EXHIBIT 6

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BEFORE THE UNITED STATES JOINT PANEL 

ON MULTIDISTRICT LITIGATION 

 ) 

IN RE: TIKTOK, INC., CONSUMER ) 

PRIVACY LITIGATION ) MDL No. 2948

 ) 

NORTHERN DISTRICT OF ILLINOIS PLAINTIFFS’ RESPONSE IN SUPPORT OF 

TRANSFER TO THE NORTHERN DISTRICT OF ILLINOIS FOR 

COORDINATED OR CONSOLIDATED PRETRIAL PROCEEDINGS 

 Plaintiffs1

 in five now-consolidated class actions pending in the Northern District of Illinois 

(“ND Ill. Plaintiffs”) submit this brief in support of the Motion for Transfer and Coordination of 

Actions Pursuant to 28 U.S.C. § 1407, but believe that, rather than transfer to the Southern District 

of Illinois, all related actions should be transferred to the Northern District of Illinois for 

consolidated pretrial proceedings before the Honorable John Z. Lee. 

I. INTRODUCTION 

 The ND Ill. Plaintiffs are Illinois resident minors in five separate lawsuits filed in federal 

court in Illinois asserting Illinois-based claims on behalf of a putative class composed exclusively 

of other Illinois resident minors. They seek relief for Defendants TikTok, Inc.’s and ByteDance, 

Inc.’s (collectively, “Defendants”) violations of the Illinois Biometric Information Privacy Act 

(“BIPA”), 740 ILCS 15/1, et seq. Specifically, the ND Ill. Plaintiffs allege Defendants’ ubiquitous 

smartphone application, “TikTok,” scans users’ facial geometry, and thereafter (without consent) 

captures, retains and disseminates their biometric identifiers and information in violation of BIPA. 

1

 Plaintiffs swiftly organized their individual actions by relating them before the Honorable John 

Z. Lee, and agreeing to consolidation with E.R. v. TikTok, Inc. et al, No. 1:20-cv-2810 (N.D. Ill.) 

(filed May 8, 2020), the first-filed action in the Northern District of Illinois. The four other actions 

originally were styled as follows: K.M. v. TikTok, Inc. et al., No. 1:20-cv-2883 (N.D. Ill.) (filed 

May 13, 2020); D.H. v. TikTok, Inc. et al., No. 1:20-cv-2884 (N.D. Ill.) (filed May 13, 2020); L.B. 

v. TikTok, Inc. et al., No: 1:20-cv-2889 (N.D. Ill.) (filed May 13, 2020); H.S. v. ByteDance, Inc. et 

al., No. 1:20-cv-3007 (N.D. Ill.) (filed May 20, 2020) (collectively, the “ND Ill. Action”). 

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As of the date of this filing, sixteen similar—though not identical—actions are currently pending 

in four different judicial districts: the Northern District of Illinois, the Southern District of Illinois, 

the Northern District of California, and the Central District of California (hereinafter, the “Related 

Actions”).2

 

 The ND Ill. Plaintiffs initially believed these cases could be coordinated informally to 

obviate any need for centralization. To that end, the ND Ill. Plaintiffs proceeded as this Panel 

suggested: they self-organized their actions before Judge Lee and immediately attempted to 

coordinate their consolidated case with all counsel for plaintiffs in the Related Actions and counsel 

for Defendants. During these communications, counsel for Defendants expressed an interest in 

pursuing mediation and the ND Ill. Plaintiffs agreed. The mediation is currently scheduled to take 

place on August 13, 2020 before the Honorable Layn R. Phillips (Ret.). Judge Phillips has already 

mediated this case once with Defendants and counsel in the Hong litigation (the first filed action 

in California). Thus, ND Ill. Plaintiffs believe that a second mediation with the same judge allows 

the parties to capitalize on these prior efforts. 

