(;+,%,7$

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 1 of 29 PageID #:3750
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 JONATHAN JAGHER IN SUPPORT OF PLAINTIFFS’ 

PETITION FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF FREED 

KANNER LONDON & MILLEN LLC 

 I, Jonathan Jagher, declare and state as follows: 

1. I am a partner of the law firm of Freed Kanner London & Millen 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 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: Along with Katrina Carroll, I organized and co-directed the team of Plaintiffs’ counsel 

that prepared for and participated in the successful mediation that resolved this litigation. Early in 

this process, Ms. Carroll and I jointly retained Bob Zeidman of Zeidman Consulting as Plaintiffs’ 

source code expert. I was the primary liaison between Mr. Zeidman and our team in the months 

of preparation for the mediation, interfacing numerous times with Mr. Zeidman as our team 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 2 of 29 PageID #:3751
2 

processed the technical information we were provided by Defendants in advance of our mediation. 

I directly negotiated with Defendants’ counsel for several months leading up to and during the 

mediation and assisted in crafting key terms of the Settlement including the monetary and 

injunctive relief benefitting Plaintiffs and the Classes. Post-mediation, I continued to directly 

negotiate with Defendants’ counsel on behalf of Plaintiffs’ counsel and co-drafted the Settlement 

Agreement. Upon execution of the Settlement Agreement, Ms. Carroll and I spearheaded the 

confirmatory discovery process. We traveled to California and spent several days in-person with 

Mr. Zeidman as he inspected Defendants’ source code. Ms. Carroll and I continued to work with 

Mr. Zeidman over the course of the next several weeks, and I was the primary liaison with 

Defendants, responsible for ensuring that Mr. Zeidman was given access to the source code and 

for assisting in the resolution of numerous technical issues. Ms. Carroll and I utilized Mr. 

Zeidman’s findings in drafting supplemental interrogatories to continue our confirmatory 

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

inception through October 31, 2020, is 1,302.70 hours. The total lodestar for my firm in this time 

period is $1,078,962.00. 

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: I was responsible for continuing my work with Mr. Zeidman and overseeing 

the confirmatory discovery process. I worked extensively with Mr. Zeidman as we analyzed the 

findings from his source code review and along with other Plaintiffs’ counsel, crafted written 

discovery requests and deposition questions. Co-Lead Counsel tasked me with participating in 

Defendants’ deposition as the liaison to Mr. Zeidman, which served as the culmination of several 

months of confirmatory discovery. In addition to being the point person for the confirmatory 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 3 of 29 PageID #:3752
3 

discovery process, I was responsible for working with our claims administrator in drafting the class 

notices and implementing the notice program. At the direction of Co-Lead Counsel, I was tasked 

with drafting portions of Plaintiffs’ motion for preliminary approval of 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 288.40 hours. The total lodestar for my firm in this time period 

is $242,683.00. 

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

inception through February 28, 2022, is 1,591.10 hours. The total lodestar for my firm is 

$1,321,645.00. 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. 

6. As detailed in Exhibit 3, my firm has incurred a total of $11,555.07 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 Co-Lead Counsel. 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 4 of 29 PageID #:3753
4 

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 25th day of March 2022 at Conshohocken, Pennsylvania. 

 

 /s/ Jonathan Jagher

 Jonathan Jagher 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 5 of 29 PageID #:3754
Exhibit 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 6 of 29 PageID #:3755
 

2201 WAUKEGAN ROAD 

SUITE 130 

BANNOCKBURN, IL 60015 

TELEPHONE (224) 632-4500 

923 FAYETTE STREET

CONSHOHOCKEN, PA 19428 

TELEPHONE (610) 234-6770

www.fklmlaw.com

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 7 of 29 PageID #:3756
Freed Kanner London & Millen LLC (“FKLM”) is one of the nation’s premier plaintiffs’ 

class action practices. The firm’s attorneys are among the pioneers and leaders in the class 

action field, having played leadership roles in major antitrust, consumer fraud, securities, 

unlawful business practices and insurance fraud cases for decades. 

FKLM was founded on January 1, 2007. The founding partners of FKLM, formerly 

principals and partners of Much Shelist Freed Denenberg Ament & Rubenstein, P.C., have 

successfully prosecuted class actions for over 40 years, including as lead or co-lead counsel in 

dozens of cases, resulting in recoveries for class members of more than $2 billion.

APPOINTMENTS AS LEAD OR CO-LEAD COUNSEL

3⁄4 Northbrook Park District v. Mr. David’s Flooring Int’l, LLC et al., No. 20-cv-07538 

(N.D. Ill.)

FKLM partner Steven Kanner serves as co-lead counsel in this antitrust action arising 

from an 8-year conspiracy to rig bids to municipal and commercial flooring purchasers in 

Illinois.

3⁄4 In re Peanut Farmers Antitrust Litigation, 2:19-cv-00463 (E.D. Va.)

FKLM partner Kimberly Justice serves as co-lead counsel in this antitrust class action

arising from peanut shellers’ wrongful and anticompetitive actions that had the intended

purpose and effect of artificially fixing, depressing, maintaining, and stabilizing the price

of runner peanuts paid to peanut farmers in the United States over the past 6 years. This

matter recently settled for $102.75 million for the class.

3⁄4 In re Chicago Board Options Exchange Volatility Index Manipulation Antitrust 

Litigation, MDL 2842 (N.D. Ill.)

FKLM partner Kimberly Justice serves as interim co-lead counsel in this multidistrict 

litigation arising from over a decade of alleged manipulation of financial instruments 

linked to the Chicago Board Options Exchange’s (“CBOE”) Volatility Index, the “VIX,” 

and the opaque settlement process the CBOE designed for certain of those instruments.

3⁄4 In re Payment Card Interchange Fee and Merchant Discount Litigation, MDL 1720

(E.D.N.Y.)

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 8 of 29 PageID #:3757
- 2 -

FKLM is serving as interim co-lead counsel for a proposed class of more than twelve 

million merchants seeking equitable and injunctive relief. Plaintiffs allege, inter alia, that 

certain of Visa and MasterCard rules, including anti-steering restraints and default 

interchange fees, working in tandem have caused artificially inflated interchange fees 

paid by merchants on credit and debit card transactions from January 1, 2004 through the 

present.

