EXHIBIT D

Case: 1:20-cv-04699 Document #: 122-4 Filed: 02/25/21 Page 1 of 13 PageID #:2096
Questions? Call SETTLEMENT INFO PHONE # or visit 

www.tiktokdataprivacysettlement.com

1

UNITED STATES DISTRICT COURT FOR 

THE NORTHERN DISTRICT OF ILLINOIS

If you and/or your minor child used the TikTok and/or 

Musical.ly application, You May Be Entitled to a 

Payment from a Class Action Settlement. 

If you live in Illinois and used the TikTok app in Illinois to create videos, you 

may be entitled to up to 6x the Payment. 

A federal court authorized this Notice. You are not being sued. This is not a solicitation from a lawyer.

• Plaintiffs filed a class action complaint alleging that TikTok, Inc. f/k/a Musical.ly, Inc; 

ByteDance, Inc.; Musical.ly n/k/a TikTok, Ltd. and Beijing ByteDance Technology Co. Ltd.

(collectively, the “Defendants”), violated federal and state law by collecting and using, without 

sufficient notice and consent, Plaintiffs’ personal data in connection with their use of the TikTok -

Make Your Day video-sharing application (and/or its predecessor app Musical.ly) distributed in 

the U.S. (the “App.”).

• Defendants deny these allegations and other material allegations in the operative complaint.

• The Settlement1 that has been reached in this case affects the following persons (collectively the 

“Settlement Class”):

Nationwide Class: All persons who reside in the United States who used the App prior 

to DATE of issuance of the Preliminary Approval Order.

Illinois Subclass: All persons who reside in the State of Illinois and used the App in the 

State of Illinois to create videos prior to DATE of issuance of the Preliminary Approval 

Order.

• The Settlement, if approved, would provide $92,000,000 to pay the members of the Settlement Class 

who file valid claims, as well as to pay Plaintiffs’ attorneys’ fees, costs, a service award for the 

named plaintiffs, and the administrative costs of the settlement. It would also provide injunctive 

relief to protect App users’ information. The Settlement avoids the further cost and risk associated 

with continuing the lawsuits; it pays money to those persons whose rights Plaintiffs contend were 

violated; and it releases Defendants from further liability. 

• You may submit a claim on your own behalf or on behalf of your minor child.

• Your legal rights are affected whether you act or don't act. Read this notice carefully. 

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT

1 Capitalized terms herein have the same meanings as those defined in the Settlement Agreement, a copy 

of which may be found online at the Settlement Website below.

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SUBMIT A 

CLAIM FORM

If you are a member of the Settlement Class, you must submit a completed 

Claim Form to receive a payment. If the Court approves the Settlement 

and it becomes final and effective, and you remain in the Settlement Class,

you will receive your payment by electronic means (unless you opt for an

alternative form of payment). Deadline: DATE

EXCLUDE 

YOURSELF

You may request to be excluded from the Settlement and, if you do, you 

will receive no benefits from the Settlement. 

Deadline: DATE

OBJECT Write to the Court if you do not like the Settlement.

Deadline: DATE

GO TO A HEARING Ask to speak in Court about the fairness of the Settlement.

DO NOTHING You will not receive a payment if you fail to timely submit a completed 

Claim Form, and you will give up your right to bring your own lawsuit 

against Defendants about the Claims in this case.

• These rights and options - and the deadlines to exercise them - are explained in this Notice.

• The Court in charge of this case still has to decide whether to approve the Settlement. If it

does, and after any appeals are resolved, benefits will be distributed to those who submit

qualifying Claim Forms. Please be patient.

WHAT THIS NOTICE CONTAINS

BASIC INFORMATION....................................................................................................................PAGE 4

1. Why is there a Notice?

2. What is this litigation about?

3. Why is this a class action?

4. Why is there a settlement?

WHO IS PART OF THE SETTLEMENT.............................................................................................PAGE 5

5. Who is included in the Settlement?

6. What if I am not sure whether I am included in the Settlement?

THE SETTLEMENT BENEFITS........................................................................................................PAGE 5

7. What does the Settlement provide?

8. How do I file a Claim?

9. When will I receive my payment?

EXCLUDING YOURSELF FROM THE SETTLEMENT.......................................................................PAGE 6

10. How do I get out of the Settlement?

11. If I do not exclude myself, can I sue Defendants for the same thing later?

12. What am I giving up to stay in the Settlement Class?

13. If I exclude myself, can I still get a payment?

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THE LAWYERS REPRESENTING YOU............................................................................................PAGE 7