Recognizing their fiduciary duty to explore the possibility of settlement for the class, 

counsel for the ND Ill. Plaintiffs immediately notified all plaintiffs’ counsel and invited them to 

participate in mediation. Plaintiffs’ counsel in actions pending in the Southern District of Illinois 

and Central District of California agreed to coordinate with the ND Ill. Plaintiffs and participate 

in mediation.3

 Counsel for plaintiffs in some of the Northern District of California cases have also 

2

 All actions, except one action filed in the Central District of California, allege BIPA violations. 

That action is based on violations of California law. 

3

 At the time of these discussions, only one action was pending in the Central District of 

California, G.R. v. TikTok, Inc. et al., No. 2:20-cv-4357 (C.D. Cal.) (filed May 20, 2020), and 

counsel in this matter agreed to attend mediation. ND Ill. Plaintiffs’ counsel just learned of a 

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3 

agreed to participate, although plaintiffs’ counsel in the Hong matter has declined. Because of this 

unfortunate lack of complete unanimity, transfer and centralization pursuant to 28 U.S.C. § 1407 

not only is appropriate, but necessary. 

 In light of all the facts, the Northern District of Illinois is the most appropriate transferee 

forum. As detailed below, the plaintiffs in all but one Related Action include Illinois residents 

under the age of 18, all of whom would be greatly inconvenienced if required to litigate their claims 

in California federal court, which they bring almost exclusively on behalf of an Illinois class for 

violations of an Illinois statute. Nor would transfer to the Northern District of Illinois 

inconvenience Defendants, who have agreed to centralization in the Northern District of Illinois if 

the Panel so chooses. When these factors are considered alongside the Northern District of Illinois’ 

geographically central location, favorable caseload and nexus to this action, there can be no doubt 

that centralization and coordination in the Northern District of Illinois will best further Section 

1407’s twin objectives: promoting convenience and the efficient prosecution of all cases. 

II. BACKGROUND 

A. The TikTok App 

 Defendants operate TikTok, a widely popular video-sharing social media application. 

TikTok is especially popular with teenagers and young adults. The app permits users to create and 

share short videos, and to use filters and other effects therein. To utilize many of the effects, 

Defendants scan users’ faces and “face geometries” to, inter alia, superimpose stickers on users’ 

faces, enhance aspects of their facial features, or swap the user’s face for an emoji or another 

individual’s face. Defendants also scan users’ faces to determine the user’s age using an algorithm. 

5036 (C.D. Cal.), and have not yet had the opportunity to communicate with counsel in that 

matter. 

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B. The Related Actions 

 The ND. Ill. Plaintiffs are Illinois-resident minors who, through their guardians, 

commenced five separate class actions arising from Defendants’ alleged violations of Illinois 

BIPA. The first action E.R. v. TikTok, Inc. et al, No. 1:20-cv-2810 (N.D. Ill.), was filed on May 

8, 2020, and assigned to the Honorable John Z. Lee. A copy of the docket as of the date of this 

filing is attached hereto as Exhibit A. 

To conserve judicial resources, the E.R. plaintiff moved to relate and reassign to Judge Lee 

three later-filed actions, with consent of all counsel. The motion to relate and reassign was granted 

on May 21, 2020 (Ex. A, at ECF No. 10), and Judge Lee later consolidated those cases with E.R.

(Id., at ECF No. 14.) On May 29, 2020, Judge Lee ordered consolidation of a subsequent related 

action, set June 12, 2020 as a deadline for the filing of a consolidated complaint, and appointed 

Katrina Carroll of Carlson Lynch LLP (“Carroll”), filer of the first BIPA action in the district, as 

interim lead Plaintiffs’ counsel during the pendency of the MDL petition. (Id., at ECF No. 18.) 

All counsel in the ND Ill. have organized themselves and are diligently and cooperatively working 

together and intend to file their Consolidated Complaint no later than June 12, 2020, as Judge Lee 

ordered. 

