EXHIBIT O 

Case: 1:20-cv-04699 Document #: 197-32 Filed: 03/31/22 Page 1 of 20 PageID #:4067
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 JOSEPH G. SAUDER IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF 

SAUDER SCHELKOPF LLC 

 I, Joseph G. Sauder, declare and state as follows: 

1. I am a partner of the law firm of Sauder Schelkopf 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 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: researching and drafting 

the JPML papers, drafting deposition by written questions to TikTok, investigating potential 

claims to include in a complaint, participation in numerous teleconferences between counsel, 

interviewing potential class members, and preparing a complaint. The total number of hours 

expended on this litigation by my firm from case inception through October 31, 2020, is 231.40 

hours. The total lodestar for my firm in this time period is $150,787.5. 

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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: reviewing the 

settlement and consulting with retained client regarding the settlement, working with the client to 

complete client questionnaire for co-lead counsel, and participating in meetings and 

teleconferences regarding the settlement. 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 23.20 hours. 

The total lodestar for my firm in this time period is $13,052.50. 

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

inception through February 28, 2022, is 254.60 hours. The total lodestar for my firm is 

$163,840.00. 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. 

 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 Berwyn, Pennsylvania. 

 

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_____________________________ 

 Joseph G. Sauder 

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Exhibit 

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Telephone: 888.711.9975 

Facsimile: 610.421.1326 

1109 Lancaster Avenue 

Berwyn, PA 19312 

www.sauderschelkopf.com 

 

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Attorneys Joseph G. Sauder 

 Matthew D. Schelkopf 

 Lori G. Kier 

 Joseph B. Kenney 

 Alice M. Elmer 

 

Practice Areas Automobile Defects and False Advertising 

 Consumer Fraud Class Actions 

 Sexual Misconduct and Gender Discrimination 

 Employee Rights Class Actions 

 General Complex Litigation 

 

Case Highlights 

 

 

 

 

 

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Joseph G. Sauder, Partner

Joseph G. Sauder handles complex cases on behalf 

of individuals, sexual misconduct victims, 

consumers, small businesses and employees. Mr. 

Sauder currently serves as court appointed lead 

counsel in state and federal courts across the country. 

He has successfully litigated cases against some of the 

largest companies in the world.

The Legal Intelligencer named Mr. Sauder in its 2020 Pennsylvania Trailblazers list 

recognizing 31 lawyers who “have taken extra measures to contribute to positive 

outcomes . . . and who are truly agents of change.” The Legal highlights Joe’s 

innovative work on advocacy as class counsel in large institutional sex abuse cover-ups, 

women's, and children's rights. Since 2012, Mr. Sauder has been selected by the

National Trial Lawyers Association as one of the Top 100 Trial Lawyers in 

Pennsylvania. Since 2011, Mr. Sauder has been selected as a Pennsylvania 

SuperLawyer, a distinction held by the top 5% of attorneys in PA, as chosen by their 

peers and through the independent research of Law & Politics. The American Lawyer 

Media, publisher of The Legal Intelligencer and the Pennsylvania Law Weekly, 

named Mr. Sauder as one of the “Lawyers on the Fast Track” a distinction that 

recognized thirty-five Pennsylvania attorneys under the age of 40 who show

outstanding promise in the legal profession and make a significant commitment to 

their community.

From 1998 to 2003, Mr. Sauder was a prosecutor in the Philadelphia District

Attorney’s Office where he tried hundreds of criminal cases to verdict. Mr. Sauder

received his Bachelor of Science, magna cum laude in Finance from Temple 

University in 1995. He graduated from Temple University School of Law in 1998, 

where he was a member of Temple Law Review.

Mr. Sauder is admitted to practice before the Supreme Courts of Pennsylvania and 

New Jersey, the United States Court of Appeals for the Third Circuit, the United 

States District Courts for the Eastern District of Pennsylvania, the Middle District of 

Pennsylvania, the District of New Jersey and the District of Colorado. Mr. Sauder 

currently serves as a lead counsel in numerous class actions related to product, 

construction and automotive defect cases pending throughout the country.

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Matthew D. Schelkopf, Partner

Matthew D. Schelkopf has extensive trial and

courtroom experience throughout the United States, 

with an emphasis on class actions involving 

automotive defects, consumer protection, defective 

products and mass torts litigation.

