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IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: TIKTOK, INC., CONSUMER 

PRIVACY LITIGATION 

This Document Relates to All Cases

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MDL No. 2948

Master Docket No. 20-cv-4699

Judge John Z. Lee

Magistrate Judge Sunil R. Harjani

 

OBJECTOR MARK S.’s MOTION FOR LEAVE TO SEAL PORTIONS OF

OBJECTIONS TO CLASS ACTION SETTLMENT BY MARK S., AS PARENT AND 

LEGAL GUARDIAN OF HIS MINOR SON, A.S.

Pursuant to Fed. R. Civ. P. 5.2 and Local Rules 5.8 and 26.2, Objector Mark S. respectfully

moves the Court for leave to file portions of the Objections to Class Action Settlement by Mark 

S., as Parent and Legal Guardian of His Minor Son, A.S. (the “Objections”) (Dkt. 187) under seal, 

nunc pro tunc to January 30, 2022. In support of this motion, Objector Mark S. states as follows:

1. On January 30, 2022, Mark S. filed the Objections, as parent and legal guardian of 

his minor son, A.S. Dkt. 187. To protect the confidential nature of a limited amount of information,

Mark S. redacted that information from the public filing and provided the Court, Plaintiffs’

leadership counsel and defense counsel with a non-redacted version of the filing. 

2. The specific information that was redacted was: (a) Mark S.’s last name and 

signature; (b) the full name of A.S., who is a minor; (c) Mark S.’s address and telephone number; 

(d) A.S.’s date of birth; (e) the TikTok usernames A.S. believed he used.

3. Pursuant to Fed. R. Civ. P. 5.2, a public filing may not include the full birthdate of 

an individual or the full name of a minor. See Fed. R. Civ. P. 5.2.

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4. Pursuant to Local Rule 26.2, the Court may for good cause shown allow documents 

to be filed under seal. See L.R. 26.2(b). 

5. Good cause exists to allow the limited personal information redacted from the

Objections to be filed under seal. Disclosure of Mark S.’s last name would defeat the purpose of 

keeping A.S.’s name confidential, as required by Fed. R. Civ. P. 5.2. Further, public disclosure of 

Mark S.’s address and telephone number or A.S.’s TikTok usernames could also lead to the 

disclosure of A.S.’s identity or provide ways for A.S. to be contacted.

1 While Fed. R. Civ. P. 5.2 

allows the year of a birthdate to be disclosed in a public filing, it does not require it. See Fed. R. 

Civ. P. 5.2(a)(2) (public filing may include only the year of birth). 

6. Accordingly, for good cause shown, Mark S. respectfully requests leave to file the 

Objections under seal, nunc pro tunc to January 30, 2022.

WHEREFORE, Objector Mark S. respectfully moves the Court for leave to file the 

Objections under seal, nunc pro tunc to January 30, 20202.

Dated: February 1, 2022

Respectfully submitted,

MARK S., as parent and legal 

guardian of his minor son, A.S.,

By: /s/ Scott R. Drury

SCOTT R. DRURY

Counsel for Objector Mark S.

Mike Kanovitz

Scott R. Drury

LOEVY & LOEVY

311 N. Aberdeen, 3rd Floor

Chicago, Illinois 60607

(312) 243-5900

drury@loevy.com

1 Mark S. notes that Objector Dennis Littekin redacted similar information. See Dkt. 184 at 5. 

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CERTIFICATE OF SERVICE

I, Scott R. Drury, an attorney, hereby certify that, on February 1, 2022, I filed the foregoing 

document using the Court’s CM/ECF system, which effected service on all counsel of record.

/s/ Scott R. Drury

SCOTT R. DRURY

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