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Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 3 of 15 PageID #:3949
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Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 4 of 15 PageID #:3950
Exhibit 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 5 of 15 PageID #:3951
Ahdoot & Wolfson, PC (“AW”) is a nationally recognized law firm founded in 1998 that 

specializes in class action litigation, with a focus on unfair and anticompetitive business practices, 

privacy cases, consumer fraud, employee rights, defective products, antitrust, civil rights, and 

taxpayer rights and unfair practices by municipalities. The attorneys at AW are experienced litigators 

who have often been appointed by state and federal courts as lead class counsel, including in 

multidistrict litigation. In over two decades of its successful existence, AW has vindicated the rights 

of millions of class members in protracted, complex litigation, conferring billions of dollars to the 

victims, and affecting real change in corporate behavior.

Privacy Class Actions

AW has been prosecuting cutting edge data cases on behalf of consumers since the late 1990s. 

AW was among the first group of attorneys who successfully advocated for the privacy rights of millions 

of consumers against major financial institutions based on the unlawful compilation and sale of 

detailed personal financial data to third-party telemarketers without the consumers’ consent. While 

such practices later became the subject of Gramm-Leach-Bliley Act regulation, at the time AW was 

prosecuting these cases before the Hon. Richard R. Kramer, (Ret.) in the complex department of San 

Francisco Superior Court, such practices were novel and hidden from public scrutiny. AW’s work shed 

light on how corporations and institutions collect, store, and monetize mass data, leading to 

governmental regulation. AW has been at the forefront of data-related litigation since then.

As an invaluable member of a five-firm Plaintiffs’ Steering Committee (“PSC”) in the Premera 

Blue Cross Customer Data Sec. Breach Litigation, No. 3:15-cv-02633-SI (D. Or.) (Hon. Michael H. Simon), 

arising from a data breach disclosing the sensitive personal and medical information of 11 million 

Premera Blue Cross members, AW was instrumental in litigating the case through class certification 

and achieving a nationwide class settlement valued at $74 million.

In The Home Depot, Inc., Customer Data Sec. Breach Litigation, No. 1:14-md-02583-TWT (N.D. 

Ga.) (Hon. Thomas W. Thrash Jr.), AW served on the consumer PSC and was instrumental in 

achieving a $29 million settlement fund and robust injunctive relief for the consumer class. 

AW also currently serves on the PSC in Am. Med. Collection Agency, Inc., Customer Data Sec. 

Breach Litigation, No. 2:19-md-2904-MCA-MAH (D.N.J.) (Hon. Madeline Cox Arleo), a class action 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 6 of 15 PageID #:3952


arising out of a medical data breach that disclosed the personal and financial information of over 20 

million patients, as well as many other data breach class actions. 

AW’s efforts have shaped data privacy law precedent. As lead counsel in Remijas v. Neiman 

Marcus Group, LLC, No. 14-cv-1735 (N.D. Ill.) (Hon. Sharon Johnson Coleman), AW’s attorneys 

successfully appealed the trial court’s order granting a motion to dismiss based on lack of Article III 

standing. The Seventh Circuit’s groundbreaking opinion, now cited in every standing brief, was the 

first appellate decision to consider the issue of Article III standing in data breach cases in light of the 

Supreme Court’s decision in Clapper v. Amnesty International USA, 568 U.S. 398 (2013) and concluded 

that data breach victims have standing to pursue claims based on the increased risk of identity theft 

and fraud, even before that theft or fraud materializes in out-of-pocket damages. Remijas v. Neiman 

Marcus Group, LLC, 794 F.3d 688 (7th Cir. 2015) (reversed and remanded). 

Similarly, in the U.S. Office of Personnel Management Data Security Breach Litigation, No. 1:15-mc1394-ABJ (D.D.C.) (Hon. Amy Berman Jackson), AW, as a member of the PSC, briefed and argued, 

in part, the granted motions to dismiss based on standing, and briefed in part the successful appeal to 

the D.C. Circuit. 