The Legal Intelligencer named Mr. Schelkopf in 

its 2020 Pennsylvania Trailblazers list recognizing 31 lawyers who “have taken extra 

measures to contribute to positive outcomes . . . and who are truly agents of 

change.” The Legal highlights Matthew’s work on behalf of clients who have been 

victimized by corporations. Since 2010, Mr. Schelkopf has been selected by

Pennsylvania Super Lawyers as a Rising Star (a distinction held by the top 2.5% of 

attorneys in PA) and then a Pennsylvania Super Lawyer, as chosen by their peers and 

through the independent research of Law & Politics. In 2012, The American Lawyer 

Media, publisher of The Legal Intelligencer and the Pennsylvania Law Weekly, 

named Mr. Schelkopf as one of the “Lawyers on the Fast Track” a distinction that 

recognized thirty-five Pennsylvania attorneys under the age of 40 who show

outstanding promise in the legal profession and make a significant commitment to 

their community. Mr. Schelkopf was also selected as a Top 40 under 40 by the 

National Trial Lawyers in 2012-2015. 

Mr. Schelkopf began his legal profession as a criminal prosecutor with the District 

Attorney’s Office of York County. He quickly progressed to Senior Deputy 

Prosecutor where he headed a trial team responsible for approximately 300 felony 

and misdemeanor cases each quarterly trial term. 

In 2004, Mr. Schelkopf then associated with a suburban Philadelphia area law firm, 

litigating civil matters throughout Pennsylvania and New Jersey. In 2006, he was cocounsel in a Philadelphia County trial resulting in a $30,000,000.00 jury verdict in 

favor of his clients – the largest state verdict recorded for that year. Mr. Schelkopf

currently serves as a lead and co-lead counsel in numerous class actions related to 

product and automotive defect cases pending throughout the country.

Outside of the office, Mr. Schelkopf enjoys spending time with his family, mountain 

and road biking, skiing and restoring classic automobiles. Three of his auto

restorations have been featured in nationally circulated automotive publications.

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Lori Kier, Counsel

With a broad litigation background, Lori G. Kier 

serves as Of Counsel to the firm. For nearly 25 years, 

Ms. Kier served as senior attorney at the U.S. 

Environmental Protection Agency in Philadelphia. 

Prior to her time at EPA, Ms. Kier was a staff 

attorney at the U.S. Court of Appeals for the Third 

Circuit and a Law Clerk to U.S. District Judge Fred 

I. Parker (D. Vt.). 

At EPA, Ms. Kier developed and prosecuted enforcement cases (administrative and 

judicial) under multiple state and federal environmental statutes, and participated in 

all aspects of litigation, both as primary counsel and in support of the U.S. Department 

of Justice. She led various teams in developing enforcement initiatives, most 

prominently in the areas of municipal and industrial stormwater. Other statutory areas 

covered included: Clean Water Act, Emergency Planning and Community Right-toKnow Act, Federal Insecticide, Fungicide, and Rodenticide Act National Historic 

Preservation Act, Resource Conservation and Recovery Act, Safe Drinking Water 

Act, and Toxic Substances Control Act. 

As an active participant in her local community, Ms. Kier is currently a member of 

the East Goshen Township Zoning Hearing Board and previously served on the 

Township’s Planning Commission. She serves as a Democratic Committee Person 

and has also been a mock trial coach for two local high schools as well as a judge for 

high school, college, and law school mock trial and moot court competitions

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Joseph B. Kenney, Associate

Joseph B. Kenney has experience representing

consumers in class actions involving defective

products, automotive defects, false and misleading 

advertising, and other consumer protection litigation.

Joe received his J.D., cum laude, from Villanova

University School of Law in 2013. He was elected 

as a Managing Editor of Student Works for the Jeffrey S. Moorad Journal of Sports 

Law for his third year of law school. As a staff writer, his comment was selected for

publication in the Spring 2012 Volume of the Journal. Prior to law school, Joe 

attended Ursinus College where he was a member of the men’s varsity soccer team.

Joe is admitted to practice before the Supreme Courts of Pennsylvania and New Jersey 

and the United States District Courts for the Eastern District of Pennsylvania and the 

District of New Jersey. In 2017 and 2018, Joe was distinguished as a Pennsylvania 

SuperLawyer Rising Star.

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Alice M. Elmer, 

Associate

Alice is a graduate of Temple University James E. Beasley 

School of Law, with a Certificate in Business Law. She was 

a Law & Public Policy Scholar and a Weisman Fellow. Prior 

to working at Sauder Schelkopf, Alice interned with the Office 

of Attorney General in Pennsylvania, and with the U.S. 

Attorney’s Office in Washington, D.C. She has studied 

economics through the lens of law, written on the topics of Federal student loan debt 

and elder abuse financial frauds, and completed projects analyzing housing issues local 

to Philadelphia with the support of City Council and the Sheller Center for Social 

Justice. Valuing Temple’s vibrant scholarly community, she held leadership positions 

with Outlaw, the Asian Pacific American Law Student Association, and the Women’s 

Law Caucus. Out of a commitment to service, she participated in the Employment 

Advocacy Project, the Name Change Project, and the Pro Se Asylum Clinic—all 

experiences where she helped clients.

