EXHIBIT N 

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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 DANIEL O. HERRERA IN SUPPORT OF PLAINTIFFS’ 

PETITION FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF 

CAFFERTY CLOBES MERIWETHER & SPRENGEL LLP 

 I, DANIEL O. HERRERA, declare and state as follows: 

1. I am a partner of the law firm of Cafferty Clobes Meriwether & Sprengel 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: investigate and research the alleged statutory violations that gave rise to these 

consolidated actions; investigate relevant factual and legal issues, and draft and file individual and 

consolidated complaints on behalf of the firm’s client and the Class at large; work to organize the 

various cases originally filed on behalf of certain Plaintiffs in this District and, later, those 

transferred to this District; draft and respond to the Motion for Transfer filed with the JPML; assist 

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in the drafting of the consolidated complaint filed following transfer, as well as drafting and 

preparing critical discovery; and assist all counsel in preparing for mediation. The total number of 

hours expended on this litigation by my firm from case inception through October 31, 2020, is 

370.7 hours. The total lodestar for my firm in this time period is $267,160.00. 

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: monitor activities relating to preliminary and final approval in order to ensure 

the firm’s client was made aware of related activities, and assist the firm’s client in preparing, 

submitting and finalizing their claim. 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 34.8 hours. The 

total lodestar for my firm in this time period is $19,665.00. 

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

inception through February 28, 2022, is 405.5 hours. The total lodestar for my firm is $286,825.00. 

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. 

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6. As detailed in Exhibit 3, my firm has incurred a total of $995.05 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. 

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 23rd day of March, 2022 at Chicago, Illinois. 

 

 s/ Daniel O. Herrera 

 DANIEL O. HERRERA 

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Exhibit 

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 www.caffertyclobes.com

Successful Solutions for Complex Litigation

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Firm Overview 

Cafferty Clobes Meriwether & Sprengel LLP combines the talents of attorneys with 

a wide range of experience in complex civil litigation. The skill and experience of 

CCMS attorneys has been recognized on repeated occasions by courts that have 

appointed these attorneys to major positions in complex multidistrict or 

consolidated litigation. As the representative sampling of cases listed below 

demonstrates, these attorneys have taken a leading role in numerous important 

actions on behalf of investors, employees, consumers, businesses and others. In 

addition, CCMS attorneys are currently involved in a number of pending class 

actions, as described on the Firm’s web page. 

Consumer Class Actions 

x Skeen v. BMW of N. Amer., LLC, No. 13-cv-1531 (D.N.J.) 

CCMS served as co-lead counsel in an action brought on behalf of owners 

of certain MINI Cooper-brand vehicles that contained a latent defect in a 

part of the engine known as the “timing chain tensioner” which caused the 

part to fail prematurely, eventually requiring replacement of that part or the 

entire engine. Following extensive discovery and mediation, the parties 

reached a global settlement on behalf of a nationwide class of vehicle 

owners. The efforts of the firm and its co-lead counsel resulted in a 

settlement which significantly extended warranty coverage, and reimbursed 

vehicle owners for tens of millions of dollars in out-of-pocket expenses 

incurred for repair and/or replacement. 

x Ponzo v. Watts Regulator Company, 1:14-cv-14080 (D. Mass.); Klug v. 

Watts Regulator Company, No. 15-cv-00061 (D. Neb.)

These consumer class cases, first brought by CCMS (D. Mass.) 

addressed defective water heater and “Floodsafe” branded connectors. 

The plaintiffs in both cases alleged that the water heater connectors were 

made of a material that would break down during regular use, causing 

leaks and ruptures that flooded class members’ homes. The efforts of the 

firm and its co-lead counsel resulted in a settlement that provides $14 

million to affected homeowners. 

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x In re Frontier Airlines Litigation, 20-cv-00063-WJM-KLM, Dkt. 52 (D. Colo.) 

CCMS serves as interim co-lead counsel in action alleging Frontier has 

wrongfully refused to issue refunds for flights cancelled as a direct and 

proximate result of the COVID-19 crisis. 

x Compo v. United Airlines, Inc., et al., No. 1:20-cv-02166 (N.D. Ill.); 

CCMS serves as interim co-lead counsel in action alleging United has 

wrongfully refused to issue refunds for flights cancelled as a direct and 

proximate result of the COVID-19 crisis. 

x Han, et al. v. Vail Resorts, Inc., 20-cv-01121-RBJ (D. Colo.) 

CCMS serves as interim lead counsel in class action brought by plaintiffs 

who purchased season passes or Epic Passes for the 2019-2020 ski 

season. Plaintiffs allege that after Defendant closed its ski resorts early due 

to the COVID-19 pandemic, class members were unable to use the 

remaining value in their passes, and Defendant has refused to refund 

Plaintiffs and Class members for the unusable portion of the passes. 

x Traxler v. PPG Industries, Inc., No. 15-cv-00912 (N.D. Ohio) 

CCMS served as lead counsel in this defective product action challenging 

certain defective deck resurfacing products. The products did not adhere 

properly, and instead peeled, cracked, bubbled and severely damaged the 

surfaces to which they were applied. In February 2017 the parties reached 

an agreement in principle to settle the case on behalf of a nationwide class 

of consumers. The efforts of the firm and its co-counsel resulted in a 

settlement that provides $6.5 million to affected homeowners. 

x Apple iPhone Warranty Litigation (N.D. Cal.) 