3⁄4 In re Opana ER Antitrust Litigation, MDL 2580 (N.D. Ill.)

FKLM is serving as co-lead counsel on behalf of indirect purchasers (end-payors) of 

brand or generic Opana ER, an opioid painkiller, in this antitrust “pay-for-delay” case 

brought under the laws of 30 states.

3⁄4 The Honest Company Inc., Sodium Lauryl Sulfate (SLS) Marketing & Sales Practices 

Litigation, 2:16-ml-02719 (C.D. Cal.)

FKLM served as co-lead counsel in this class action brought on behalf of consumers 

allegedly deceived in their purchase of products labeled as “Free of SLS.” The settlement 

in the case ultimately provided class claimants with, in most instances, close to full 

reimbursement of the money they spent on the products at issue and the defendant agreed 

to cease marketing the products as SLS free.

3⁄4 In re Automotive Parts Antitrust Litigation, MDL 2311 (E.D. Mich.)

FKLM is serving as interim co-lead counsel on behalf of direct purchasers of automotive 

parts in multiple concurrently active nationwide, antitrust price-fixing cases relating to 

the following products: wire harnesses; instrument panel clusters; heater control panels; 

occupant safety parts; fuel senders; bearings; air conditioning systems; windshield wiper 

systems; starters; windshield washer systems; spark plugs; oxygen and air fuel ratio 

sensors; fuel injection systems; brake hoses; alternators; ignition coils; power window 

motors; shock absorbers; and electric power steering assemblies. Settlements with 

dozens of defendants reached to date total over $550 million.

3⁄4 Kleen Products, Inc. et al. v. International Paper, et al., 10-CV-5711 (N.D. Ill.) 

(“Containerboard Antitrust Litigation”)

As co-lead counsel for a class of direct purchasers of containerboard and related products 

in this antitrust price-fixing case, FKLM recovered $376 million dollars through 

settlement after more than 7 years of heavily contested litigation, including two appeals 

to the Seventh Circuit Court of Appeals.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 9 of 29 PageID #:3758
- 3 -

3⁄4 In re Pharmacy Benefit Managers Antitrust Litigation, MDL No. 1782 (E.D. Pa.)

FKLM is serving as co-lead counsel in these consolidated class actions brought on behalf 

of retail pharmacies against prescription benefit managers for fixing at artificially low 

levels the prices paid to pharmacies for pharmaceuticals sold, and reimbursement for 

services rendered, to the members of plans created by the prescription benefit managers. 

The complaints allege that the prescription benefit managers illegally aggregate the 

purchases of their members in order to effectuate the underpayment.

3⁄4 In re Hydrogen Peroxide Antirust Litigation, MDL 1682 (E.D. Pa.) 

FKLM attorneys served as co-lead counsel in this antitrust price-fixing action against 

hydrogen peroxide producers. The case resulted in settlements of over $97 million for the 

class. In approving the Plaintiffs’ motion for an award of attorneys’ fees and expenses, 

Judge Stewart Dalzell lauded co-lead counsel: 

[t]he “skill and efficiency of the attorneys involved” is of a very 

high order indeed, and as we noted at the fairness hearing 

yesterday, we have been impressed that these attorneys have 

prosecuted this matter vigorously against seasoned opponents 

without needlessly distracting the Court with discovery disputes.

3⁄4 In re Brand Name Prescription Drugs Antitrust Litigation, MDL 997 (N.D. Ill.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action. 

Settlements totaling approximately $715 million were recovered on behalf of the plaintiff 

class.

3⁄4 In re Clozapine Antitrust Litigation, MDL No. 874 (N.D. Ill.)

FKLM attorneys served as co-lead counsel in this antitrust class action against Caremark 

and Sandoz Pharmaceuticals alleging that the defendants entered into an illegal 

agreement to distribute a drug known as Clozaril by tying it to the purchase of a blood 

testing system, by fixing the price of the packaged sale, and by conspiring to monopolize 

the relevant market. More than $20 million was recovered for the class.

3⁄4 In re High Fructose Corn Syrup Antitrust Litigation, MDL 1087 (C.D. Ill.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action 

against major manufacturers of high fructose corn syrup. The case was settled for $531 

million for the class. At the close of the hearing where counsel fees were approved, 

Judge Michael M. Mihm stated:

I’ve said many times during this litigation that you and the attorneys 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 10 of 29 PageID #:3759
- 4 -

who represent the defendants here are as good as it gets. Very 

professional. At least in my presence or in my contacts with you, 

you’ve always been civil. You’ve always been cutting to the chase 

and not wasting my time or each other’s time or adding to the cost of 

the litigation.

3⁄4 In re Linerboard Antitrust Litigation, MDL 1261 (E.D. Pa.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing case, which 

resulted in settlements of over $200 million for the class.

3⁄4 SchagrinGas Co. v. BP Products North America, et al., No. 1:06-cv-3621 (N.D. Ill.)

FKLM served as co-lead counsel on behalf of direct purchaser plaintiffs in this 

nationwide class action involving monopolization claims under Section 2 of the Sherman 

Act. The case resulted in a settlement of over $50 million for the class.

3⁄4 In re Aftermarket Filters Antitrust Litigation, MDL 1957 (N.D. Ill.)

FKLM served as interim co-lead counsel on behalf of direct purchasers of replacement 

automobile air and oil filters in this nationwide, antitrust price-fixing case. The case 

resulted in settlements of nearly $18 million for the class.

3⁄4 In re Flat Glass Antitrust Litigation (No. II), MDL 1942 (W.D. Pa.)

FKLM served as co-lead counsel on behalf of direct purchaser plaintiffs of construction 

flat glass in this nationwide, antitrust price-fixing case. The case resulted in settlements

for the class exceeding $22 million.

3⁄4 In re Urethane Chemicals Antitrust Litigation, MDL 1616 (D. Kan.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing action. The case 

resulted in settlements of $33 million for the class.

3⁄4 In re Methyl Methacrylate (MMA) Antitrust Litigation, MDL 1768 (E.D. Pa.)

FKLM served as co-lead counsel in this antitrust price-fixing action against producers of 

methyl methacrylate and polymethyl methacrylate. The case resulted in a settlement of 

over $15 million for the class.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 11 of 29 PageID #:3760
- 5 -

3⁄4 In re Infant Formula Antitrust Litigation, MDL 878 (N.D. Fla.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action 

against the major manufacturers of infant formula. The case settled for over $125 million

for the class.