 The related litigation in California is much less organized than the proceedings in the 

Northern District of Illinois and the procedural history is somewhat complicated. The “first filed” 

of all related cases which are the subject of this MDL is Hong v. ByteDance, Inc. et al., 5:19-cv07792-LHK, filed in the Northern District of California in November of 2019. Hong is not the 

first BIPA case filed against TikTok in California, however. Indeed, as originally pled, Hong was 

not a BIPA case at all, was not brought on behalf of any Illinois plaintiffs, and did not seek to 

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represent a putative class of any Illinois residents - in other words, the case had no ties whatsoever 

to Illinois. 

After unsuccessfully mediating their action with Judge Phillips, Hong counsel amended 

their complaint to add Illinois plaintiffs and a BIPA claim on May 11, 2020 - after E.R. was filed 

in the Northern District of Illinois and a separate, BIPA-only case was filed in California.4 

Thereafter, five new BIPA cases were filed in the Northern District of California and all of the 

related actions were consolidated with Hong.

5

While Hong now includes a BIPA claim, that action still includes all claims initially pled 

(a broad panoply of California causes of action), the plaintiffs seek to represent the broadest class 

conceivable (all TikTok users in the United States) and the case is not tailored as a BIPA case. 

Thus, Hong is an outlier. All other related actions (except one) filed in all districts are BIPAexclusive, Illinois-based cases brought on behalf of Illinois classes by Illinois residents under 

Illinois law.6 Illinois is the obvious nexus and tie that binds all of the actions together and is thus 

the most logical place for the cases to proceed. 

This makes sense, in fact, because the Illinois cases are organized and the proceedings are 

more advanced that those in California. Despite the fact that the non-BIPA Hong complaint was 

4

 The first filed BIPA case in California is P.S. v. TikTok, Inc., No. 3:20-cv-2992 (filed Apr. 30, 

2020), filed within days of E.R. in the Northern District of Illinois. 

5 See Schedule of Actions, MDL No. 2948 (ECF No. 1-2); Notices of Related Actions, (ECF Nos. 

13, 24, 27, 28). 

6

 As previously noted, there is one action pending in the Central District of California (G.R. v. 

TikTok, Inc. et al., No. 2:20-cv-4357 (C.D. Cal.) alleging violations of the California Consumer 

Privacy Act and another BIPA case, C.H. v. TikTok, Inc. et al., No. 2:20-cv-5036 (C.D. Cal.). 

There are two BIPA cases pending in the Southern District of Illinois (A.S. v. TikTok, Inc. et al., 

No. 3:20-cv-457 (S.D. Ill.) (filed May 15, 2020); L.M. v. TikTok, Inc. et al, No. 3:-20-498 (S.D. 

Ill.) (filed May 29, 2020)). Through their coordination efforts, ND. Ill. Plaintiffs understand that 

counsel in the G.R. action and both S.D. Ill. actions are not opposed to centralization in the 

Northern District of Illinois for the reasons stated herein. 

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filed in November 2019, no dispositive motions have been filed, no discovery has been exchanged, 

and no leadership structure has been proposed to Judge Koh, who is overseeing the consolidated 

actions in the Northern District of California. Defendants have not responded to the original Hong

complaint, the amended Hong complaint, nor any of the recently-filed BIPA complaints. In fact, 

leadership for the ND. Cal. cases is not scheduled to be addressed until a hearing scheduled for 

July 23, 2020, and a consolidated amended complaint is not due until 21 days after leadership is 

appointed for the ND. Cal. plaintiffs. 

Contrast the progression (or lack thereof) of the ND. Cal. actions with that of the ND. Ill. 