Alice holds a B.A. degree in Art and Gender Studies from the Johnston Center for 

Integrative Studies at the University of Redlands. As an undergraduate student, she 

studied in Prague and in Paris, where she focused on photography and European 

culture. Prior to law school, Alice worked in book publishing for five years. She 

learned the value of good design and cultivated an editor’s attention to detail. Driven 

to create great change in people’s lives, she has since harnessed her experiences in 

writing and storytelling for the study of law.

Outside of work, Alice enjoys cooking, the outdoors, and traveling as often as possible.

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Practice Area: Consumer Fraud Class Actions

The attorneys at Sauder Schelkopf have prosecuted and resolved numerous consumer 

fraud class actions on behalf of millions of consumers against nationally known 

corporations for deceptive and unfair business practices. Sauder Schelkopf’s 

experience includes the following types of consumer fraud class action cases: 

Automotive Defects – Automobiles are a major expense and consumers expect them 

to provide safe and reliable transportation for themselves and their family and friends. 

Some vehicles, however, may contain manufacturing or design defects that can pose a 

danger to our families and others on the road. Even if these defects do not create a 

potential safety issue, they might result in costly repairs to consumers. 

Construction Defects – When consumers purchase a home, they expect the plumbing 

and other basic functions of the home to work without fail. Certain companies, 

however, are known to cut corners when designing and manufacturing their products. 

When an essential component of the home fails, it can lead to costly repair bills, 

damage to the surrounding property in the home, and high homeowner’s deductibles. 

Consumer Electronics Defects – As technology continues to evolve, more and more 

consumers purchase and depend upon electronic devices in their daily routines. From 

smartphones to state-of-the art drones, many manufacturers rush products to sale to 

take advantage of high consumer demand. As these products are rushed to market, 

consumers often are left between the difficult choice of paying expensive repair bills 

or placing their expensive product on the shelf to gather dust. 

Medical Device Defects – Manufacturers of medical devices are held to high standards 

in the design, manufacturing, and marketing of their products. When a manufacturer 

learns of a defect in their medical device that could cause bodily harm to the end-user, 

the law imposes a strict duty on them to institute a recall immediately. Many times, 

however, manufacturers seek to place profits above the safety of their customers 

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Practice Area: Sexual Misconduct and Gender 

Discrimination 

Sauder Schelkopf has a nationally recognized sexual misconduct practice with 

significant experience fighting for victims. Our former prosecutors have extensive 

experience investigating and trying cases. Sauder Schelkopf currently represents 

victims of clergy sexual abuse in dioceses throughout the country. We have 

numerous class action lawsuits pending throughout the country on behalf of sexual 

abuse survivors.

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Practice Area: Employee Rights Class Actions

The attorneys at Sauder Schelkopf have protected workers’ rights. Employees are 

given numerous protections under state and federal law. The attorneys at Sauder 

Schelkopf has held employers accountable to their obligations under the law when 

hiring, employing, and firing their workers. 

If employees face discrimination based on their race, color, country of origin, religion, 

gender, sexual orientation, the employer is violating the law. In addition, many 

employees do not receive their due compensation as numerous employers engage in 

wage and hour violations. Whether you are a potential whistleblower, or your case is 

associated with any technical or creative legal matter, the attorneys at Sauder Schelkopf 

are available to discuss your potential case. 

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Case Highlights 

The attorneys at Sauder Schelkopf have played a lead role in cases throughout the 

country including:

• In re Checking Account Overdraft Litig., (S.D. Fla.) (class action resulting in a 

$55 million settlement with US Bank; $14.5 million settlement with 

Comerica); 

• Afzal v. BMW of North America, LLC, (D.N.J.) (class action on behalf of 

purchasers and lessees of BMW M3 vehicles with S65 engines containing an 

alleged rotating assembly defect resulting in engine failure); 

• Ajose v. Interline Brands, Inc., (M.D. Tenn.) ($16.5 million nationwide class 

action settlement on behalf of purchasers of defective toilet connectors); 

• Rangel v. Cardell Cabinetry, LLC, (W.D. Tex.) ($800,000 settlement on 

behalf of hundreds of former employees of a Texas cabinetry maker for 

Worker Adjustment and Retraining Notification (WARN) violations when 

they were fired without notice); 

• In re: Outer Banks Power Outage Litigation (E.D.N.C.) ($10.3 million 

settlement on behalf of businesses impacted by massive power outage and 

evacuation cause by a bridge builder); 

• Guill, Jr. v. Alliance Resource Partners, L.P. et al (S.D. Ill) (WARN Act class 

action on behalf of 200 coal miners); 

• Bang v. BMW of North America, LLC, (D.N.J.) (nationwide class action 

settlement on behalf of hundreds of thousands of purchasers and lessees of 

certain BMW vehicles with N63 engines containing alleged oil consumption 

defect); 

• Traxler v. PPG Industries, Inc. (N.D. Ohio) ($6.5 million class action 

settlement on behalf of homeowners who purchased and used defective deck 

stain); 