3⁄4 In re Chubb Drought Insurance Litigation, MDL 782 (S.D. Ohio)

FKLM attorneys served as co-lead counsel in this class action filed on behalf of farmers 

who purchased drought insurance that Chubb refused to honor. The settlement exceeded 

$110 million and was achieved in less than 9 months. This sum, together with $8 million 

recovered at trial against Chubb’s general agent, resulted in complete recovery for the 

affected farmers.

3⁄4 In re Ocean Shipping Antitrust Litigation, MDL 395 (S.D.N.Y.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action, 

which resulted in a $79 million recovery for thousands of U.S. and European shippers. 

Distributions were made to claimants in the United States and throughout a number of 

European countries.

3⁄4 In re Isostatic Graphite Antitrust Litigation, Master File 00-CV-1857 (E.D. Pa.) 

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action. The 

case resulted in combined settlements of over $11 million for the class.

3⁄4 In re Carbon Dioxide Antitrust Litigation, MDL 940 (M.D. Fla.)

FKLM attorneys served as co-lead counsel in this antitrust price-fixing class action in 

which the plaintiff class recovered $53 million and achieved significant therapeutic relief 

for the class.

3⁄4 In re Morrison Knudson Securities Litigation, CA No. 94-CV-3345 (D. Idaho)

FKLM attorneys served as co-lead counsel in this securities class action where the 

plaintiff class received $43 million and approximately 3 million shares of Morrison 

Knudson common stock in settlement of their claims.

3⁄4 In re M-L Lee Acquisition Fund Securities Litigation (D. Del.)

FKLM attorneys served as co-lead counsel in this securities class action case against a 

syndicate of partnerships and its general partners, involving Merrill Lynch and its 

affiliates, and a leveraged buy-out specialty firm overseen by Thomas H. Lee. The case 

resulted in a $33 million settlement on behalf of the limited partners.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 12 of 29 PageID #:3761
- 6 -

3⁄4 In re Public Service Company of New Mexico (S.D. Cal.)

FKLM attorneys served as lead counsel in this derivative action and obtained $33 million 

dollars in a joint settlement with class plaintiffs in a related securities fraud class action. 

Judge Harry R. McCue, District Court Judge for the Southern District of California 

stated:

The petitioners in this case are members of respected law firms 

which specialize in class action litigation. These attorneys brought 

considerable legal talents together, and were able to achieve the 

successful completion of this litigation. They are entitled to fair 

and reasonable compensation.

3⁄4 Piggly Wiggly Antitrust Litigation (E.D. Tex.)

FKLM attorneys served as co-lead counsel in this statewide (Texas) antitrust price-fixing 

action, which resulted in total settlements of approximately $32 million for class 

members.

3⁄4 Koch Gathering Systems, Inc. Oil Spill Litigation (Dist. Ct. of Nueces County, Tex.)

FKLM attorneys served as co-lead counsel in this case concerning a marine oil spill in 

which a class consisting of commercial fisherman and shrimpers recovered over $10 

million.

OTHER LEADERSHIP ROLES

In addition to serving as lead or co-lead counsel, FKLM attorneys regularly play key 

roles as members of executive or steering committees, negotiating ESI issues, taking and 

defending depositions, working with expert witnesses, and managing all aspects of pre-trial 

discovery.

3⁄4 In re Toyota Hybrid Brake Litig., No. 4:20-cv-00127-ALM (E.D. Tex.)

FKLM partner Kimberly Justice serves on the Plaintiffs’ Executive Committee in this 

class action arising from allegations that Toyota manufactured, sold, and leased certain 

Toyota vehicles with defective braking systems.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 13 of 29 PageID #:3762
- 7 -

3⁄4 In Re: TikTok, Inc., Consumer Privacy Litigation, MDL No. 2948 (N.D. Ill.)

FKLM partner Jonathan Jagher serves on the Plaintiffs’ Steering committee in this class 

action related to allegations of data privacy violations involving the popular app and the 

creation of short videos on mobile devices.

3⁄4 In Re: Morgan Stanley Data Security Litigation, 1:20-CV-05914 (S.D.N.Y.)

FKLM partner Jonathan Jagher serves on the Plaintiffs’ Executive Committee in this data 

privacy class action related to allegations that Morgan Stanley failed to safeguard its 

customers’ highly sensitive personally identifiable information.

3⁄4 In re DPP Beef Antitrust Litigation, 0:20-CV-01319 (D. Minn.)

FKLM serves on the Plaintiffs’ Steering Committee in this antitrust class action alleging

that the country’s biggest beef companies have illegally conspired to both raise the price 

of beef and lower the amount paid to cattle ranchers.

3⁄4 Cameron et al. v. Apple, Inc., 4:19-cv-03074 (N.D. Cal.)

FKLM serves as class counsel and as an Executive Committee Member in this antitrust 

class action arising from Apple’s abusive monopoly in the distribution of iOS apps and 

related products, seeking to get rid of its pricing mandates, and to reimburse developers

for overcharges made through abuse of its monopoly power.

3⁄4 In re Farm-Raised Salmon and Salmon Products Litigation, 19-CV-21551 (S.D. Fla.)

FKLM serves as a member of the Direct Purchaser Plaintiffs’ Executive Committee in 

this case alleging various North Atlantic farms engaged in restrictive business practices 

including illegal price-fixing and violated rules prohibiting cartels.

3⁄4 In re Local TV Advertising Antitrust Litigation, MDL No. 2867 (N.D. Ill.)

FKLM serves court appointed roles both on the Plaintiffs’ Steering Committee, and as 

Liaison Counsel in this multidistrict, antitrust class action accusing the primary industry 

players of fixing television advertising prices.

3⁄4 In re German Automotive Manufacturers Antitrust Litigation, 17-md-02796 (N.D. 

Cal.)

FKLM partner Kimberly Justice served on the Plaintiffs’ Steering Committee in this 

multi-district class action accusing Audi, BMW, Volkswagen and other German 

automakers of a decades-long antitrust conspiracy covering car technology, costs, 

suppliers and emissions equipment.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 14 of 29 PageID #:3763
- 8 -

3⁄4 Washington County Health Care Auth., Inc., et al. v. Baxter Int’l Inc., et al., 16-CV10324 (N.D. Ill.)