This case challenged Apple’s policy of denying warranty claims based on 

liquid contact indicators located in headphone jacks and dock connector 

ports of iPhones and iPod touches. Similar class actions were subsequently 

filed in federal courts on behalf of Apple consumers. CCMS helped 

negotiate and achieve a $53 million settlement of the state and federal 

cases. 

x In re Volkswagen “Clean Diesel” Marketing, Sales Practices and Prod. 

Liability Litig., MDL No. 2672 (N.D. Cal.) 

CCMS worked closely with lead counsel and other class counsel in this 

class case challenging unlawful actions by the manufacturer defendants to 

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mask the actual diesel emission levels in various vehicle makes and 

models. Judge Beyer approved a class settlement with defendants worth 

billions of dollars. 

x In re Takata Airbag Prod. Liability Litig., MDL No. 2599 (S.D. Fla.) 

CCMS represents six named Class Plaintiffs and has been and continues 

to work closely with lead counsel on this multi-billion dollar case involving 

defective airbags installed in tens of millions of affected vehicles 

manufactured by most major manufacturers. Class settlements with Honda 

and BMW providing class members with hundreds of millions of dollars and 

substantial programmatic relief have been finally approved and are the 

subject of pending appeals. 

x In re General Motors Corp. Air Conditioning Marketing and Sales 

Practices Litig., MDL No. 2818 (E.D. Mich.) 

After conducting a significant pre-suit investigation, CCMS filed the first 

class action in the Eastern District of Michigan seeking relief on behalf of 

owners of GM vehicles suffering from a defect in the air conditioning system 

which typically results in total system failure, necessitating significant 

repairs thereto. Since commencing the action, CCMS has communicated 

with dozens of affected consumers and worked with GM assess the scope 

and nature of an extended warranty program GM implemented in a 

purported effort to resolve the claims of certain vehicle owners. On April 

11, 2018, the Court appointed CCMS co-lead counsel. 

x Squires et al., v. Toyota Motor Corp., et al., No. 18-cv-00138 (E.D. Tex.)

CCMS investigated, originated and filed the first and only consumer class 

action brought on behalf of owners of multi-model year Toyota Prius 

vehicles that suffer from a defect that causes windshields to crack and fail 

in ordinary and foreseeable driving conditions. Plaintiffs allege that 

Defendants have breached express and implied warranties, and have 

violated the consumer protection statutes of various States. 

x Gonzalez, et al., v. Mazda Motor Corp., et al., No. 16-cv-2087 (N.D. Cal.) 

CCMS is lead counsel in a consumer class action brought on behalf of 

owners of Model Year 2010-15 Mazda3 vehicles with defective clutch 

assemblies that cause them to prematurely fail. Plaintiffs allege that 

Defendants have breached express and implied warranties, and have 

violated the consumer protection statutes of various states. See, e.g.,

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Gonzalez v. Mazda Motor Corp., No. 16-CV-02087-MMC, 2017 WL 345878 

(N.D. Cal. Jan. 5, 2017) (denying and granting in part Defendants’ motion 

to dismiss). 

x Albright v. The Sherwin-Williams Company, No. 17-cv-02513 (N.D. 

Ohio)

CCMS is serving as Co-Lead Counsel in this class action concerning deck 

resurfacing products sold under the Duckback and SuperDeck brand 

names. Plaintiffs allege that defendants have breached express and 

implied warranties, and have violated the consumer protection statutes of 

various states. 

x Anderson v. Behr Process Corp., No. 1:17-cv-08735 (N.D. Ill.)

CCMS is serving as Co-Lead Counsel in this class action brought on behalf 

of purchasers of various deck coating products from 2012 through the 

present. After many months of mediation and settlement negotiations, and 

successfully opposing efforts by other plaintiffs and firms to have the JPML 

centralize pending cases, the parties have agreed to a proposed Class 

settlement which will provide substantial valuable monetary relief to Class 

members to refund the cost of product purchased as well as compensate 

them for damage to their decks and the costs of restoring and repairing the 

same. 

x Bergman v. DAP Products, Inc., 14-cv-03205 (D. Md.) 

CCMS served as lead counsel in this class action on behalf of consumers 

who purchased various models of “XHose” garden hoses, which were 

flexible outdoor hoses that were predisposed to leaking, bursting, seeping, 

and dripping due to design defects. The court approved a nationwide 

settlement providing hundreds of thousands of consumer class members 

with the opportunity to recover a substantial portion of their damages. 

x In re Midway Moving & Storage, Inc.’s Charges to Residential 

Customers, No. 03 CH 16091 (Cir. Ct. Cook Cty., Il.) 