Action. The ND. Ill. Plaintiffs agreed upon leadership within days of the first four cases being 

filed. Within 21 days of the filing of the first ND. Ill. action, Judge Lee appointed Carroll as 

interim lead Plaintiffs’ counsel during the pendency of the MDL petition and ordered that a 

Consolidated Complaint be filed on June 12, 2020. (Ex. A, at ECF No. 18).7

 Within five days of 

Judge Lee’s scheduling order, Carroll notified Judge Lee and all counsel for all related actions of 

the mediation opportunity that Defendants presented to her. In just over a month since the firstfiled ND. Ill. action, the ND. Ill. Plaintiffs have self-organized with Judge Lee’s assistance, will 

have filed their Consolidated Complaint and scheduled a mediation which will be attended by 

counsel for all districts involved. The ND. Ill. Plaintiffs have advanced their litigation well beyond 

that of the ND. Cal. actions. 

C. The ND. Ill. Plaintiffs Attempted to Coordinate Prosecution of the Related 

Actions 

As the Panel requested, the ND. Ill. Plaintiffs took every conceivable step “to pursue 

alternatives to centralization (including, but not limited to, engaging in informal coordination of 

7

 At Carroll’s own suggestion and by agreement of all counsel for the ND. Ill. actions on file at the 

time of the submitted proposed order, the ND. Ill. Plaintiffs proposed that the leadership 

appointment be temporary until the panel rules on the pending Motion. 

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discovery and scheduling, and seeking Section 1404 transfer of one or more of the subject cases.).” 

(ECF No. 4). Indeed, since before these MDL proceedings, the ND. Ill. Plaintiffs have maintained 

a constant dialogue with plaintiffs’ counsel in the Related Actions in order to explore alternatives 

to centralization. Those efforts continued following the filing of the Transfer Motion, during 

which time the Related Actions pending in the Northern District of Illinois and California were 

consolidated before Judges Lee and Koh, respectively. 

Because the Related Actions have largely been consolidated in their respective fora—as 

well as the fact the Illinois actions seek relief exclusively for Illinois minors under a single Illinois 

statute—the ND. Ill. Plaintiffs proposed to all counsel in all of the actions that the parties continue 

to informally coordinate amongst themselves, rather than engage in a four-way, Section 1404 

motion practice. Under this approach, each action would pursue its own discrete legal theories 

and claims while coordinating their discovery efforts to ensure the Related Actions proceed 

efficiently. To that end, the ND. Ill. Plaintiffs and Defendants agreed to proceed to mediation with 

the assistance of the Honorable Layn Phillips (Ret.), and on June 3, 2020, the ND. Ill. Plaintiffs 

immediately invited all plaintiffs’ counsel to participate. See Exhibit B, attached hereto. 

 Certain counsel from each district accepted this invitation and agreed to participate in the 

mediation. Unfortunately, ND Ill. Plaintiffs have been unable to obtain the cooperation of all 

counsel for the ND. Cal. actions. Rather than try to coordinate with the ND. Ill. Plaintiffs, the 

Hong plaintiffs did just the opposite. They flatly refused to participate in any mediation alongside 

other counsel and instead have chosen to pursue intervention in the related ND. Ill. Action for the 

purpose of seeking dismissal of the ND. Ill. Action. 

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D. The Hong Plaintiffs-Intervenors’ Attempts to Intervene In Every Illinois 

Action Come At the Expense of the Class 

 Rather than engage in productive coordination as this Panel asked, the Hong plaintiffs 

opted to intervene in the ND. Ill. Action and the SD. Ill. Actions. Incredibly, they pursue 

intervention at the Illinois class’s peril through jurisdictional and venue arguments belonging to 

Defendants that Defendants themselves have never raised. The papers are also peppered with ad 

hominem attacks on counsel. Personal attacks aside, the Hong plaintiffs’ decision to appear in 

related cases and take unasserted defense positions is hardly the type of cooperation and informal 

coordination this Panel envisioned, let alone designed to advance the best interests of the putative 

class. Moreover, as Defendants have advised the Panel, they are not opposed to centralization in 

the Northern District of Illinois, showing that jurisdiction and venue are non-issues. 