AW is also serving as plaintiffs’ counsel in consumer privacy rights cases involving the right to 

control the collection and use of biometric information, successfully opposing dispositive motions 

based on Article III standing. See, e.g., Rivera v. Google LLC, No. 19-CH-00990 (Ill. Cir. Ct.) (Hon. Anna 

M. Loftus); Miracle-Pond v. Shutterfly, Inc., No. 19-CH-07050 (Ill. Cir. Ct.) (Hon. Raymond W. Mitchell); 

Acaley v. Vimeo, Inc., No. 1:19-cv-7164 (N.D. Ill.) (Hon. Matthew F. Kennelly). 

Results 

 AW has achieved excellent results as lead counsel in numerous complex class actions. 

As co-lead counsel in the Zoom Video Communications, Inc. Privacy Litigation, No. 5:20-cv-02155 

(N.D. Cal.) (Hon. Laurel Beeler), a nationwide class action alleging privacy violations from the 

collection of personal information through third-party software development kits and failure to provide 

end to end encryption, AW achieved an $85 million nationwide class settlement that also included 

robust injunctive relief overhauling Zoom’s data collection and security practices. 

 In Eck v. City of Los Angeles, No. BC577028 (Cal. Super. Ct.) (Hon. Ann I. Jones), AW achieved 

a $295 million class settlement in a case alleging that an 8% surcharge on Los Angeles electricity rates 

was an illegal tax. Final settlement approval was affirmed on appeal in October 2019. 

In Alvarez v. Sirius XM Radio Inc., No. 2:18-cv-08605-JVS-SS (C.D. Cal.) (Hon. James V. Selna), 

a breach of contract class action alleging that defendant did not honor its lifetime subscriptions, AW 

achieved a nationwide class action settlement conservatively valued at approximately $420 million. The 

settlement extended the promised lifetime subscription for the lifetime of class members who have 

active accounts and provided the opportunity for class members with closed accounts to reactivate their 

accounts and enjoy a true lifetime subscription or recover $100. The district court had granted the 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 7 of 15 PageID #:3953


motion to compel arbitration on an individual basis, and AW appealed. AW reached the final deal 

points of the nationwide class action settlement minutes prior to oral argument in the Ninth Circuit. 

 As a member of the Plaintiffs’ Executive Committee in the Apple Inc. Device Performance 

Litigation, No. 5:18-md-2827-EJD (N.D. Cal.) (Hon. Edward J. Davila), AW helped achieve a nationwide 

settlement of $310 million minimum and $500 million maximum. The case arose from Apple’s alleged 

practice of deploying software updates to iPhones that deliberately degraded the devices’ performance 

and battery life. 

As co-lead counsel in the Experian Data Breach Litigation, No. 8:15-cv-01592-AG-DFM (C.D. 

Cal.) (Hon. Andrew J. Guilford), which affected nearly 15 million class members, AW achieved a 

settlement conservatively valued at over $150 million. Experian also provided robust injunctive relief. 

Judge Guilford praised counsel’s efforts and efficiency in achieving the settlement, commenting “You 

folks have truly done a great job, both sides. I commend you.” 

In Kirby v. McAfee, Inc., No. 5:14-cv-02475-EJD (N.D. Cal.) (Hon. Edward J. Davila), a case 

arising from McAfee’s auto renewal and discount practices, AW and co-counsel achieved a settlement 

that made $80 million available to the class and required McAfee to notify customers regarding autorenewals at an undiscounted subscription price and change its policy regarding the past pricing it lists 

as a reference to any current discount. 

 In Lavinsky v. City of Los Angeles, No. BC542245 (Cal. Super. Ct.) (Hon. Ann I. Jones), a class 

action alleging the city unlawfully overcharged residents for utility taxes, AW certified the plaintiff class 

in litigation and then achieved a $51 million class settlement. 

As co-lead counsel in Berman v. General Motors, LLC, No. 2:18-cv-14371-RLR (S.D. Fla.) (Hon. 