A class action on behalf of customers of Illinois’ largest moving company. 

A litigation class was certified and upheld on appeal. See Ramirez v. 

Midway Moving and Storage, Inc., 880 N.E.2d 653 (Ill. App. 2007). On the 

eve of trial, the case settled on a class-wide basis. The court stated that 

CCMS is “highly experienced in complex and class action litigation, 

vigorously prosecuted the Class’ claims, and achieved an excellent 

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Settlement for the Class under which Class members will receive 100% of 

their alleged damages.” 

x Walter Cwietniewicz d/b/a Ellis Pharmacy, et al. v. Aetna U.S. 

Healthcare, June Term, 1998, No. 423 (Pa. Common Pleas)

On May 25, 2006, the court granted final approval to a settlement of a class 

action brought on behalf of pharmacies that participated in U.S. 

Healthcare’s capitation program seeking to recover certain required semiannual payments. At the final approval hearing, the court found that “this 

particular case was as hard-fought as any that I have participated in” and 

with respect to the Class’s reaction to the settlement achieved as a result 

of our firm's work: “. . . a good job, and the reason there should be no 

objection, they should be very very happy with what you have done.” 

x Davitt v. American Honda Motor Co., Inc., No. 13-cv-381 (D.N.J.) 

CCMS served as plaintiffs’ counsel in a class action brought on behalf of 

owners of 2007-09 Honda CRV vehicles that suffered from a defect that 

predisposed the door-locking mechanisms to premature failure. Following 

extensive dismissal briefing, discovery and mediation, the parties arrived at 

a global settlement that provided class members with extended warranty 

coverage for the defect and reimbursement of out-of-pocket expenses 

incurred in connection therewith. 

x Sabol v. Ford Motor Company, No. 2:14-cv-06654 (E.D. Pa.) 

CCMS served as Lead Counsel in this class case brought on behalf of 

owners of various model 2010-2015 Ford, Volvo and Land Rover vehicles 

allegedly including a defect in certain Ecoboost engines. Defendant 

claimed it addressed and repaired the problem through a series of recalls 

and repairs. After briefing summary judgment and class certification, and 

several years of hard fought litigation, including substantial discovery, the 

parties entered into a settlement providing substantial monetary and other 

relief. 

x Lax v. Toyota Motor Corp., No. 14-cv-1490 (N.D. Cal.) 

CCMS served as class counsel in an action brought on behalf of owners of 

certain Toyota-brand vehicles that contained a defect which caused 

vehicles to consume oil at accelerated rates, often resulting in catastrophic 

engine failure. Following extensive discovery and mediation, the parties 

reached a private settlement following Toyota’s implementation of an 

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extended warranty and reimbursement program for affected vehicles. ECF 

No. 82. 

Antitrust Class Actions and Litigation 

x In re Insurance Brokerage Antitrust Litig., MDL No. 1663 (D.N.J.)

CCMS served as Co-Lead Counsel for plaintiffs in this class case alleging 

that insurance brokers and insurers conspired to allocate customers in a 

complicated scheme to maximize their own revenues at the expense of 

class members. The litigation concluded in 2013 with final approval of the 

last of five separate settlements that, in total, exceeded $270 million. Judge 

Cecchi observed that “Class counsel include notably skilled attorneys with 

experience in antitrust, class actions and RICO litigation.” In re Insurance 

Brokerage Antitrust Litig., 297 F.R.D. 136, 153 (D.N.J 2013); see also In re 

Insurance Brokerage Antitrust Litig., MDL No. 1663, 2007 WL 1652303, at 

*6 (D.N.J. June 5, 2007). 

x VisaCheck/MasterMoney Antitrust Litig., Master File No. 96-5238 

(E.D.N.Y.)

CCMS’s client, Burlington Coat Factory Warehouse, and the other plaintiffs, 

alleged that Visa and MasterCard violated the antitrust laws by forcing 

retailers to accept all of their branded cards as a condition of acceptance 

of their credit cards. The parties entered into settlement agreements that 

collectively provided for the payment of over $3.3 billion, plus widespread 

reforms and injunctive relief. 

x In Re VisaCheck/MasterMoney Antitrust Litig., Master File No. 96-5238 

(E.D.N.Y.)

CCMS’s client, Burlington Coat Factory Warehouse, and the other plaintiffs, 

alleged that Visa and MasterCard violated the antitrust laws by forcing 

retailers to accept all of their branded cards as a condition of acceptance 

of their credit cards. The parties entered into settlement agreements that 

collectively provided for the payment of over $3.3 billion, plus widespread 

reforms and injunctive relief. 

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x In re National Collegiate Athletic Association Athletic Grant-in-Aid 

Cap Antitrust Litig., No. 4:14-md-02541 (N.D. Cal.)