In any event, when the Hong plaintiffs moved to intervene in the ND. Ill. Action, Carroll, 

as court-appointed interim lead counsel pending this MDL proceeding, conferred with Defendants 

and immediately advised Judge Lee that, given the pendency of the MDL, duplicative motions to 

transfer are not necessary or appropriate here. Counsel for the parties in the ND. Ill. Action 

immediately filed a joint status report to apprise the court that they oppose intervention and 

transfer. Their joint response is due to Judge Lee on June 17, 2020. 

For reasons that will soon become apparent in response, the Hong plaintiffs’ motions to 

intervene are both procedurally and substantively defective. They cannot meet the requirements 

for intervention as of right or permissive intervention. Nor can they meet the standard for 

intervention by making a showing that they have some interest in this litigation that is particular 

to intervenor and not the existing Plaintiffs. 

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Suffice it to say, the Hong plaintiffs’ motions, which ND. Ill. Plaintiffs will ask Judge Lee 

to promptly deny, and their refusal to informally coordinate the Related Actions for the benefit of 

the putative classes, confirms that the Panel’s intervention is necessary. 

III. ARGUMENT 

A. Legal standard 

 “When civil actions involving one or more common questions of fact are pending in 

different districts, such actions may be transferred to any district for . . . the convenience of parties 

and witnesses and [promotion of] just and efficient conduct of such actions.” 28 U.S.C.A. § 1407. 

Pursuant to 28 U.S.C. § 1407(a), transfer and centralization is appropriate where (1) the pending 

actions involve one or more common questions of fact; (2) transfer will aid the convenience of 

parties and witnesses; and (3) transfer will promote the just and efficient conduct of such actions. 

In these instances, transfer and centralization streamlines discovery, avoids conflicting rulings and 

scheduling issues, minimizes costs, and conserves the time and resources of the parties, witnesses 

and the courts. See Manual for Complex Litigation § 20.131 (4th ed. 2016). As discussed below, 

these factors weigh heavily in favor of transfer and centralization in the Northern District of 

Illinois. 

B. The Actions Share Common Factual Questions

 The Related Actions undoubtedly meet the threshold requirement for centralization under 

28 U.S.C. § 1407(a) because they share common factual questions. See In re Fed. Election 

Campaign Act Litig., 511 F. Supp. 821, 823 (J.P.M.L. 1979) (transfer was appropriate in cases 

sharing common factual issues in order to avoid duplication of discovery efforts and prevent 

inconsistent rulings). It matters not that the plaintiffs in each Related Action bring varying state 

law claims; “the applicability of different legal principles will not prevent the transfer of an action 

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under section 1407 if the requisite common questions of fact exist.” In re Antibiotic Drugs, 309 F. 

Supp. 155, 156 (J.P.M.L. 1970). 

 Because the bulk of the Actions arise from the same operative facts—Defendants’ alleged 

collection and dissemination of users’ private data without their consent—and seek to recover 

under similar legal theories, transfer and centralization is appropriate. In re Zyprexa Prod. Liab. 

Litig., 314 F. Supp. 2d 1380, 1381 (J.P.M.L. 2004) (“transfer under Section 1407 does not require 

a complete identity or even majority of common factual issues as a prerequisite to transfer”). 

Moreover, because the Actions seek to certify overlapping classes, transfer and centralization will 

guard against inconsistent rulings and class determinations. See In re U. S. Fin. Sec. Litig., 375 F. 

Supp. 1403, 1404 (J.P.M.L. 1974) (“the prevalence of common factual issues and similar class 

allegations necessitates transfer of all actions to a single district for coordinated or consolidated 

pretrial proceedings under Section 1407 in order to prevent duplication of discovery and eliminate 

the possibility of inconsistent or overlapping class determinations”). 