Robin L. Rosenberg) (vehicle oil consumption defect class action), AW achieved a $40 million 

settlement. 

Current Noteworthy Leadership Roles 

AW was selected to serve as interim co-lead class counsel in the StubHub Refund Litigation, 

No. 4:20-md-02951-HSG (N.D. Cal.) (Hon. Haywood S. Gilliam, Jr.). This consolidated multidistrict 

litigation alleges that StubHub retroactively changed its policies for refunds for cancelled or 

rescheduled events as a result of the Covid-19 pandemic and refused to offer refunds despite 

promising consumers 100% of their money back if events are cancelled. In appointing Ms. Wolfson 

as Interim Co-Lead Counsel, Judge Gilliam noted that while competing counsel were qualified, her 

team “proposed a cogent legal strategy,” “a process for ensuring that counsel work and bill efficiently” 

and “demonstrated careful attention to creating a diverse team.” 

Ms. Wolfson was appointed, after competing applications, to serve as interim co-lead class 

counsel in the Ring LLC Privacy Litigation, No. 2:19-cv-10899-MWF-RAO (C.D. Cal.) (Hon. Michael 

W. Fitzgerald), a consolidated class action arising from Ring’s failure to implement necessary 

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measures to secure the privacy of Ring user accounts and home-security devices, and failure to protect 

its customers from hackers despite being on notice of the inadequacies of its cybersecurity. 

In Clark v. American Honda Motor Co., Inc., No. 2:20-cv-03147-AB-MRW (C.D. Cal.) (Hon. 

André Birotte Jr.), Ms. Wolfson serves as co-lead counsel in a class action arising from unintended 

and uncontrolled deceleration in certain Acura vehicles. In selecting Ms. Wolfson from competing 

applications, Judge Birotte noted: “The Court believes that Ms. Wolfson brings particular attention 

to the virtues of collaboration, efficiency, and cost-containment which strike the Court as especially 

necessary in a case such as this. Ms. Wolfson’s appointment as Co-Lead also brings diversity to the 

ranks of attorneys appointed to such positions: such diversity is not simply a ‘plus factor’ but the 

Court firmly believes that diverse perspectives improve decision-making and leadership.” 

In the Kind LLC “Healthy And All Natural” Litigation, No. 1:15-md-02645-NRB (S.D.N.Y.) 

(Hon. Naomi Reice Buchwald), AW was selected as interim co-lead class counsel after competing 

applications. AW certified three separate classes of New York, California, and Florida consumers 

who purchased Kind LLC’s products in a false labeling food MDL. 

AW was appointed to serve as co-lead interim class counsel in the Google Location History 

Litigation, No. 5:18-cv-05062-EJD (N.D. Cal.) (Hon. Edward J. Davila), a consumer class action 

arising out of Google’s allegedly unlawful collection and use of mobile device location information 

on all Android and iPhone devices. 

AW serves on the Plaintiffs’ Executive Committees in Allergan Biocell Textured Breast Implant 

Products Liability Litigation, No. 2:19-md-02921-BRM-JAD (D.N.J.) (Hon. Brian R. Martinotti), a class 

action alleging textured breast implants caused a rare type of lymphoma and in ZF-TRW Airbag Control 

Units Products Liability Litigation, No. 2:19-ml-02905-JAK-FFM (C.D. Cal.) (Hon. John A. Kronstadt), a 

class action alleging a dangerous defect in car airbag component units. 

As part of the leadership team in Novoa v. The Geo Group, Inc., No. 5:17-cv-02514-JGB-SHK 

(C.D. Cal.) (Hon. Jesus G. Bernal), AW certified a class of immigration detainees challenging private 

prison’s alleged forced labor practices. 

In the Google Digital Advertising Antitrust Litigation, No. 1:21-md-03010-PKC (S.D.N.Y.) (Hon. 

P. Kevin Castel), a class action alleging monopolization of the digital advertising market, Ms. 

Wolfson and AW are serving as court appointed co-lead counsel on behalf of the advertiser class. 