CCMS represented a former Division 1 college basketball player in this 

antitrust litigation challenging the cap imposed by the NCAA on grant-inaid packages. The efforts of the firm and its co-counsel resulted in 

certification of an injunctive class and a settlement of $209 million. 

x Kamakahi v. American Society for Reproductive Medicine, No. 3:11-cv01781 (N.D. Cal.)

CCMS served as Co-Lead Counsel in a cutting edge antitrust case 

challenging the legality of ethical guidelines promulgated by two 

professional associations that limited the compensation members were 

permitted to pay to women providing donor services for in-vitro fertilization. 

Without the benefit of a parallel government case or investigation, CCMS 

achieved a groundbreaking settlement that required defendants to eliminate 

the compensation caps and to refrain from imposing similar caps in the 

future. 

x In re New Motor Vehicles Canadian Export Antitrust Litig., MDL No. 

1532 (D. Me.) 

CCMS served as Class Counsel in multidistrict litigation alleging that 

automobile manufacturers and other parties conspired to prevent lower 

priced new motor vehicles from entering the American market thereby 

artificially inflating prices. The court approved a $37 million settlement with 

Toyota and the Canadian Automobile Dealers’ Association. 

x In re TriCor Indirect Purchaser Antitrust Litig., No. 05-360 (D. Del) 

CCMS served as Lead Counsel for consumer and third-party payor plaintiffs 

who alleged that defendants engaged in unlawful monopolization in the 

market for fenofibrate products, which are used to treat high cholesterol and 

high triglyceride levels. The court approved to a $65.7 million settlement 

(an amount that excludes an initial payment to opt-out insurance 

companies). 

x In re Prandin Direct Purchaser Antitrust Litig., Civ. No. 10-12141 (E.D. 

Mich.) 

CCMS served as Co-Lead counsel for a plaintiff class of direct purchasers 

of the prescription drug repaglinide, which is manufactured and marketed 

by Novo Nordisk under the brand-name Prandin. Plaintiffs alleged that 

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Novo Nordisk blocked FDA approval of generic versions of the drug by 

wrongfully manipulating the language of the “use code” filed with the FDA 

in connection with a method of use patent. The court approved a $19 million 

settlement. 

x In Re Restasis (Cyclosporine Ophthalmic Emulsion) Antitrust 

Litigation, MDL No. 2819 (E.D.N.Y) 

CCMS is a member of the Executive Committee representing a putative 

class of indirect purchasers of Restasis, an eye-drop used to treat dry-eye 

syndrome, and allege that Defendant Allergan engaged in various 

anticompetitive activities to illegally prolong the life of its patents over 

Restasis, and to otherwise forestall the entry of generic competition into the 

cyclosporine market. 

x In re Disposable Contact Lens Antitrust Litigation, MDL No. 2626 (M.D. 

Fla.) 

CCMS serves on the Defendant Discovery Committee, which is tasked with 

overseeing all aspects of discovery pertaining to Defendants, who are 

alleged to have conspired to implement retail price maintenance 

agreements intended to inflate the prices of disposable contact lenses to 

supracompetitive levels. Plaintiffs already have secured an $8 million 

settlement from Defendant CooperVision. 

x In re Automotive Parts Antitrust Litig., MDL No. 2311 (E.D. Mich.)

CCMS has served as a member of Plaintiffs’ Executive Committee 

representing the end-payor class in one of the largest civil antitrust actions 

in US history. As a member of the Executive Committee, CCMS has played 

an important role in this groundbreaking litigation in which plaintiffs have 

recovered over $1 billion on behalf of end-payor consumers and businesses 

who allege they purchased or leased new automobiles at prices that were 

artificially inflated as a result of automotive component manufacturers' 

anticompetitive conduct. 

x Nichols v. SmithKline Beecham Corp., No. Civ.A.00-6222 (E.D. Pa.) 

CCMS served as Co-Lead Counsel for consumers and third-party payors 

who alleged that the manufacturer of the brand-name antidepressant Paxil 

misled the U.S. Patent Office into issuing patents that protected Paxil from 

competition from generic substitutes. The court approved a $65 million 

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class action settlement for the benefit of consumers and third-party payors 

who paid for Paxil. 

x In re Relafen Antitrust Litig. No. 01-12239 (D. Mass.) 

The court approved a $75 million class action settlement for the benefit of 

consumers and third-party payors who paid for branded and generic 

versions of the arthritis medication Relafen. In certifying an exemplar class 

of end-payors, the court singled out our Firm as experienced and vigorous 

advocates. See In re Relafen Antitrust Litig., 221 F.R.D. 260, 273 (D. Mass. 

2004). In the opinion granting final approval to the settlement, the court 

commented that “Class counsel here exceeded my expectations in these 

respects [i.e., experience, competence, and vigor] in every way.” In re 

Relafen Antitrust Litig., 231 F.R.D. 52, 85 (D. Mass. 2005); see also id. at 

80 (“The Court has consistently noted the exceptional efforts of class 

counsel.”). 

x In re Warfarin Sodium Antitrust Litig., MDL 98-1232 (D. Del.) 

