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 KATRINA CARROLL

I, KATRINA CARROLL, declare as follows:

1. I am the managing partner of the Chicago, Illinois office of Lynch Carpenter LLP, 

a nationally recognized litigation boutique specializing in the prosecution of plaintiff-side class 

actions. I have over twenty years of experience litigating class action matters, have been appointed 

by the Court as Co-Lead Counsel for Plaintiffs in this case and I have personal knowledge of the 

facts stated herein. I submit this Declaration on my personal behalf to address the primary false 

statements contained in Class Member Edelson PC’s Motion to Vacate or Modify Preliminary 

Injunction in this matter.

2. Edelson PC (“Edelson”) is counsel of record for objector Dennis Littekin and filed 

an objection to preliminary approval of the settlement on behalf of its client. The objection was

largely denied by the Court. (Dkt. 161).

3. Now, under the pretext that the firm itself is a settlement “class member,” Edelson 

has filed a false, inflammatory and offensive pleading in this Court. This pleading was 

unaccompanied by even a basic declaration, makes sweeping statements without any factual 

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support, and contains direct quotations unattributed to any source. Because the pleading is a 

baseless personal attack on me, I feel compelled to address the various falsehoods that are now in 

the public domain.

4. I have never communicated with any lawyer at Edelson nor any person acting on 

behalf of the firm regarding the substance of Edelson’s objection.

5. Even if I had, such communications are recognized as proper by the Federal Rules. 

Class Counsel may negotiate freely with counsel for objectors to compromise or encourage the 

withdrawal of objections, so long as any payment or other consideration given to objector’s 

counsel is disclosed and approved by the Court pursuant to Federal Rule of Civil Procedure 

23(e)(5). I am mindful of these obligations.

6. The unsworn statements made by Edelson appear to relate to a conversation my 

husband had, and one I subsequently had, with Tiffany Elking, the lobbyist employed by Edelson’s 

Political Action Committee (“PAC”). No one from Edelson participated in those conversations. 

7. My husband, Jonathan Carroll, is the current Illinois House Representative for the 

57th District. In March 2021, an anti-BIPA bill was pending and set to be heard in one of the 

committees on which Jonathan sits.

8. In March 2021, in the days following the oral argument on Plaintiffs’ preliminary 

approval motion in this case, Ms. Elking actively solicited my husband’s assistance in opposing 

the anti-BIPA legislation. 

9. During their conversation, my husband advised Ms. Elking that he could not vote 

on the bill, as taking a position on the merits would pose a potential conflict since I am currently 

actively litigating many BIPA matters. 

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10. Jonathan’s legislative voting history, a matter of public record, demonstrates that 

whenever a BIPA-related initiative is brought to vote, he opts simply to vote “present.” 

11. During her conversation with Jonathan, Ms. Elking asked him whether I would be 

willing to assist in the PAC’s legislative efforts. Jonathan was surprised that Ms. Elking was 

seeking my assistance given Jay Edelson’s “live tweets” during the March 2, 2021 preliminary 

approval proceedings and other Twitter communications that misquoted Class Counsel, 

lampooned the proceedings in this Court, and spread falsehoods about the settlement. (See Dkt. 

138). 

12. Jonathan told Ms. Elking that I was offended by Mr. Edelson’s lack of 

professionalism and that I deserved an apology. 

13. Jonathan did not discuss the merits of Edelson’s objection with Ms. Elking. Nor 

did he request that the objection be withdrawn. 

14. At the end of their conversation, Ms. Elking asked Jonathan for my cell phone 

number and asked him to relay a message to me to call her. 

15. Ms. Elking then followed up via text message to me requesting that I call her. 

16. Separately, I received phone calls and emails from other members of Edelson’s 

PAC to solicit my assistance in combating the anti-BIPA legislation.

17. In response to Ms. Elking’s request and as a courtesy to the requests of the other 

PAC members who contacted me directly, I called Ms. Elking. 

18. When we spoke, Ms. Elking asked me to help Edelson’s PAC in discussing the bill 

with other state legislators. I told Ms. Elking that her request was ill-timed given Mr. Edelson’s 

offensive use of Twitter just days before which I analogized as similar to former President 

Trump’s. I further informed her that I do not have a cordial relationship with Mr. Edelson’s firm 

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