EXHIBIT 3 

Case: 1:20-cv-04699 Document #: 126-3 Filed: 03/01/21 Page 1 of 4 PageID #:2251
Anthony J Weibell | Partner | Wilson Sonsini Goodrich & Rosati

650 Page Mill Road | Palo Alto, CA 94304-1050 | direct: 650.354.4134 | aweibell@wsgr.com

From: Scott Drury

To: "Weibell, Tony"; "Elizabeth Fegan"

Cc: "Katrina Carroll"; "erhow@birdmarella.com"; Michael Kanovitz

Subject: RE: TikTok MDL / T.K. v. ByteDance Technology Co., Ltd.

Date: Wednesday, February 24, 2021 5:08:00 PM

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Tony and Beth:

I respectfully request that you reconsider your decision to not discuss the TikTok MDL and T.K. until

the MDL settlement becomes public. Given our offer to enter into an appropriate nondisclosure/confidentiality agreement, it does not appear that any issue precludes the requested

discussion. There is no downside to engaging in the requested dialogue.

--Scott

From: Weibell, Tony <aweibell@wsgr.com> 

Sent: Wednesday, February 24, 2021 4:13 PM

To: Scott Drury <drury@loevy.com>; Elizabeth Fegan <beth@feganscott.com>

Cc: Katrina Carroll <kcarroll@carlsonlynch.com>; erhow@birdmarella.com; Michael Kanovitz

<mike@loevy.com>

Subject: RE: TikTok MDL / T.K. v. ByteDance Technology Co., Ltd.

Hi Scott,

Thanks for looping me in. We have been working closely for the past 6 months with the more than

eight separate law firms appointed by the Court to have the settlement reviewed for any concerns

regarding the fairness of the settlement to class members. That group includes several of the finest

consumer class action attorneys in America, and several law firms that were not a part of the original

settlement. Rest assured, the class members are in good hands.

Thanks,

Tony

___________________________________

Case: 1:20-cv-04699 Document #: 126-3 Filed: 03/01/21 Page 2 of 4 PageID #:2252
From: Scott Drury <drury@loevy.com> 

Sent: Wednesday, February 24, 2021 1:36 PM

To: Elizabeth Fegan <beth@feganscott.com>

Cc: Katrina Carroll <kcarroll@carlsonlynch.com>; erhow@birdmarella.com; Michael Kanovitz

<mike@loevy.com>; Weibell, Tony <aweibell@wsgr.com>

Subject: RE: TikTok MDL / T.K. v. ByteDance Technology Co., Ltd.

[External]

Beth:

Thank you for your response. It seems that it serves everyone’s interests, including the Defendants,

to begin these discussions now to address any concerns or issues that may exist. We are willing to

enter into an appropriate non-disclosure agreement/confidentiality agreement to allow the

discussions to proceed. Given that the Biden administration currently is not pursuing a sale of Tik

Tok (https://apnews.com/article/donald-trump-jen-psaki-ca5e68d8b23cb26a0e964b3ea5fe826d),

the bases TikTok has given for requiring total secrecy no longer exist. I have copied Tony Weibell on

this email so that he can also be part of this dialogue. Based on the above, I suggest we schedule a

call this week to work through the confidentiality issue.

--Scott

From: Elizabeth Fegan <beth@feganscott.com> 

Sent: Wednesday, February 24, 2021 3:24 PM

To: Scott Drury <drury@loevy.com>

Cc: Katrina Carroll <kcarroll@carlsonlynch.com>; erhow@birdmarella.com; Michael Kanovitz

<mike@loevy.com>

Subject: RE: TikTok MDL / T.K. v. ByteDance Technology Co., Ltd.

Scott,

As soon as we can publicly discuss the settlement, we would be happy to

schedule a call.

Beth

Elizabeth A. Fegan | Fegan Scott LLC | 312.741.1019

Case: 1:20-cv-04699 Document #: 126-3 Filed: 03/01/21 Page 3 of 4 PageID #:2253
From: Scott Drury <drury@loevy.com> 

Sent: Wednesday, February 24, 2021 12:25 PM

To: Elizabeth Fegan <beth@feganscott.com>

Cc: Katrina Carroll <kcarroll@carlsonlynch.com>; erhow@birdmarella.com; Michael Kanovitz

<mike@loevy.com>

Subject: TikTok MDL / T.K. v. ByteDance Technology Co., Ltd.

Beth:

I am writing to renew my request for a telephone conference to discuss the overlapping issues in the

TikTok MDL and T.K. v. ByteDance Technology Company, Ltd., 1:19-cv-7915 (N.D. Ill.) (Blakey, J.)

(“T.K.”). In T.K., we objected to a proposed settlement that failed to provide adequate relief for

millions of TikTok users under the age of 13. As a result of our objection, the proposed settlement in

T.K. has not yet been approved. Further, as a result of our objection, the T.K. class members have

not been subjected to the broad release in the proposed settlement in that case. Given our

substantial efforts on behalf of the millions of T.K. class members, we are concerned that we have

not been provided any information regarding the relief being sought for them, if any, in the TikTok

MDL. Please let us know your availability for the requested call.

--Scott

_______________________

Scott R. Drury

LOEVY & LOEVY

311 N. Aberdeen, 3rd Floor

Chicago, Illinois 60607

312.243.5900

drury@loevy.com

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Case: 1:20-cv-04699 Document #: 126-3 Filed: 03/01/21 Page 4 of 4 PageID #:2254