Multidistrict class action on behalf of purchasers of Coumadin, the brandname warfarin sodium manufactured and marketed by DuPont 

Pharmaceutical Company. Plaintiffs alleged that the defendant engaged in 

anticompetitive conduct that wrongfully suppressed competition from 

generic warfarin sodium. The Court approved a $44.5 million settlement. 

x In re Cardizem CD Antitrust Litig., MDL No. 1278 (E.D. Mich.) 

Multidistrict class action on behalf of purchasers of Cardizem CD, a brandname heart medication. Plaintiffs alleged that an agreement between the 

brand manufacturer and a generic manufacturer unlawfully stalled generic 

competition. The court approved an $80 million settlement for the benefit 

of consumers, third-party payors and state attorneys general. 

x In re Synthroid Marketing Litig., MDL No. 1182 (N.D. Ill) 

This multidistrict action arose out of alleged unlawful activities with respect 

to the marketing of Synthroid, a levothyroxine product used to treat thyroid 

disorders. The court approved a consumer settlement in the amount of 

$87.4 million. 

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Commodities Litigation 

x Ranchers Cattlemen Action Legal Fund United Stockgrowers of 

America, et al., v. Tyson, et al., 19-cv-01222-JRT-HB (D. Minn.) 

CCMS serves as interim co-lead counsel in this case involving alleged 

manipulation of cattle and cattle futures prices by major meatpackers, as 

well as an antitrust conspiracy. 

x In re Deutsche Bank Spoofing Litig.., 20-cv-03638 (N.D. Ill.). 

CCMS serves as interim co-lead counsel in this case involving alleged 

manipulation through spoofing of Treasury and Eurodollar Futures. 

x In re Libor-Based Financial Instruments, 11-md-2262 (S.D.N.Y) 

CCMS serves as class counsel for exchange trader plaintiffs in claims 

involving manipulation in violation of the Commodity Exchange Act against 

many of the world’s largest financial institutions. 

x Hershey/Kohen v. Pacific Investment Management Co. LLC, No. 05 C 

4681 (N.D. Ill.)

As liaison and class counsel in action arising from PIMCO’s manipulation 

of 10-year treasury notes futures traded on the Chicago Board of Trade, 

CCMS helped secure a $118 million settlement for the class. 

x In re Crude Oil Commodity Futures Litig., No. 11-cv-03600 (S.D.N.Y.)

As class counsel in action arising from manipulation of NYMEX West Texas 

Intermediate grade crude oil futures contracts, CCMS expended significant 

resources assisting the class with investigation and discovery. The 

collective efforts resulted in a $16.5 million settlement for the class. 

x In re Foreign Exchange Benchmark Rates Antitrust Litigation, 13-cv7789 (S.D.N.Y.) 

As class counsel in this action arising from manipulation of foreign 

exchange rates by international banks and others, CCMS has devoted 

significant resources toward investigation, discovery, and allocation of more 

than $2 billion in settlements for the class. 

x In re Sumitomo Copper Litig., 96 Civ. 4584(MP) (S.D.N.Y.) 

As class counsel in action arising out of manipulation of the world copper 

market, CCMS helped achieve settlements aggregating $134.6 million. In 

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awarding attorneys’ fees, Judge Milton Pollack noted that it was “the largest 

class action recovery in the 75 plus year history of the Commodity 

Exchange Act.” 74 F. Supp. 2d 393 (S.D.N.Y. Nov. 15, 1999). 

x In re Soybean Futures Litig., No. 89 C 7009 (N.D. Ill.) 

As class counsel in this action against Ferruzzi Finanziaria SpA and related 

companies for unlawfully manipulating the soybean futures market, CCMS 

helped recover a $21.5 million settlement. 

x Lawrence E. Jaffe Pension Plan v. Household International, Inc., No. 

1:02-cv-05893 (N.D. Ill.)

Securities fraud class action. CCMS served as local counsel and helped 

recover a settlement of approximately $1.6 billion. 

x In re Kaiser Group International, Case No. 00-2263 (Bankr. D. Del.)

On December 7, 2005, Chief Judge Mary F. Walrath of the United States 

Bankruptcy Court for the District of Delaware granted final approval to a 

settlement that produced 175,000 shares of common stock for a class of 

former shareholders of ICT Spectrum Constructors, Inc. (a company that 

merged with ICF Kaiser Group International and ICF Kaiser Advanced 

Technology in 1998). The settlement followed Judge Joseph J. Farnan’s 

ruling which upheld the Bankruptcy Court’s decision to award common 

stock of the new Kaiser entity (Kaiser Group Holdings, Inc.) to the Class 

of former Spectrum shareholders based on contractual provisions within 

the merger agreement. See Kaiser Group International, Inc. v. James D. 