FKLM is serving as interim liaison counsel this class action alleging that the major U.S. 

manufacturers of a critical medical product, intravenous saline solution (“IV Saline 

Solution”), conspired to restrict output and artificially fix, raise, maintain and/or stabilize 

the prices of IV Saline Solution sold throughout the United States, under the pretext of a 

supply shortage. 

3⁄4 Mulhern, et al. v. Pepperidge Farm, 16-CV-32199 (N.D. Ill.)

FKLM is serving as interim liaison counsel and managing discovery efforts in this class 

action alleging that drivers/distributors are improperly classified by Pepperidge Farm as 

“independent contractors” in order to wrongfully deny them certain compensation and 

other benefits.

3⁄4 In re Lithium Ion Batteries Antitrust Litigation, MDL No. 2420 (N.D. Cal.)

FKLM served as a member of the Direct Purchaser Plaintiff Direct Purchaser Plaintiffs’ 

Steering Committee in this case on behalf of direct purchasers of Lithium-Ion Battery 

products in this nationwide price fixing case. More than $138 million was recovered for 

the class.

3⁄4 In re Rail Freight Fuel Surcharge Antitrust Litigation, MDL 1869 (DC)

FKLM is serving as co-chair of the Executive Committee in this case on behalf of direct 

purchasers of rail freight services that paid fuel surcharges in this nationwide, antitrust 

price-fixing case.

3⁄4 Standard Iron Works v. ArcelorMittal et al., 08-CV-5214 (N.D. Ill.)

FKLM was appointed as liaison counsel on behalf of direct purchasers of steel in this 

nationwide supply manipulation and price-fixing case.

3⁄4 In re Blood Reagents Antitrust Litigation, MDL 2081 (E.D. Pa.)

FKLM is serving as a member of the Executive Committee in this nationwide antitrust 

class action brought on behalf of direct purchasers of blood reagents.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 15 of 29 PageID #:3764
- 9 -

3⁄4 In re NCAA Student-Athlete Name & Likeness Licensing Litigation, 4:09-CV-1967 

(N.D. Cal.)

FKLM attorneys managed a variety of critical discovery matters in this antitrust case 

brought on behalf of former collegiate athletes.

3⁄4 In re Fresh and Process Potatoes Antitrust Litigation, MDL 2186 (D. Idaho)

In addition to handling all aspects of discovery concerning two defendants, FKLM 

attorneys worked closely with lead counsel in drafting the consolidated complaint and 

successfully opposing a motion to dismiss in this nationwide antitrust class action 

brought on behalf of direct purchasers of fresh and process potatoes.

3⁄4 In re Processed Egg Products Antitrust Litigation, MDL 2002 (E.D. Pa.)

FKLM attorneys worked closely with lead counsel in drafting the original complaint and 

successfully opposing a motion to dismiss in this nationwide antitrust class action 

brought on behalf of direct purchasers of eggs and egg products.

3⁄4 In re Cathode Ray Tube (CRT) Antitrust Litigation, MDL 1917 (N.D. Cal.)

FKLM served as Chair of Discovery and worked closely with lead counsel to manage a 

variety of top level matters, including negotiating ESI issues and taking key depositions 

in this nationwide price-fixing class action with over $100 million in partial settlements.

3⁄4 In re Optical Disk Drive (ODD) Antitrust Litigation, MDL 2143 (N.D. Cal.)

FKLM was one of several firms that assisted lead counsel with discovery and briefing in 

this nationwide price-fixing class action brought on behalf of direct purchasers of optical 

disk drives.

3⁄4 In re Municipal Derivatives Antitrust Litigation, MDL 1940 (S.D.N.Y.)

FKLM oversaw discovery of a key defendant and worked closely with lead counsel on a 

variety of other pre-trial matters in this nationwide class action brought on behalf of 

purchasers of municipal derivatives.

3⁄4 In re American Express Anti-Steering Rules Antitrust Litigation (No. II), MDL 2221 

(E.D.N.Y.)

FKLM managed discovery of independent merchant (opt-out) plaintiffs in this 

nationwide antitrust case.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 16 of 29 PageID #:3765
- 10 -

3⁄4 In re Air Cargo Shipping Services Antitrust Litigation, MDL 1775 (E.D.N.Y.)

FKLM attorneys served as co-chairs of discovery in this antitrust class action involving 

claims under Section 1 of the Sherman Act. Settlements in the case totaled nearly $600 

million. 

3⁄4 In re Intel Corp. Microprocessor Antitrust Litigation, MDL 1717 (D. Del.) 

FKLM attorneys managed discovery from dozens of named plaintiffs in this nationwide 

antitrust action. Among other things, the firm played a key role in overseeing document 

production and coordinating, managing and defending over 50 depositions.

3⁄4 In re Vitamins Antitrust Litigation, MDL 1285 (D.D.C.)

FKLM attorneys served as co-chairs of discovery in this antitrust price-fixing action, 

which resulted in over $1.3 billion in settlements.

3⁄4 In re Dynamic Random Access Memory (DRAM) Antitrust Litigation,

MDL 1486 (N.D. Cal.)

FKLM attorneys served as co-chairs of discovery in this nationwide, antitrust price-fixing 

action, which resulted in settlements of over $300 million for class members.

3⁄4 In re Rubber Chemicals Antitrust Litigation, MDL 1648 (N.D. Cal.)

FKLM attorneys served on the executive committee in this nationwide, antitrust pricefixing action, which resulted in settlements of over $300 million for class members.

3⁄4 In re Ethylene Propylene Diene Monomer (EPDM) Antitrust Litigation, MDL 1542 (D. 

Conn.)

FKLM attorneys served as co-chairs of discovery in this nationwide antitrust price-fixing 

action, which has resulted in settlements of over $87 million for class members.

3⁄4 In re Static Random Access Memory (SRAM) Antitrust Litigation, MDL 1819 (N.D. 

Cal.)

FKLM was a member of the executive committee representing direct purchaser plaintiffs 

in this antitrust price-fixing case which resulted in settlements exceeding $76 million.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 17 of 29 PageID #:3766
- 11 -

3⁄4 In re Waste Management, Inc. Securities Litigation, Master File 97-CV-7709 (N.D. 