14. Do I have a lawyer in the case?

15. How will the lawyers be paid?

OBJECTING TO THE SETTLEMENT.................................................................................................PAGE 7

16. How do I tell the Court I do not like the Settlement?

17. What is the difference between objecting and asking to be excluded?

THE FINAL APPROVAL HEARING...................................................................................................PAGE 8

18. When and where will the Court decide whether to approve the Settlement?

19. Do I have to attend the hearing?

20. May I speak at the hearing?

IF YOU DO NOTHING.......................................................................................................................PAGE 9

21. What happens if I do nothing at all?

GETTING MORE INFORMATION.....................................................................................................PAGE 9

22. How do I get more information?

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BASIC INFORMATION

A court authorized this Notice because you have a right to know about a proposed Settlement of the 

class action lawsuit known as In Re: TikTok, Inc., Consumer Privacy Litigation, MDL No. 2948, 20-

cv-4699 (N.D. Ill.) (the “Action”) and about all of your options before the Court decides whether to

give Final Approval to the Settlement. This Notice explains the lawsuit, the Settlement, and your legal 

rights.

The United States District Court for the Northern District of Illinois is overseeing this case. The persons

who sued are called the “Plaintiffs.” TikTok, Inc. f/k/a Musical.ly, Inc; ByteDance, Inc.; Musical.ly n/k/a 

TikTok, Ltd. and Beijing ByteDance Technology Co. Ltd. are called the “Defendants.”

The lawsuit alleges that Defendants collected and used, without sufficient notice and consent, Plaintiffs’ 

personal data in connection with Plaintiffs’ use of the App. 

Defendants deny every allegation of wrongdoing, liability, and damages that were or could have been 

asserted in the litigation and that the claims in the litigation would be appropriate for class treatment if 

the litigation were to proceed through trial.

The Plaintiffs’ Complaint, Settlement Agreement, and other case-related documents are posted on the 

Settlement Website, www.tiktokdataprivacysettlement.com. The Settlement resolves the lawsuit. The

Court has not decided who is right.

In a class action, the person called the “Class Representative” (in this case, Plaintiffs) sues on behalf of

herself and other people with similar claims. 

All the people who have claims similar to the Plaintiffs’ are Settlement Class Members, except for those 

who exclude themselves from the class.

The Court has not found in favor of either Plaintiffs or Defendants. Instead, both sides have agreed to 

a settlement. By agreeing to the Settlement, the parties avoid the costs and uncertainty of a trial, and 

if the Settlement is approved by the Court, Settlement Class Claimants will receive the benefits 

described in this Notice. Defendants deny all legal claims in this case. Plaintiffs and their lawyers think 

the proposed Settlement is best for everyone who is affected.

1. Why is there a Notice?

2. What is this litigation about?

3. Why is this a class action?

4. Why is there a settlement?

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WHO IS PART OF THE SETTLEMENT

The Settlement Class includes the following persons:

Nationwide Class: All persons who reside in the United States who used the App prior 

to DATE of issuance of the Preliminary Approval Order.

Illinois Subclass: All persons who reside in the State of Illinois and used the App in the 

State of Illinois to create videos prior to DATE of issuance of the Preliminary Approval 

Order.

If you do not reside in the United States and did not use the App prior to DATE of issuance of the 

Preliminary Approval Order, you are not a part of the Settlement Class and may not submit a claim to 

receive benefits under the Settlement. Also excluded from the Settlement Class are: (i) TikTok, its 

parent, subsidiaries, successors, affiliates, officers, and directors; (ii) the judge(s) to whom the Civil 

Actions are assigned and any member of the judge’s or judges’ immediate family; (iii) persons who 

have settled with and released TikTok from individual claims substantially similar to those alleged in 

the Civil Actions; (iv) persons who submit a valid and timely Request for Exclusion; and (v) all Class 

Counsel and counsel of record in the Civil Actions.

If you are not sure whether you are in the Settlement Class or have any other questions about the 

Settlement, visit the Settlement Website at www.tiktokdataprivacysettlement.com or call the toll-free 

number, SETTLEMENT PHONE #. You also may send questions to the Settlement Administrator

at info@email address.

THE SETTLEMENT BENEFITS

To fully settle and release claims of the Settlement Class Members, Defendants have agreed to establish 

a $92 million fund (the “Settlement Fund”) to (i) make payments to the Settlement Class Members and 

(ii) pay for notice and administration costs of the Settlement, attorneys’ fees and expenses incurred by 

counsel for the Settlement Class, and service awards for Plaintiffs. Each Settlement Class member who 

timely files with the Settlement Administrator a valid Claim Form will receive a settlement payment of

a pro rata share of the Settlement Fund. 