• Physicians of Winter Haven v. Steris Corp., (N.D. Ohio) ($20 million class 

action settlement on behalf of surgical centers to recoup out-of-pocket 

expenses related to recalled medical device); 

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• In re Stericycle Inc., Sterisafe Contract Litigation, (N.D. Ill.) ($295 million 

class action settlement on behalf of medical waste disposal customers of 

Stericycle regarding alleged automated price increases in violation of 

contractual terms); 

• Desio et al. v. Insinkerator et al. (E.D. WA) ($3.8 million class action 

settlement on behalf of homeowners who purchased defective water filters); 

• Davitt v. Honda North America, Inc., (D.N.J.) (class action nationwide 

settlement on behalf of hundreds of thousands of purchasers and lessees of 

Honda CR-V vehicles with alleged defective door lock actuators); 

• McCoy v. North State Aviation, (M.D.NC) ($1.5 million settlement on behalf 

of hundreds of former employees for Worker Adjustment and Retraining 

Notification (WARN) violations when they were fired without notice); 

• Henderson v. Volvo Cars of North America LLC, (D.N.J.) (class action 

nationwide settlement on behalf of 90,000 purchasers and lessees of Volvo 

vehicles with defective GM4T65 automatic transmissions); 

• Klug v. Watts Regulatory Co., and Ponzo v. Watts Regulatory Co (D. Neb.) 

($14 million settlement on behalf of homeowners with defective toilet 

connectors and water heater connectors manufactured by Watts); 

• Lax v. Toyota Motor Corporation (N.D. Cal.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Toyota vehicles 

with alleged oil consumption defect); 

• Mendoza v. Hyundai Motor America, Inc., (N.D. Cal.) (class action on behalf 

of hundreds of thousands of purchasers and lessees of certain Hyundai Sonata 

vehicles with alleged connecting rod bearing defect resulting in engine failure); 

• Neale v. Volvo Cars of North America LLC, (D.N.J.) (certified class action on 

behalf of hundreds of thousands of purchasers and lessees of certain Volvo 

vehicles with alleged defective sunroof water drainage systems); 

• Rivera v. Ford Motor Company, (E.D. Mich.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Ford Focus 

vehicles with alleged defective Evaporative Emission Control (EVAP) systems 

causing sudden and unexpected engine stalling); 

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• Wallis v. Kia Motors America, Inc., (N.D. Cal.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Kia vehicles with 

alleged connecting rod bearing defect resulting in engine failure); 

• Whalen v. Ford Motor Co., (N.D. Cal.) (class action on behalf of hundreds of 

thousands of purchasers and lessees of certain Ford and Lincoln vehicles with 

alleged defective MyFord Touch infotainment systems); 

• Tolmasoff v. General Motors, (E.D. MI.) ($6 million nationwide class action 

settlement on behalf of purchasers and lessees alleging overstated MPG);

• Yaeger v. Subaru of America, Inc., (D.N.J.) (class action on behalf of 

hundreds of thousands of purchasers and lessees of certain Subaru vehicles 

with alleged oil consumption defect); 

• Smith v. Gaiam, (D. Colo.) ($10 million consumer class action settlement, 

which provided full relief to the class). 

• International Brotherhood of Electrical Workers Local 98 Pension Fund v 

Encore, (San Diego, CA) (shareholder derivative settlement implemented 

industry-leading reforms to its risk management and corporate governance 

practices, including creating Chief Risk Officer and Chief Compliance Officer 

positions, various compliance committees, and procedures for consumer 

complaint monitoring) 

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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

Joseph Sauder (P) 4.80 13.00 50.60 7.70 37.50 0.00 113.60 113.60 

Matthew Schelkopf (P) 4.70 10.40 7.10 35.70 0.00 57.90 57.90 

Lori Kier (A) 0.80 3.90 0.00 4.70 4.70 

Joseph Kenney (A) 5.60 1.00 10.90 36.20 5.20 13.70 0.00 72.60 72.60 

SUB-TOTAL 10.30 16.20 24.70 0.00 93.90 0.00 0.00 0.00 0.00 0.00 12.90 90.80 0.00 0.00 0.00 0.00 248.80 248.80 

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

Paula Lyons (PL) 2.70 0.00 2.70 2.70 

Heather Swadley (LC) 3.10 0.00 3.10 3.10 SUB-TOTAL 0.00 0.00 3.10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.70 0.00 0.00 0.00 0.00 5.80 5.80 GRAND TOTAL: 10.30 16.20 27.80 0.00 93.90 0.00 0.00 0.00 0.00 0.00 12.90 93.50 0.00 0.00 0.00 0.00 254.60 254.60 

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

Sauder Schelkopf LLC Reporting Period: Inception through February 28, 2022

 556281 

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