In the Dental Supplies Antitrust Litigation, No. 1:16-cv-00696-BMC-GRB (E.D.N.Y.) (Hon. 

Brian M. Cogan), a class action alleging an anticompetitive conspiracy among three dominant dental 

supply companies in the United States, AW served on the plaintiffs’ counsel team that brought in 

an $80 million cash settlement for the benefit of a class of approximately 200,000 dental 

practitioners, clinics, and laboratories. 

In Klein v. Meta Platforms, Inc., No. 3:20-cv-08570-JD (N.D. Cal.) (Hon. James Donato), Ms. 

Wolfson and AW are serving on the Executive Committee for the digital advertiser plaintiff class in 

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a class action alleging that Meta (formerly Facebook) engaged in anticompetitive conduct to stifle 

and/or acquire competition to inflate the cost of digital advertising on its social media platform. 

Many of the plaintiffs’ claims recently survived a motion to dismiss and are in the process of 

amending their complaint.

In Robinson v. Jackson Hewitt, Inc., No. 2:19-cv-09066-JXN-ESK (D.N.J.) (Hon. Julien Xavier 

Neals), a class action alleging that a standardized “no-poach” agreement among Jackson Hewitt and 

its franchisees limited mobility and compensation prospects for the tax preparer employees, AW is 

asserting claims on behalf of consumers under both federal antitrust and California employment 

laws. 

Attorney Profiles 

Tina Wolfson graduated Harvard Law School cum laude in 1994. Ms. Wolfson began her 

civil litigation career at the Los Angeles office of Morrison & Foerster, LLP, where she defended 

major corporations in complex actions and represented indigent individuals in immigration and 

deportation trials as part of the firm’s pro bono practice. She then gained further invaluable litigation 

and trial experience at a boutique firm, focusing on representing plaintiffs on a contingency basis in 

civil rights and employee rights cases. Since co-founding AW in 1998, Ms. Wolfson has led 

numerous class actions to successful results. Ms. Wolfson is a member of the California, New York 

and District of Columbia Bars. 

Recognized for her deep class action experience, Ms. Wolfson frequently lectures on 

numerous class action topics across the country. She is a guest lecturer on class actions at the 

University of California at Irvine Law School. Her recent notable speaking engagements include: 

• Class Action Mastery Forum at the University Of San Diego School of Law (Consumer

Class Actions Roundtable) March 2020, featuring Hon. Lucy H. Koh, Hon. Edward M.

Chen, and Hon. Fernando M. Olguin.

• Class Action Mastery Forum at the University Of San Diego School of Law (Data

Breach/Privacy Class Action Panel) January 16, 2019.

• Association of Business Trial Lawyers: “Navigating Class Action Settlement Negotiations

and Court Approval: A Discussion with the Experts,” Los Angeles May 2017, featuring

Hon. Philip S. Gutierrez and Hon. Jay C. Gandhi.

• CalBar Privacy Panel: “Privacy Law Symposium: Insider Views on Emerging Trends in

Privacy Law Litigation and Enforcement Actions in California,” Los Angeles Mar. 2017

(Moderator), featuring Hon. Kim Dunning.

• American Conference Institute: “2nd Cross-Industry and Interdisciplinary Summit on

Defending and Managing Complex Class Actions,” April 2016, New York: Class Action

Mock Settlement Exercise featuring the Hon. Anthony J. Mohr.

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 10 of 15 PageID #:3956


• Federal Bar Association: N.D. Cal. Chapter “2016 Class Action Symposium,” San 

Francisco Dec. 2016 (Co-Chair), featuring Hon. Joseph F. Anderson, Jr. and Hon. Susan 

Y. Illston. 

• Federal Bar Association: “The Future of Class Actions: Cutting Edge Topics in Class 

Action Litigation,” San Francisco Nov. 2015 (Co-Chair &Faculty), featuring Hon. Jon 

S. Tigar and Hon. Laurel Beeler. 

Ms. Wolfson currently serves as a Ninth Circuit Lawyer Representative for the Central 

District of California, as Vice President of the Federal Litigation Section of the Federal Bar 

Association, as a member of the American Business Trial Lawyer Association, as a participant at the 

Duke Law School Conferences and the Institute for the Advancement of the American Legal System, 

and on the Board of Public Justice. 

