on capital and operational 

questions. We also have counselled accounting firms performing audits of securities and commodities 

professionals. 

Members of Lawrence Kamin have successfully represented clients in investigations and enforcement proceedings 

before an array of agencies and self-regulatory organizations, including the Securities and Exchange Commission 

(SEC), the Commodity Futures Trading Commission, the Financial Industry Regulatory Authority (FINRA ), the New 

York Stock Exchange (NYSE), the National Futures Association (NFA), the Chicago Board Options Exchange (CBOE), 

the Chicago Mercantile Exchange (CME) and the Chicago Board of Trade (CBOT). 

Much of our success is due to the professional experience of the members of our practice groups. These attorneys 

not only have decades of experience representing members of the financial services industry before regulatory 

authorities, but also have worked as counsel for the SEC and/or for some of the exchanges conducting inquiries. 

The depth of their experience assists us in anticipating the direction of investigations and enforcement 

proceedings and in structuring resolutions with regulators. 

Our diversified practice groups and experienced attorneys enable us to aggressively represent clients in financial 

services matters in a broad spectrum of litigation, ranging from brokers and underwriters in nationwide class 

actions, to FCM’s and traders in industry arbitrations and to dealers and registered representatives in customer 

disputes. Lawrence Kamin has previously served as liaison counsel in several securities class action matters before 

the Northern District of Illinois. When pursuing or defending securities claims, we strive to not only understand 

the facts of a given case, but also to learn the details of the firm or company’s operations and procedures. 

LAWRENCE KAMIN LITIGATION, BUSINESS, AND SECURITIES INDUSTRY PARTNERS 

Thomas F. Bennington, Jr., is a partner with Lawrence Kamin's Businesses & Corporations practices, concentrates 

his practice in business sales and purchases, commercial real estate, wealth protection, and business succession 

planning. 

Peter E. Cooper joined Lawrence Kamin in July 1998, after positions with a Chicago securities litigation boutique 

and two diversified New York law firms. Peter’s practice includes representing broker-dealers and registered 

representatives in customer complaints and securities arbitrations and lawsuits, and representing both plaintiffs 

and defendants in non-securities litigation ranging from business torts and breaches of contract to trust and 

estates disputes. An adjunct professor at the IIT Chicago-Kent School of Law, Peter previously served as the chair of 

the Securities Litigation and Enforcement Subcommittee of the Chicago Bar Association Securities Law Committee. 

Katelyn M. Hodgman is a litigation attorney representing both corporate and individual clients in a wide range of 

commercial litigation issues. She astutely advises small businesses, financial institutions, product manufacturers, 

distributors, installers, and vendors involved in contract disputes, restrictive covenant issues, insurance defense, 

collection matters, and fiduciary litigation. 

Ted Harman is of counsel with the firm, and possesses solid experience in counseling clients on disputes and 

regulatory matters since 1989. Ted is the consummate problem solver when it comes to his clients. Whether 

working to conclude an existing dispute in the most advantageous manner possible for his clients or planning for 

disputes which may arise, he aims to find the best solutions on the legal issues facing his clients. He works with his 

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3 

clients to identify their needs and goals as well as the risks and benefits of the available courses of action to solve 

their problems. 

Kent Lawrence is a sought-after mediator and arbitrator who is retained either directly by counsel or through 

organizations such as the American Arbitration Association, Financial Industry Regulatory Authority (FINRA, f/k/a 

NASD), National Futures Association and the Center for Conflict Resolution. His mediations often focus on matters 

involving securities, options, commodities and futures, general commercial and real estate, but he has also 

mediated as a volunteer in employment discrimination, divorce fee and community matters. 

John S. Monical, Lawrence Kamin's managing partner, has been with the firm since 1998. His primary area of 

practice is litigation, including commercial disputes, representing the financial services industry in regulatory 

investigations, arbitration, mediation and litigation of disputes between broker-dealers, their registered 

representatives and their clients and in defending major manufacturers of juvenile products in their product 

liability actions across the country. Opposing counsel have most often complimented John for his tenacious 

attention to detail. Through his active membership in the CBA Securities Law Committee, the Defense Research 

Institute (DRI) and the Securities Industry and Financial Markets Association (SIFMA), John stays current on legal 

developments and contributes to the ongoing discussion of cutting-edge arguments for his clients. John is the 

Illinois State Liaison to the ABA Committee on the State Regulation of Securities and a past chair of the CBA 

Securities Law Committee. 