 The ND. Ill. Plaintiffs recognize that transfer “under Section 1407 should be the last 

solution after considered review of all other options.” In re Best Buy Co., Inc., California SongBeverly Credit Card Act Litig. 804 F.Supp.2d 1376, 1378 (J.P.M.L. 2011) (denying transfer under 

Section 1407 due to the limited number of cases and the possibility of informal coordination). 

And, for their part, ND Ill. Plaintiffs made a good faith effort to pursue “informal cooperation 

among counsel” in lieu of centralization. In re: Crest Sensitivity Treatment & Protection 

Toothpaste Marketing and Sales Practices Litig., 857 F. Supp. 2d 1348 (J.P.M.L. 2012) (denying 

centralization under Section 1407). Unfortunately, the failure of their efforts has only crystallized 

the need for transfer and centralization pursuant to Section 1407. 

C. The Panel Should Centralize the Related Actions in the Northern District of 

Illinois Before Judge Lee

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In selecting a transferee forum, the Panel typically considers “the site of the occurrence of 

the common facts, where the cost and inconvenience will be minimized, and the experience, skill, 

and caseloads of available judges.” Manual for Complex Litigation § 20.131 (4th ed. 2016). Each 

of these factors weighs in favor of transfer to and centralization in the Northern District of Illinois. 

1. The Northern District of Illinois Bears the Strongest Nexus to this 

Litigation. 

The Northern District of Illinois undoubtedly possesses the strongest connection to this 

litigation. It matters not that the Defendants reside in California—all but one of the Related 

Actions brings claims pursuant to BIPA (an Illinois statute) on behalf of a class of Illinois residents 

harmed while they used the TikTok app in Illinois. And Defendants have indicated that 

centralization is proper in the Northern District of Illinois. 

Indeed, no judicial district is more qualified to oversee BIPA litigation. Illinois courts have 

overseen and adjudicated issues in hundreds of BIPA cases during the last three years. See In re: 

Helicopter Crash Near Wendle Creek, British Columbia, on Aug. 8, 2002, 542 F. Supp. 2d 1362, 

1363 (J.P.M.L. 2008) (“Indeed, the transferee judge has developed a familiarity with the 

allegations, issues, parties and counsel involved in this docket, which will further the expeditious 

resolution of the litigation taken as a whole.”). Indeed, there have been nearly 200 BIPA class 

actions filed in Illinois courts, which has become the hub for actions brought pursuant to Illinois’ 

groundbreaking statute. The Northern District of Illinois clearly bears the strongest nexus to this 

litigation. 

2. The Northern District of Illinois Is the Most Convenient Forum 

The Northern District of Illinois also is a convenient and readily accessible location for all 

counsel and witnesses. Located in Chicago, the Court is accessible by both Chicago O’Hare 

International Airport and Chicago Midway Airport. As the Panel has recognized in the past, these 

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factors make the Northern District of Illinois a convenient forum for geographically dispersed 

parties. In re McDonald’s French Fries Litig., 444 F. Supp. 2d 1342, 1343 (J.P.M.L. 2006), 

adhered to, 545 F. Supp. 2d 1356 (J.P.M.L. 2008) (finding “given the geographic dispersal of the 

constituent actions, the Northern District of Illinois offers a relatively geographically central and 

accessible forum for this litigation”); In re: Fluidmaster, Inc., 65 F. Supp. 3d 1397, 1398 (J.P.M.L. 

2014) (observing the Northern District of Illinois “offers a geographically accessible forum for 

this nationwide litigation”); In re Fairlife Milk Prod. Mktg. & Sales Practices Litig., 396 F. Supp. 

3d 1370, 1371 (J.P.M.L. 2019) (“The Northern District of Illinois thus presents a convenient and 

accessible forum for this litigation.”). 

Moreover, the sweeping majority of the plaintiffs in the Related Actions reside in Illinois.