Pippin (In re Kaiser Group International), 326 B.R. 265 (D. Del. 2005). 

x Danis v. USN Communications, Inc., No. 98 C 7482 (N.D. Ill.) 

Securities fraud class action arising out of the collapse and eventual 

bankruptcy of USN Communications, Inc. On May 7, 2001, the court 

approved a $44.7 million settlement with certain control persons and 

underwriters. Reported decisions: 73 F. Supp. 2d 923 (N.D. Ill. 1999); 189 

F.R.D. 391 (N.D. Ill. 1999); 121 F. Supp. 2d 1183 (N.D. Ill. 2000). 

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Individual Biographies 

PARTNERS 

PATRICK E. CAFFERTY graduated from the 

University of Michigan, with distinction, in 1980 and 

obtained his J.D., cum laude, from Michigan State 

University College of Law in 1983. From 1983 to 1985, 

he served as a prehearing attorney at the Michigan 

Court of Appeals and as a Clerk to Judge Glenn S. 

Allen, Jr. of that Court. Mr. Cafferty is an experienced 

litigator in matters involving antitrust, securities, 

commodities, and the pharmaceutical industry. In 2002, 

Mr. Cafferty was a speaker at a forum in Washington 

D.C. sponsored by Families USA and Blue Cross/Blue Shield styled “Making the 

Drug Industry Play Fair.” At the Health Action 2003 Conference in Washington 

D.C., Mr. Cafferty was a presenter at a workshop titled “Consumers’ Access to 

Generic Drugs: How Brand Manufacturers Can Derail Generic Drugs and How to 

Make Them Stay on Track.” In 2010, Mr. Cafferty made a presentation on indirect 

purchaser class actions at the American Antitrust Institute’s annual antitrust 

enforcement conference. See Indirect Class Action Settlements (Am. Antitrust 

Inst., Working Paper No. 10-03, 2010). Mr. Cafferty is admitted to the state bars 

of Michigan and Illinois, and holds several federal district and appellate court 

admissions. Mr. Cafferty has attained the highest rating, AV®, from MartindaleHubbell and is a top rated SuperLawyer®. 

BRYAN L. CLOBES is a 1988 graduate of the 

Villanova University School of Law and received his 

undergraduate degree from the University of Maryland. 

Mr. Clobes clerked for Judge Arlin M. Adams of the 

United States Court of Appeals for the Third Circuit, 

Judge Mitchell H. Cohen of the United States District 

Court for the District of New Jersey, and Judge Joseph 

Kaplan of the Maryland Circuit Court in Baltimore. 

From 1989 through June, 1992, Mr. Clobes served as 

Trial Counsel to the Commodity Futures Trading Commission in Washington, D.C. 

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Mr. Clobes has served as lead counsel in many of the firm’s class cases covering 

all areas of the firm’s practice, and is widely recognized as an expert in class 

action litigation. Mr. Clobes has authored briefs filed with the Supreme Court in 

a number of class cases, served as a panelist for class action, consumer and 

antitrust CLE programs, has sustained and maintained the highest rating, AV®, 

from Martindale-Hubbell, and has been named a “Super Lawyer” for the past 

twelve years. Mr. Clobes is admitted to the bar in New Jersey and Pennsylvania, 

and admitted to practice in several federal district and appellate court admissions. 

DANIEL O. HERRERA received his law degree, 

magna cum laude, and his MBA, with a concentration in 

finance, from the University of Illinois at UrbanaChampaign in 2008. Mr. Herrera received his 

bachelor’s degree in economics from Northwestern 

University in 2004. Mr. Herrera joined CCMS as an 

associate in 2011 and is resident in its Chicago, Illinois 

Office. Since joining CCMS, Mr. Herrera has 

successfully prosecuted a wide range of antitrust, 

consumer and commodities class action. Prior to 

joining CCMS, Mr. Herrera was an associate in the trial practice of Mayer Brown 

LLP, a Chicago-based national law firm, where he defended corporations in 

securities and antitrust class actions, as well as SEC and DOJ investigations and 

enforcement actions. Mr. Herrera also routinely handled commercial matters on 

behalf of corporate clients. Mr. Herrera is licensed to practice in Illinois and holds 

several federal district and appellate court admissions. 

ELLEN MERIWETHER received her law degree 

from George Washington University, magna cum laude, 

in 1985. She was a member of the George Washington 

Law Review and was elected to the Order of the Coif. 

Ms. Meriwether received a B.A. degree, with highest 

honors, from LaSalle University in 1981. Ms. 

Meriwether is on the Board of Directors of the American 

Antitrust Institute (AAI), is Editorial Board Co-Chair of 

ANTITRUST, a publication by the section of Antitrust 

Law of the American Bar Association and serves as 

Vice-Chair of the Board of Directors of the Public Interest Law Center, in 

Philadelphia. Since 2010, Ms. Meriwether has been included in the US News and 

World Report Publication of “Best Lawyers in America” in the field of Antitrust. 