Ill.)

3⁄4

FKLM attorneys were actively involved in litigating the case and served as liaison 

counsel. A settlement for the plaintiff class of $220 million was obtained.

3⁄4 Blinder Robinson Securities Litigation (E.D. Pa.)

FKLM attorneys served as members of the Steering Committee in this securities fraud 

action in which an injunction was obtained preventing a transfer of assets; judgment of 

$71 million was later entered.

3⁄4 In re Drill Bits Antitrust Litigation, CA No. H-91-627 (S.D. Tex.)

FKLM attorneys served as members of the Steering Committee in this antitrust pricefixing class action and were instrumental in achieving a settlement for the class in excess 

of $52 million.

3⁄4 In re Industrial Gas Antitrust Litigation, CA No. 80 C. 3479 (N.D. Ill.)

FKLM attorneys served as members of the executive committee in this antitrust pricefixing class action, which ultimately recovered more than $50 million dollars for the 

class. The settlement included assignable purchase certificates, which the court found 

increased the competitive value of the settlement.

3⁄4 In re Records and Tapes Antitrust Litigation (N.D. Ill.)

FKLM attorneys served as members of the executive committee in this antitrust pricefixing class action. The class recovered $26 million dollars in settlement in cash and 

assignable purchase certificates.

3⁄4 Kaufman v. Motorola, Inc. (N.D. Ill.)

FKLM attorneys were actively involved in litigating the case and served as liaison 

counsel. A settlement of $25 million was obtained for the plaintiff class.

3⁄4 In re Unisys Securities Litigation, CA No. 99-5333 (E.D. Pa.)

FKLM attorneys served on the executive committee in this derivative action in which 

Plaintiffs recovered $20 million for corporation.

* * *

Other large class action cases in which FKLM attorneys were involved in a leadership 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 18 of 29 PageID #:3767
- 12 -

position include In re Folding Cartons Antitrust Litigation, In re Plywood Antitrust Litigation, In 

re Standard Screws Antitrust Litigation, In re Cotton Yarn Antitrust Litigation, In re Glass 

Containers Antitrust Litigation, In re Aluminum Siding Antitrust Litigation, Rusty Jones 

Warranty Litigation, NPA Securities Litigation, In re Chlor-alkali and Caustic Soda Antitrust 

Litigation, and In re Potash Antitrust Litigation.

FKLM frequently serves as local counsel for a variety of cases, working closely with law 

firms located outside of Illinois. Some examples include North Miami General Employees 

Retirement Fund et al. v. Parkinson et al., Case No. 1:10-cv-06514 (N.D. Ill.) (pending), Marvin 

H. Maurras Revocable Trust v. Bronfman Jr. et al., Case No. 1:12-cv-03395 (N.D. Ill.) 

(pending), and St. Lucie County Fire District Firefighters' Pension Trust Fund v. Motorola, Inc. 

et al., Case No. 1:10-cv-00427 (N.D. Ill.) actions where FKLM was appointed as liaison counsel. 

ATTORNEY PROFILES

Michael J. Freed

After leaving the Department of Justice Antitrust Division, Mr. Freed has engaged in 

private antitrust class action litigation for 50 years. He has served as co-lead counsel in many 

prominent antitrust and securities fraud class action cases. Presently, Mr. Freed is serving as colead counsel in the Kleen Products v. International Paper/Containerboard Antitrust case and In 

re Opana ER Antitrust Litigation. Prior antitrust class actions in which Mr. Freed served as colead counsel include In re Aftermarket Filters Antitrust Litigation, In re Brand Name 

Prescription Drugs Antitrust Litigation, In re High Fructose Corn Syrup Antitrust Litigation, In 

re Linerboard Antitrust Litigation, In re Carbon Dioxide Antitrust Litigation, In re Infant 

Formula Antitrust Litigation, and In re Ocean Shipping Antitrust Litigation. More than $2 billion 

has been recovered for the plaintiff classes in cases in which Mr. Freed has served as co-lead 

counsel.

Mr. Freed has been named an Illinois Super Lawyer by Chicago Magazine, an Illinois 

Leading Lawyer by the Leading Lawyer’s Network, and one of the top plaintiffs’ antitrust 

lawyers in Illinois by Chambers and Partners. In March 2007, Mr. Freed was honored by the 

Chicago Appleseed Fund for Justice for his exceptional pro bono efforts.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 19 of 29 PageID #:3768
- 13 -

Mr. Freed was formerly a trial and appellate attorney with the United States Department 

of Justice, Antitrust Division (Honors Program). He is a graduate of the University of 

Pennsylvania (B.S., 1959) and University of Chicago Law School (J.D., 1962).

Steven A. Kanner

Mr. Kanner has over 30 years’ experience in complex antitrust litigation and previously 

led the class action practice at Much Shelist Freed. His experience includes investigation, 

discovery, trial and appeal of antitrust, securities and other complex cases. Mr. Kanner has been 

designated an Illinois Super Lawyer by Chicago Magazine for the past 5 years and is a frequent 

lecturer both domestically and internationally on antitrust and trade regulation.

With respect to class action matters, Mr. Kanner has been involved in a leadership 

capacity in many of the cases described above. Mr. Kanner is currently serving as co-lead 

counsel or interim co-lead counsel include In re Automotive Parts Antitrust Litigation, MDL 

2311 (E.D. Mich.), (an international price fixing conspiracy of historic proportions which 

currently includes individual cases for Wire Harnesses, Instrument Panel Clusters, Fuel Senders, 

Heater Control Panels, Occupant Safety Systems, Ball Bearings, Air Conditioning Systems, 

Windshield Wiper Systems, Starters, Alternators, Windshield Washer Systems).

Historically, Mr. Kanner has been appointed by federal and state courts as co-lead 

counsel in a broad array of important cases, which have resulted in recoveries of hundreds of 

millions of dollars. Some of these cases include: In re Aftermarket Filters Antitrust Litig., MDL 

1957 (N.D. Ill.) (settlements of over $17 million); In re Carbon Dioxide Antitrust Litig., MDL 

940 (M.D. Fla.) (settlements of over $53 million); In re Flat Glass Antitrust Litig. (No. II), MDL 

1942 (W.D. Pa.) (settlements of over $22 million); In re Hydrogen Peroxide Antirust Litig., 

MDL 1682 (E.D. Pa.) (settlements of over $97 million); In re Isostatic Graphite Antitrust Litig., 

No. 00-cv-1857 (E.D. Pa.) (settlements of over $11 million); In re Koch Gathering Systems, Inc. 