Ensuring the convenience of these plaintiffs—all except one are minors—is paramount. See, e.g.,

Sickman v. Asset Recovery Solutions, LLC, No. 14 C 9748, 2015 WL 1911431, *3 (N.D. Ill. Apr 

27, 2015) (“the court is most concerned with the convenience of the putative class members whom 

plaintiff seeks to represent”). This is particularly true here where Defendants concede that they 

will not be inconvenienced in the slightest if the cases are transferred to the Northern District of 

Illinois. 

3. The Northern District of Illinois Possesses Sufficient Resources and 

Expertise, and a Favorable Caseload

Docket conditions also favor the Northern District of Illinois over the Northern District of 

California, one of the proposed transferee courts.8

 As of May 15, 2020, there are twice as many 

MDLs pending in the Northern District of California than in the Northern District of Illinois. And 

8 MDL Statistics Report – Distribution of Pending MDL Dockets by District, JPML, 

https://www.jpml.uscourts.gov/sites/jpml/files/Pending_MDL_Dockets_By_District-May-15-

2020.pdf (report date: May 15, 2020). 

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as of 2019, there also was an average of 854 pending cases per judgeship in the Northern District 

of California, compared to just 722 in the Northern District of Illinois.9 Judge Koh—the proposed 

transferee judge in the Northern District of California—currently is presiding over two MDLs 

comprised of 53 separate actions. Conversely, Judge Lee, the proposed transferee judge in the 

Northern District of Illinois, currently presides over only one MDL in which a settlement already 

has been reached and granted final approval. Transfer to Judge Lee will support the efficient 

resolution of this litigation. 

Most importantly, Judge Lee possesses experience presiding over both MDLs and complex 

consumer class action lawsuits. See, e.g., In re Nat’l Collegiate Athletic Ass’n Student-Athlete 

Concussion Injury Litig., 332 F.R.D. 202, 207 (N.D. Ill. 2019), aff’d sub nom. Walker v. Nat’l 

Collegiate Athletic Ass’n, No. 19-2638, 2019 WL 8058082 (7th Cir. Oct. 25, 2019) (granting final 

approval in MDL proceeding related to “the way the NCAA handled student-athlete concussions 

and concussion related risks”); Craftwood Lumber Co. v. B.E. Atlas Co., No. 16-CV-07865, 2018 

WL 2077729, at *1 (N.D. Ill. Mar. 30, 2018) (granting final approval to Telephone Consumer 

Protection Act settlement). Judge Lee is more than qualified to “steer this litigation on an efficient 

and prudent course.” In re Fairlife Milk Prod. Mktg. & Sales Practices Litig., 396 F. Supp. 3d at 

1371. 

9 United States District Courts – National Judicial Caseload Profile, UNITED STATES COURTS, 

https://www.uscourts.gov/sites/default/files/data_tables/fcms_na_distprofile1231.2019.pdf (last 

visited June 3, 2020). 

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IV. CONCLUSION 

 For the foregoing reasons, the ND. Ill. Plaintiffs respectfully request that the Panel transfer 

the Related Actions to the Northern District of Illinois for coordinated pretrial proceedings. 

Respectfully submitted, 

Date: June 9, 2020 CARLSON LYNCH LLP 

/s/ Katrina Carroll

Katrina Carroll 

kcarroll@carlsonlynch.com 

Kyle A. Shamberg 

kshamberg@ carlsonlynch.com 

Nicholas R. Lange 

nlange@carlsonlynch.com 

111 W. Washington Street, Suite 1240 

Chicago, IL 60602 

Telephone: (312) 750-1265 

Plaintiff’s Counsel in E.R. v. TikTok, Inc., No. 1:20-cv2810 (N.D. Ill.) 