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She has been named a “Pennsylvania Super Lawyer” since 2005 and has attained 

the highest rating, “AV”, from Martindale-Hubbell. She is a frequent presenter on 

topics relating to complex, class action and antitrust litigation and has published 

a number of articles on subjects relating to class actions and antitrust litigation, 

including, among others: “The Fiftieth Anniversary of Rule 23: Are Class Actions 

on the Precipice?,” Antitrust, (Vol. 30, No. 2, Spring 2016); “Motorola Mobility and 

the FTAIA: If Not Here, Then Where?,” Antitrust, Vo. 29, No.2 Spring 2015); 

“Comcast Corp. v. Behrend: Game Changing or Business as Usual?,” Antitrust, 

(Vol. 27, No. 3, Summer 2013). Links to these articles and others authored by 

Ms. Meriwether can be found on the firm’s website. Ms. Meriwether is admitted 

to the bar of Supreme Court of Pennsylvania and is admitted in a number of 

federal district court and appellate court jurisdictions. 

NYRAN ROSE RASCHE received her 

undergraduate degree cum laude from Illinois 

Wesleyan University in 1995, was awarded a graduate 

teaching fellowship for law school, and earned her law 

degree from the University of Oregon School of Law in 

1999. Following law school, Ms. Rasche served as a 

law clerk to the Honorable George A. Van Hoomissen 

of the Oregon Supreme Court. She is the author of 

Protecting Agricultural Lands: An Assessment of the 

Exclusive Farm Use Zone System, 77 Oregon Law 

Review 993 (1998) and Market Allocation through Contingent Commission 

Agreements: Strategy and Results in In re Insurance Brokerage Antitrust Litigation 

(with Ellen Meriwether), The Exchange: Insurance and Financial Services 

Developments (Spring 2015). Since joining CCMS, Ms. Rasche has successfully 

prosecuted a wide range of antitrust, consumer class, securities and commodities 

class actions. Ms. Rasche has been admitted to practice in the state courts of 

Oregon and Illinois, as well as the United States District Courts for the Northern 

District of Illinois and the Southern District of Illinois. She is also a member of the 

American and Chicago Bar Associations. 

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JENNIFER WINTER SPRENGEL received her law 

degree from DePaul University College of Law, where 

she was a member of the DePaul University Law 

Review. Her undergraduate degree was conferred by 

Purdue University. Ms. Sprengel is an experienced 

litigator in matters involving commodities, antitrust, 

insurance and the financial industries. In addition, Ms. 

Sprengel is a committee member of the Seventh Circuit 

Electronic eDiscovery Pilot Program and is a frequent 

speaker regarding issues of discovery. Links to some 

of her presentations and articles can be found on the firm’s website. She also 

serves as co-chair of the Antitrust Law subcommittee of the ABA Class Action and 

Derivative Suits committee. She is admitted to practice law in Illinois, holds 

several federal district and appellate court admissions, and has attained the 

highest rating, AV®, from Martindale-Hubbell. Ms. Sprengel serves as the 

managing partner of the Firm. 

ASSOCIATES 

NICKOLAS J. HAGMAN received his 

undergraduate degree, magna cum laude, from the 

University of Minnesota in 2008. Mr. Hagman earned 

his law degree from Marquette University Law School, 

cum laude, in 2013, with a Certificate in 

Litigation. During law school, Mr. Hagman served as 

an associate editor of the Marquette Law Review, was 

a member of the Pro Bono Society, and worked as an 

intern for the late Wisconsin Supreme Court Justice N. 

Patrick Crooks, and current Wisconsin Supreme Court 

Justice Rebecca Dallet. Following law school, Mr. Hagman served as a judicial 

clerk in the Milwaukee County Circuit Court for two years. Prior to joining CCMS 

in 2019, Mr. Hagman was an associate at a plaintiff-side consumer class action 

firm for five years. Mr. Hagman is licensed to practice in Illinois and Wisconsin, 

and before the United State District Courts for the Northern District of Illinois and 

Eastern District of Wisconsin. He is also a member of the Wisconsin Bar 

Association and Chicago Bar Association, where he is a member of the Class 

Action and Consumer Committees. 

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EDWARD KHATSKIN earned his law degree from 

Washington University School of Law in St. Louis in 

2012, where he served as the Executive Articles Editor 

for the Washington University Journal of Law and 

Policy. While in Law School, Mr. Khatskin served as the 

Judicial Extern for the Honorable William Stiehl in the 

United States District Court for the Southern District of 

Illinois and interned at the St. Louis County Prosecuting 

Attorney’s Office. Mr. Khatskin graduated from St. 

Louis University with a bachelor’s degree in Finance. 

He is fluent in Russian. Prior to joining CCMS in 2021, Mr. Khatskin practiced in 

the St. Louis and Chicago Offices of a firm representing clients in a wide array of 

matters including: general and commercial litigation, personal injury, consumer 

protection and civil rights litigation. Mr. Khatskin is admitted to practice in the 

States of Illinois and Missouri, and before the District Courts for the Northern 

District of Illinois and the Southern District of Illinois. 