Oil Spill Litig., (Dist. Ct. of Nueces County, Tex.) (settlements of over $10 million); and In re 

Texas Bread Antitrust Litig., No. 95-cv-0048 (E.D. Tex.) (settlements of over $32 million).

A 1979 graduate of DePaul University Law School, Mr. Kanner is admitted to the Bars of 

Illinois, the Northern District of Illinois (member of the trial bar), the United States Court of 

Appeals (Second, Third, Fourth, Fifth, Seventh and Tenth Circuits) and the United States 

Supreme Court. He is also a member of the Chicago Bar Association (Committees on Litigation 

and Antitrust Law), the Illinois State Association (Sections on Antitrust Law and Litigation), the 

American Bar Association (Sections on Antitrust Law and Litigation), the Illinois Trial Lawyers 

Association, and the Decalogue Society where he previously served on the Editorial Board of the 

Society's Law Journal. Prior to entering private practice, Mr. Kanner was employed by the 

Federal Trade Commission as a consumer affairs specialist.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 20 of 29 PageID #:3769
- 14 -

Douglas A. Millen

Mr. Millen devotes his practice to prosecuting direct purchaser, price-fixing class actions 

and has played a key role in many of the most successful price-fixing cases in the United States. 

For example, Mr. Millen was recently appointed to serve on the Plaintiffs’ Steering Committee 

for the In re DPP Beef Antitrust Litigation (D. Minn.) Mr. Millen was appointed to serve on the 

Direct Purchaser Plaintiffs’ Steering Committee in In re Lithium Ion Batteries Antitrust 

Litigation, MDL No. 2420 (N.D. Cal) which ultimately obtained almost $140 million for the 

class. Mr. Millen has also played a prominent role in many of the largest antitrust cases in recent 

history – including: In re Cathode Ray Tube (CRT) Antitrust Litigation, MDL 1971 (N.D. Cal.), 

where he served as Chair of Discovery and aided in the recovery of more than $210 million of 

the class; In re Dynamic Random Access Memory (DRAM) Antitrust Litigation, MDL 1486 (N.D. 

Cal.); In re Vitamins Antitrust Litigation, MDL 1285 (D.D.C.); and In re Rubber Chemicals 

Antitrust Litigation, MDL 1648 (N.D. Cal.) – and his efforts have assisted in the recovery of 

billions of dollars for class members. Accordingly, he has been recognized as one of the nation’s 

top competition lawyers by various publications, including Global Competition Review, and as a 

top Plaintiffs’ lawyer by Lawdragon 500 Leading Lawyers in America. Mr. Millen currently 

represents several Fortune 500 companies in the Rail Freight Fuel Surcharge Antitrust Litigation

and provides antitrust compliance consultation services for large, multi-national companies.

Mr. Millen is a graduate of the University of Michigan (B.G.S., 1991) and University of 

Illinois College of Law (J.D. magna cum laude, 1994). In 1994, he was admitted to the New 

York and Connecticut State Bars; and in 1995 he was admitted to the Illinois State Bar. He is 

also admitted to practice in the Northern and Southern Districts of Illinois. Mr. Millen is a 

member of the American Bar Association, Antitrust Section and the Chicago Bar Association. 

Prior to founding FKLM, Mr. Millen was a partner at Much Shelist Freed, where he practiced 

with the class action group from November 1995 through December 31, 2006. 

William H. London 

Mr. London has been litigating class action cases for over 25 years. He served as trial 

counsel for the plaintiff class in In re High Pressure Laminates Antitrust Litigation, a case that 

was tried before a jury in the Southern District of New York. He was actively involved in 

several cases in which FKLM was serving in a leadership capacity, including In re Flat Glass 

Antitrust Litigation (No. II), MDL No. 1942 (W.D. Pa.); In re Static Random Access Memory 

(SRAM) Antitrust Litigation, MDL No. 1819 (N.D. Cal); and In re Hydrogen Peroxide Antitrust 

Litigation, MDL 1682 (E.D. Pa.). Mr. London presently has significant involvement in In re 

Automotive Parts Antitrust Litigation, MDL 2311 (E.D. Mich.) and In re Optical Disk Drive 

Products Antitrust Litigation, No. 3:10-md-2143 (N.D. Cal.).

Mr. London graduated Magna Cum Laude from Syracuse University in 1984 and 

received his law degree in 1987 from IIT Chicago-Kent College of Law. In 1987, he was 

admitted to the Illinois Bar and the Federal Bar; and in 1988, he was admitted to practice before 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 21 of 29 PageID #:3770
- 15 -

the United States Court of Appeals for the Seventh Circuit. Mr. London is a member of the 

American Bar Association and is a past-Chairman of the Chicago Bar Association Class 

Litigation Committee. He was formerly an Assistant Attorney General for the State of Illinois, 

during which time he argued cases in the United States Court of Appeals for the Seventh Circuit 

and the Illinois Supreme Court. Since 1990, Mr. London has concentrated on complex and 

commercial litigation, with an emphasis on class action litigation involving antitrust claims. Mr. 

London practiced with Much Shelist Freed from March 1993 through December 31, 2006. 

Michael E. Moskovitz

Michael E. Moskovitz is a partner at Freed Kanner London & Millen LLC and has been 

involved in trial and appellate litigation for more than 15 years. Since 2000, he has concentrated 

on complex commercial litigation, with a primary emphasis on class action litigation involving 

antitrust, securities fraud, and consumer fraud claims. Mr. Moskovitz previously played a key 

role in the class action practice of Much Shelist Freed. He is significantly involved in several 

pending antitrust class actions, In re Automotive Parts Antitrust Litigation, MDL 2311 (E.D. 

Mich.), and In re Vehicle Carrier Services Antitrust Litigation, MDL No. 2471. Mr. Moskovitz 

is also a member of The Sedona Conference’s Working Group 1 (Electronic Document 

Retention and Production) and has spoken at The Sedona Conference’s Midyear meeting and has 

co-written papers published by The Sedona Conference. 