Douglas A. Millen 

Brian M. Hogan 

FREED KANNER LONDON & 

 MILLEN LLC 

2201 Waukegan Road, Suite 130 

Bannockburn, Illinois 60015 

Tel.: (224) 632-4500 

Fax: (224) 632-4521 

dmillen@fklmlaw.com 

bhogan@fklmlaw.com 

 

Jonathan M. Jagher 

Kimberly A. Justice 

FREED KANNER LONDON & 

 MILLEN LLC 

923 Fayette St. 

Conshohocken, PA 19428 

Tel.: (610) 234-6487 

Fax: (224) 632-4521 

jjagher@fklmlaw.com 

kjustice@fklmlaw.com 

Plaintiffs’ Counsel in D.H. v. TikTok, Inc., No. 1:20-cv2884 (N.D. Ill.) 

Case: 1:19-cv-07915 Document #: 52-6 Filed: 09/09/20 Page 15 of 17 PageID #:2343 Case: 1:20-cv-04699 Document #: 59-8 Filed: 09/09/20 Page 15 of 17 PageID #:1471 Case MDL No. 2948 Document 35 Filed 06/09/20 Page 14 of 16
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Jennifer W. Sprengel 

Daniel O. Herrera 

Nickolas J. Hagman 

CAFFERTY CLOBES MERIWETHER 

& SPRENGEL LLP 

150 S. Wacker, Suite 3000 

Chicago, Illinois 60606 

Telephone: 312-782-4880 

Facsimile: 318-782-4485 

jsprengel@caffertyclobes.com 

dherrera@caffertyclobes.com 

nhagman@caffertyclobes.com 

Plaintiffs’ Counsel in L.B. v. TikTok, Inc., et al., No. 

1:20-cv-2889 (N.D. Ill.) 

Joseph G. Sauder 

Joseph B. Kenney 

SAUDER SCHELKOPF LLC 

1109 Lancaster Avenue 

Berwyn, PA 19312 

Telephone: (610) 200-0580 

Fax: (610) 421-1326 

jgs@sstriallawyers.com 

jbk@sstriallawyers.com 

Richard R. Gordon 

Gordon Law Offices, Ltd. 

111 West Washington Street 

Suite 1240 

Chicago, Illinois 60602 

Tel: (312) 332-5200 

Fax: (312) 242-4966 

rrg@gordonlawchicago.com 

Plaintiffs’ Counsel in Marks v. TikTok, Inc., No. 1:20-cv2883 (N.D. Ill.) 

James B. Zouras 

Ryan F. Stephan 

Andrew C. Ficzko 

Megan E. Shannon 

STEPHAN ZOURAS, LLP 

100 N. Riverside Plaza, 

Suite 2150 

Case: 1:19-cv-07915 Document #: 52-6 Filed: 09/09/20 Page 16 of 17 PageID #:2344 Case: 1:20-cv-04699 Document #: 59-8 Filed: 09/09/20 Page 16 of 17 PageID #:1472 Case MDL No. 2948 Document 35 Filed 06/09/20 Page 15 of 16
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Chicago, Illinois 60606 

312.233.1550 

312.233.1560 f 

rstephan@stephanzouras.com 

jzouras@stephanzouras.com 

aficzko@stephanzouras.com 

mshannon@stephanzouras.com 

Erik H. Langeland 

733 Third Avenue, 15th Floor 

New York, N.Y. 10017 

(212) 354-6270 

elangeland@langelandlaw.com

Jon A. Tostrud 

TOSTRUD LAW GROUP, P.C. 

1925 Century Park East, Suite 2100 

Los Angeles, CA 90067 

(310) 278-2600 

jtostrud@tostrudlaw.com

Plaintiffs’ Counsel in H.S. v. Bytedance, Inc. et al., No. 

1:20-cv-3007 (N.D. Ill.)

Case: 1:19-cv-07915 Document #: 52-6 Filed: 09/09/20 Page 17 of 17 PageID #:2345 Case: 1:20-cv-04699 Document #: 59-8 Filed: 09/09/20 Page 17 of 17 PageID #:1473 Case MDL No. 2948 Document 35 Filed 06/09/20 Page 16 of 16