Myra Mormile-Wolper is a seasoned business and financial regulatory lawyer and commercial litigator licensed in 

Illinois and Georgia. Myra represents financial service entities including broker-dealers and investment advisors, as 

well as financial advisors and registered representatives in compliance matters; state, SEC, and FINRA regulatory 

investigations and enforcement proceedings; customer litigation and arbitration; and employment disputes. With 

almost 20 years of professional practice, Myra has amassed a successful track record in general counsel and senior 

in-house counsel roles. Myra was instrumental in the formation and implementation of a Legal, Compliance and 

AML-Fraud department for an online brokerage firm. Additionally, she provided legal counsel and training on 

information security, incident response and open source software for a multi-billion dollar financial services firm 

providing online investing, brokerage and banking services to millions of retail investors. Myra has substantial 

experience serving as a financial services litigator and regulatory counsel, often representing clients in state and 

federal courts, arbitration, negotiations, witness preparation, depositions, and on-the-record interviews. 

Raymond E. Saunders centers his practice around corporate structure, business transactions, income tax, mergers 

and acquisitions, and trusts, estate and gift tax (including cross-generational transfer and ownership of business). 

He is technically proficient as a Certified Public Accountant, but his strength is his pragmatic approach and ability 

to craft simple solutions to complex problems. He has developed the skill of being able to provide concise and 

simple oral and written explanations of complex legal andbusiness matters. 

Michael Wise joined Lawrence Kamin in 1989. His practice centers on the financial services industry, encompassing 

compliance, transaction and litigation matters.Michael counsels brokers, advisers, derivatives market participants 

and private funds. He regularly handles compliance issues and complex transactions. He has been active in helping 

clients respond to new requirements mandated by the Dodd Frank Act. Michael represents firms and individuals 

before the SEC, self-regulatory organizations and state regulators in investigations and enforcement proceedings. 

Michael’s litigation activities include arbitrations before securities and futures exchanges, and appearing on behalf 

of investment professionals in disciplinary proceedings. Michael also advises corporate and investment company 

officers and directors in governance and employment related matters, including internal investigations, and 

regularly represents professionals, such as accountants and other attorneys working in the financial services 

area. In addition to serving as a seminar panelist for various industry association events, Michael has co-authored 

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articles on financial services issues with Paul Uhlenhop, including “Managing Regulatory Investigations,” published 

in The Review of Securities and Commodities Regulation and “Regulatory Examinations For Cause.” 

Mitchell B. Goldberg (Retired—Appointed as Judge, Circuit Court of Cook County, Illinois). Prior to his departure 

from Lawrence Kamin, Mitchell focused his practice on commercial litigation, concentrating in securities and 

commodity futures law and alternative dispute resolution. He is also a trained mediator. Mitch’s active 

membership on the boards of various legal committees and law societies, including the Chicago Bar Association 

and the Decalogue Society of Lawyers, reinforces his intent to continually improve the legal profession, as well as 

his desire to provide the best possible guidance to clients by keeping abreast of the latest developments in the law. 

Mitch has lectured to the Decalogue Society of Lawyers and taught securities litigation at IIT’s Chicago-Kent College 

of Law. In September 2021, Mitchell was appointed Associate Judge, Circuit Court of Cook County, Illinois, and left 

the firm. 

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Exhibit 

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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

Peter Cooper (P) 9.40 0.70 51.30 0.70 0.00 62.10 62.10 

Mitchell Goldberg (P) 1.20 9.00 0.00 10.20 10.20 

SUB-TOTAL 0.00 10.60 0.00 0.70 60.30 0.00 0.00 0.00 0.70 0.00 0.00 0.00 0.00 0.00 0.00 0.00 72.30 72.30 

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

Guadalupe Sanchez (PL) 3.00 0.00 3.00 3.00 

SUB-TOTAL 0.00 0.00 0.00 0.00 3.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.00 3.00 GRAND TOTAL: 0.00 10.60 0.00 0.70 63.30 0.00 0.00 0.00 0.70 0.00 0.00 0.00 0.00 0.00 0.00 0.00 75.30 75.30 

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 1

TIME REPORT SUMMARY AT CURRENT RATES

Lawrence Kamin, LLC Reporting Period: Inception through February 28, 2022

 556281 

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Exhibit 

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CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees

Experts/consultants

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw PACER Online Research $16.90

Photocopies - in House

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous

TOTAL EXPENSES $16.90

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: Lawrence Kamin, LLC

REPORTING PERIOD: Inception through February 28, 2022

 556281 Ex. 3 Expense Summary

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