Mr. Moskovitz is a graduate of Indiana University (B.A., 1993) and New York 

University School of Law (J.D., 1996).

Robert J. Wozniak

Robert J. Wozniak is a partner at Freed Kanner London & Millen LLC. Since 2001, Mr. 

Wozniak has been involved in complex commercial litigation, with a primary emphasis on 

antitrust, employment, and consumer class action cases. Prior to engaging in private law 

practice, Mr. Wozniak worked as a trial attorney for the United States Department of Justice, 

Antitrust Division (Honors Program). Mr. Wozniak was then employed by Cohen Milstein 

Hausfeld & Toll, a Washington, D.C. class action firm, before joining Much Shelist Freed in 

2004.

The complex antitrust class actions in which Mr. Wozniak has had significant 

involvement include: In re Opana ER Antitrust Litigation (N.D. Ill.); In re Local TV Advertising 

Antitrust Litigation (N.D. Ill.); Mulhern, et al. v. Pepperidge Farm (N.D. Ill.) (consolidated and 

transferred to C.D. Cal for settlement approval); In re Payment Card Interchange Fee and 

Merchant Discount Antitrust Litigation (E.D.N.Y.); Kleen Products, et al. v. International 

Paper, et al. (N.D. Ill.) (“Containerboard Antitrust Litigation”); In re NCAA Student-Athlete 

Names & Likeness Licensing Litigation (N.D. Cal.); In re Fresh and Process Potatoes Antitrust 

Litigation (D. Idaho); In re Municipal Derivatives Antitrust Litigation (S.D.N.Y.); In re Flat 

Glass Antitrust Litigation (II) (W.D. Pa.); In re TFT-LCD (Flat Panel) Antitrust Litigation (N.D. 

Cal.); In re Static Random Access Memory (SRAM) Antitrust Litigation (N.D. Cal.); In re 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 22 of 29 PageID #:3771
- 16 -

Hydrogen Peroxide Antitrust Litigation (E.D. Pa.); In re Intel Corp. Microprocessor Antitrust 

Litigation (D. Del.); In re Dynamic Random Access Memory (DRAM) Litigation (N.D. Cal.); In 

re Buspirone Antitrust Litigation (S.D.N.Y.); and In re Terazosin Hydrochloride Antitrust 

Litigation (S.D. Fla.).

Mr. Wozniak is a graduate of the University of Michigan (B.A., 1988), University of 

Minnesota (M.A., 1994), and Wayne State University Law School (J.D., 2000, cum laude, Order 

of the Coif). He has been admitted to practice law in Illinois, Michigan and the District of 

Columbia.

Kimberly A. Justice

Kimberly A. Justice, a partner of the Firm, is a respected litigator and experienced trial 

lawyer who has dedicated her career to obtaining justice for those harmed by corporate fraud. 

She focuses her practice on class action litigation, including antitrust, consumer and securities 

fraud matters. Ms. Justice has extensive experience in all aspects of complex litigation from 

investigating and developing an initial case theory, to formulating and managing litigation 

strategy, to conducting discovery, to trial. 

She has secured sizeable recoveries on behalf of investors in several high-profile 

securities fraud cases. Kimberly also led the trial team that obtained a jury verdict in favor of 

investors in the In re Longtop Fin. Tech. Ltd. Sec. Litig., No. 11-cv-3658 (S.D.N.Y) securities 

class action litigation, among just a handful of securities cases to be tried to jury verdict. 

Ms. Justice also has served as lead or co-lead counsel in several nationwide antitrust and 

securities fraud class actions. Most recently, Ms. Justice was appointed as Co-Lead Counsel in 

In re Peanut Farmers Antitrust Litigation, 2:19-cv-00463 (E.D. Va.), which settled for $102.75 

million for the class, and In re: Chicago Board of Options Exchange Volatility Index 

Manipulation Antitrust Litigation (N.D. Ill.). Ms. Justice also serves on the Plaintiff 

Steering/Executive Committees in, In re Local TV Advertising Antitrust Litigation, No. 18-cv06785 (N.D. Ill.); In re Farm-Raised Salmon and Salmon Products Litigation, No. 19-cv-21551; 

and In re Toyota Hybrid Brake Litig., No. 4:20-cv-00127-ALM (E.D. Tex.). Ms. Justice also 

served on the Plaintiff Steering Committee in In re: Liquid Aluminum Sulfate Antitrust 

Litigation, No. 16-md-02687 (D.N.J.) (over $90 million in settlements for direct purchaser 

plaintiff class) and In re German Automotive Manufacturers Antitrust Litigation, No. 17-md02796 (N.D. Cal.).

Prior to entering private practice, Ms. Justice served as a federal antitrust prosecutor for 

nearly a decade where she led teams of trial attorneys and law enforcement agents who 

investigated and prosecuted domestic and international cartel activity, including in the following 

industries: graphite electrodes, carbon products, ocean shipping and benchmark interest rates 

(LIBOR).

Ms. Justice graduated magna cum laude from Temple University Beasley School of Law,

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 23 of 29 PageID #:3772
- 17 -

where she served as an Articles Editor of the Temple Law Review. Kimberly earned her B.A. 

cum laude from Kalamazoo College. Upon graduating from law school, Ms. Justice served as a 

judicial clerk to the Honorable William H. Yohn, Jr. of the United States District Court for the 

Eastern District of Pennsylvania.

Ms. Justice frequently lectures and serves on discussion panels concerning antitrust and 

securities litigation matters and currently serves as a member of the Advisory Board of the 

American Antitrust Institute and as an Advisory Council Member for The Duke Conferences: 

Bench-Bar-Academy Distinguished Lawyers’ Series.

Jonathan M. Jagher

Prior to entering private practice, Mr. Jagher served as a supervising Assistant District 

Attorney for the Middlesex District Attorney in Cambridge, Massachusetts. As a prosecutor, he 

conducted numerous investigations and tried approximately forty cases before a jury. 