Theodore W. Maya graduated from UCLA Law School in 2002 after serving as Editor-inChief of the UCLA Law Review. From July 2003 to August 2004, Mr. Maya served as Law Clerk to 

the Honorable Gary Allen Feess in the United States District Court for the Central District of 

California. Mr. Maya was also a litigation associate in the Los Angeles offices of Kaye Scholer LLP 

for approximately eight years where he worked on a large variety of complex commercial litigation 

from inception through trial. Mr. Maya was named “Advocate of the Year” for 2007 by the 

Consumer Law Project of Public Counsel for successful pro bono representation of a victim of a 

large-scale equity fraud ring. As a partner at AW, Mr. Maya has extensive experience litigating all 

aspects of complex and consumer class actions and has successfully taken cases through trial and 

appeal. 

Bradley K. King is a member of the State Bars of California, New Jersey, New York, and the 

District of Columbia. He graduated from Pepperdine University School of Law in 2010, where he 

served as Associate Editor of the Pepperdine Law Review. He worked as a law clerk for the California 

Office of the Attorney General, Correctional Law Section in Los Angeles and was a certified law 

clerk for the Ventura County District Attorney’s Office. Mr. King began his legal career at a boutique 

civil rights law firm, gaining litigation experience in a wide variety of practice areas, including 

employment law, police misconduct, municipal contracts, criminal defense, and premises liability 

cases. During his career at AW, Mr. King has focused on consumer class actions, with experience in 

privacy, product liability, and antitrust class actions. He has served as appointed interim lead counsel 

and has extensive experience litigating consolidated and MDL class actions with AW, including 

numerous large data breach cases that have resulted in nationwide class settlements. 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 11 of 15 PageID #:3957
Exhibit 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 12 of 15 PageID #:3958
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

HOUR

RAT

Tina Wolfson (P) 12.60 5.70 24.50 7.40 1.90 17.80 24.70 0.00 94.60 94.60 $950

Theodore Maya (P) 4.70 18.40 1.60 33.70 0.00 58.40 58.40 $900

Bradley King (P) 0.70 0.70 3.50 18.90 0.00 23.80 23.80 $750

Rachel Johnson (A) 1.40 2.50 4.70 7.50 0.00 16.10 16.10 $500

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 0.00 18.00 6.40 47.80 0.00 9.90 0.00 0.00 6.60 38.30 0.00 65.90 0.00 0.00 0.00 0.00 192.90 192.90 

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

HOUR

RAT

Samantha Benson (PL) 5.20 0.00 5.20 5.20 $250

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 0.00 0.00 0.00 5.20 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.20 5.20 GRAND TOTAL: 0.00 18.00 6.40 53.00 0.00 9.90 0.00 0.00 6.60 38.30 0.00 65.90 0.00 0.00 0.00 0.00 198.10 198.10 

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) Par(A) Ass(LC) L(SPL) S(PL) Pa

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT CURRENT RATES

Ahdoot & Wolfson, PC Reporting Period: Inception through February 28, 2022

 556281 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 13 of 15 PageID #:39
Exhibit 

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 14 of 15 PageID #:3960
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees $400.00

Experts/consultants

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw $521.34

Photocopies - in House

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap) $391.82

Travel - Hotels

Miscellaneous mileage re source code review $32.44

TOTAL EXPENSES $1,345.60

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: Ahdoot & Wolfson, PC

REPORTING PERIOD: Inception through February 28, 2022

 556281 Ex 2 Expense Summary

Case: 1:20-cv-04699 Document #: 197-26 Filed: 03/31/22 Page 15 of 15 PageID #:3961