OLIVIA LAWLESS received her law degree from the 

University of Denver Sturm College of Law in 2020, with 

a Certificate of Specialization in Workplace Law. At 

Sturm, Ms. Lawless served as senior staff editor for the 

University of Denver Water Law Review and was a 

Teaching Assistant for Legal Writing and Constitutional 

Law. She also received the Scholastic Excellence 

Award and became the first Sturm Law Scholar to 

graduate from the University of Denver. Ms. Lawless is 

licensed to practice in Illinois. 

KAITLIN NAUGHTON received her law degree from 

the George Washington University Law School in 2019, 

where she served as managing editor for the George 

Washington Journal of Energy & Environmental Law. 

Ms. Naughton earned her bachelor’s degree in political 

science and sociology with distinction from Purdue 

University in 2015. Ms. Naughton joined CCMS in 2019 

and is resident in its Chicago, Illinois office. She is 

licensed to practice in Illinois and before the United 

State District Court for the Northern District of Illinois. 

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ALEXANDER SWEATMAN earned his law degree 

from the University of Notre Dame Law School in 2019, 

where he served as Managing Notes Editor for 

the Notre Dame Journal of Legislation. While in law 

school, Mr. Sweatman served as a judicial extern for 

the Honorable Thomas Donnelly in the Circuit Court of 

Cook County and participated in Notre Dame’s Public 

Defender Externship where he represented juveniles in 

initial hearings, sentencing proceedings, and probation 

modification hearings. Mr. Sweatman graduated summa cum laude from Wheaton 

College in 2016. Mr. Sweatman joined CCMS in 2021. He is a member of the 

Chicago Bar Association and is involved in its Antitrust Law Section and Civil 

Practice and Procedure Committee. Mr. Sweatman is licensed to practice in 

Illinois. 

SENIOR COUNSEL 

DOM J. RIZZI received his B.S. degree from DePaul 

University in 1957 and his J.D. from DePaul University 

School of Law in 1961, where he was a member of the 

DePaul University Law Review. From 1961 through 

1977, Judge Rizzi practiced law, tried at least 39 cases, 

and briefed and argued more than 100 appeals. On 

August 1, 1977, Judge Rizzi was appointed to the 

Circuit Court of Cook County by the Illinois Supreme 

Court. After serving as circuit court judge for 

approximately one year, Judge Rizzi was elevated to 

the Appellate Court of Illinois, First District, where he served from 1978 to 1996. 

Judge Rizzi became counsel to the firm in October 1996. 

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Exhibit 

Case: 1:20-cv-04699 Document #: 197-31 Filed: 03/31/22 Page 24 of 27 PageID #:4063
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

B. Clobes (P) 0.40 0.00 0.40 0.40 $1,000J. Sprengel (P) 7.90 1.60 1.70 0.70 0.00 11.90 11.90 $1,000

D. Herrera (P) 35.90 24.50 86.10 2.00 23.70 1.10 0.00 173.30 173.30 $800

N. Hagman (A) 18.90 52.90 93.00 1.30 30.30 0.00 196.40 196.40 $650

Name (A) 0.00 0.00 0.00 $0.0

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

SUB-TOTAL 0.00 63.10 77.40 0.00 180.70 0.00 0.00 0.00 3.30 0.00 55.70 1.80 0.00 0.00 0.00 0.00 382.00 382.00 

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

S. Nyland (PL) 3.30 17.40 0.00 20.70 20.70 $350

K. McDonald (PL) 2.30 0.50 0.00 2.80 2.80 $350

Name (LC) 0.00 0.00 0.00 $0.0

Name (SPL) 0.00 0.00 0.00 $0.0

Name (SPL) 0.00 0.00 0.00 $0.0

Name (SPL) 0.00 0.00 0.00 $0.0

Name (PL) 0.00 0.00 0.00 $0.0

Name (PL) 0.00 0.00 0.00 $0.0

Name (PL) 0.00 0.00 0.00 $0.0

Name (PL) 0.00 0.00 0.00 $0.0

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 0.00 2.30 0.00 0.00 3.80 0.00 0.00 0.00 0.00 0.00 0.00 17.40 0.00 0.00 0.00 0.00 23.50 23.50 GRAND TOTAL: 0.00 65.40 77.40 0.00 184.50 0.00 0.00 0.00 3.30 0.00 55.70 19.20 0.00 0.00 0.00 0.00 405.50 405.50 

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

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT CURRENT RATES

Cafferty Clobes Meriwether & Sprengel LLP Reporting Period: Inception through 2/28/22

 556281 

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Exhibit 

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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 $563.05

Photocopies - in House $32.00

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous

TOTAL EXPENSES $995.05

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: Cafferty Clobes Meriwether & Sprengel LLP

REPORTING PERIOD: Inception through 2/28/22

 556281 Ex 2 Expense Summary

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