Mr. Jagher is a partner at Freed Kanner where he has a national practice representing 

plaintiffs in antitrust and consumer class actions. Recent cases include: In re Automotive Parts 

Antitrust Litigation, MDL No. 2311 (E.D. Mich.); In re Korean Ramen Antitrust Litigation,13-

cv-04115 (N.D. Cal.); In re Lithium Ion Batteries Antitrust Litigation, 13-MD-2420 (N.D. Cal.); 

In re OSB Antitrust Litigation, Master File No. 06-CV-00826 (E.D. Pa.); In re Online DVD 

Rental Antitrust Litigation, MDL No. 2029 (N.D. Cal.); In re Processed Eggs Antitrust 

Litigation, MDL No. 2002 (E.D. Pa.); In re Air Cargo Shipping Services Antitrust Litigation, 

MDL No. 1775 (E.D.N.Y.); and In re Broiler Chicken Antitrust Litigation, 1:16-cv-08637 (N.D. 

Ill.).

Mr. Jagher was recently appointed to serve on the Plaintiffs’ Steering Committee in In 

Re: TikTok, Inc., Consumer Privacy Litigation, MDL No. 2948 (N.D. Ill.), a class action related 

to allegations of data privacy violations involving the popular app and the creation of short form 

videos on mobile devices. Mr. Jagher was also recently appointed to serve on the Plaintiffs’ 

Executive Committee in In Re: Morgan Stanley Data Security Litigation, 1:20-CV-05914 (S.D. 

N.Y.), a data privacy class action related to allegations that Morgan Stanley failed to safeguard 

its customers’ highly sensitive personally identifiable information.

Mr. Jagher received a B.A. degree magna cum laude from Boston University in 1998 and 

a J.D. degree from Washington University School of Law in 2001. He is currently admitted to 

practice law in Pennsylvania, Massachusetts, the United States District Court for the District of 

Massachusetts, the United States District Court for the Eastern District of Pennsylvania and the 

United States Court of Appeals for the Third Circuit. Mr. Jagher currently serves on the 

Advisory Board of Loyola University School of Law’s Institute for Consumer Antitrust Studies 

and is a member of the Philadelphia Bar Association and the American Bar Association. Mr. 

Jagher was named as a Pennsylvania Super Lawyer in 2018 and 2019 after having been named as 

a Super Lawyer Rising Star in 2012, 2013, 2014, 2015 and 2016.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 24 of 29 PageID #:3773
- 18 -

Brian M. Hogan

Brian M. Hogan is a partner at Freed Kanner London & Millen LLC. He specializes in 

class action litigation and has a wide range of experience successfully handling product liability, 

mass tort, toxic and environmental exposure, consumer protection and antitrust cases. He has 

litigated cases in numerous state and federal courts nationwide, including multidistrict litigation.

Mr. Hogan has tried over a dozen cases to verdict.

Currently, Mr. Hogan has significant involvement litigating In re Automotive Parts 

Antitrust Litigation, MDL No. 2311 (E.D. Mich.), In re Payment Card Interchange Fee and 

Merchant Discount Antitrust Litigation, 05-md-1720 (E.D.N.Y.), and In re Opana ER Antitrust 

Litigation, 1:14-cv-10150 (N.D. Ill.) where Freed Kanner London & Millen is court-appointed 

co-lead counsel representing direct purchasers of automotive parts who were overcharged as a 

result of price-fixing and bid-rigging conspiracies by various sets of defendants throughout the 

automotive parts industry. The litigation follows the largest United States Department of Justice 

criminal antitrust investigation in history. 

Mr. Hogan received a B.A. from Indiana University and his J.D. from Chicago-Kent 

College of Law.

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 25 of 29 PageID #:3774
Exhibit 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 26 of 29 PageID #:3775
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

H

Michael J. Freed (OC) 0.30 0.00 0.30 0.30 $Brian M. Hogan (P) 10.00 39.80 0.60 1.40 4.10 0.00 55.90 55.90 

Jonathan M. Jagher (P) 67.40 17.90 298.00 52.60 2.10 750.20 119.80 0.00 1,308.00 1,308.00 Kimberly A. Justice (P) 6.50 37.20 68.10 38.20 0.00 150.00 150.00 

Steven A. Kanner (P) 10.10 1.10 0.00 11.20 11.20 $

William H. London (P) 0.30 0.00 0.30 0.30 Douglas A. Millen (P) 2.80 1.40 4.40 9.50 33.90 0.00 52.00 52.00 

Robert J. Wozniak (P) 0.50 0.00 0.50 0.50 

0.00 0.00 0.00 

SUB-TOTAL 0.00 77.20 27.90 0.00 386.50 0.00 0.00 0.00 57.60 2.10 829.50 197.40 0.00 0.00 0.00 0.00 1,578.20 1,578.20 

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

H

Marlene Khamoo 12.90 0.00 12.90 12.90 

Name (LC) 0.00 0.00 0.00 Name (LC) 0.00 0.00 0.00 Name (SPL) 0.00 0.00 0.00 Name (SPL) 0.00 0.00 0.00 Name (SPL) 0.00 0.00 0.00 Name (PL) 0.00 0.00 0.00 Name (PL) 0.00 0.00 0.00 Name (PL) 0.00 0.00 0.00 Name (PL) 0.00 0.00 0.00 

0.00 0.00 0.00 

0.00 0.00 0.00 

SUB-TOTAL 0.00 0.00 0.00 0.00 12.90 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 12.90 12.90 

GRAND TOTAL: 0.00 77.20 27.90 0.00 399.40 0.00 0.00 0.00 57.60 2.10 829.50 197.40 0.00 0.00 0.00 0.00 1591.10 1,591.10 

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) (A) (LC(SP(PL

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT CURRENT RATES

FREED KANNER LONDON & MILLEN LLC Reporting Period: Inception through February 28, 2022

 556281 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 27 of 29 PageID #:37
Exhibit 

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 28 of 29 PageID #:3777
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees $400.00

Experts/consultants $5,000.00

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw

Charges for PACER and 

Westlaw $2,025.16

Photocopies - in House $8.60

Photocopies - Outside

Telephone/telecopier

Travel - Transportation

(Airplanes - Coach Fares Only) $1,446.32

Travel - Meals

($75 per person / day cap) $1,459.25

Travel - Hotels $1,144.75

Miscellaneous Gratuity and Internet on Flight $70.99

TOTAL EXPENSES $11,555.07

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: FREED KANNER LONDON & MILLEN LLC

REPORTING PERIOD: Inception through February 28, 2022

 556281 Ex 2 Expense Summary

Case: 1:20-cv-04699 Document #: 197-18 Filed: 03/31/22 Page 29 of 29 PageID #:3778