If you are an Illinois resident and used the App in Illinois to create videos, you may be entitled to a 

payment up to 6 times that of non-Illinois residents due to certain claims in the lawsuit that are specific 

to Illinois residents. 

If you qualify for a payment, you must complete and submit a valid Claim Form. You may download a 

Claim Form at the Settlement Website, www.tiktokdataprivacysettlement.com, or request a Claim Form 

5. Who is included in the Settlement?

6. What if I am not sure whether I am included in the Settlement?

7. What does the Settlement provide?

8. How do I file a Claim?

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by calling the Settlement Administrator at the toll-free number below. To be valid, a Claim Form must 

be completed fully and accurately, signed under penalty of perjury, and timely submitted.

You may submit a Claim Form by U.S. mail or file a Claim Form online. If you send in a Claim Form 

by U.S. mail, it must be postmarked by DATE. If you file a Claim Form online, then you must do so 

by 11:59 p.m. EST on DATE.

No matter which method you choose to file your Claim Form, please read the Claim Form carefully and 

provide all the information required. Only one Claim Form may be submitted per Settlement Class 

Member. You should not submit a Claim Form if you do not qualify for a payment.

 

Payments to Settlement Class Members will be made only after the Court grants Final Approval to the

Settlement and after any appeals are resolved (see “Final Approval Hearing” below). Ifthere are appeals,

resolving them can take time. Please be patient.

EXCLUDING YOURSELF FROM THE SETTLEMENT

If you do not want benefits from the Settlement, and you want to keep the right to sue or continue to 

sue Defendants on your own about the legal issues in this case, then you must take steps to get out of 

the Settlement. This is called excluding yourself—or it is sometimes referred to as “opting out” of the 

Settlement Class.

To exclude yourself from the Settlement, you must send a timely letter by mail to:

Musical.ly and/or TikTok Class Action

Attn: Exclusion Request

P.O. Box 58220

Philadelphia, Pennsylvania 19102

Your request to be excluded from the Settlement must include: (i) the name of the Action; (ii) your full 

name, address, email address and telephone number; (iii) a specific statement of your intention to be 

excluded from the Settlement; (iv) the identity of your counsel, if represented; and (v) your signature 

and the date on which the request was signed.

Your exclusion request must be postmarked no later than DAY AND DATE. You cannot ask to be 

excluded on the phone, by email, or at the Settlement Website.

You may opt out of the Settlement Class only for yourself or your minor child.

No. Unless you exclude yourself, you give up the right to sue Defendants for the claims that the 

Settlement resolves. You must exclude yourself from this Settlement Class in order to pursue your own 

lawsuit.

9. When will I receive my payment?

10. How do I get out of the Settlement?

11. If I do not exclude myself, can I sue Defendants for the same thing later?

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Unless you opt out of the Settlement, you cannot sue or be part of any other lawsuit against Defendants

about the issues in this case, including any existing litigation, arbitration, or proceeding. Unless you

exclude yourself, all of the decisions and judgments by the Court will bind you.

The Settlement Agreement is available at www.tiktokdataprivacysettlement.com. The Settlement 

Agreement provides more detail regarding the Releases and describes the Released Claims with specific 

descriptions in necessary, accurate legal terminology, so read it carefully. You can talk to the law firms

representing the Settlement Class listed in Question 14 for free, or you can, at your own expense, talk to

your own lawyer if you have any questions about the Released Claims or what they mean.

No. You will not get a payment from the Settlement Fund if you exclude yourself from the Settlement.

THE LAWYERS REPRESENTING YOU

The Court has appointed the following lawyers as “Class Counsel” to represent all members of the

Settlement Class.

Katrina Carroll Elizabeth A. Fegan Ekwan E. Rhow

Carlson Lynch, LLP Fegan Scott LLC Bird, Marella, Boxer, Wolpert, Nessim,

111 W. Washington Street 150 South Wacker Drive Drooks, Lincenberg & Rhow, P.C.

Suite 1240 24th Floor 1875 Century Park East

Chicago, IL 60602 Chicago, IL 60606 23rd Floor

(312) 750-1265 (312) 741-1019 Los Angeles, CA 90067

(310) 201-2100

You will not be charged for these lawyers. If you want to be represented by another lawyer, you may 

hire one to appear in Court for you at your own expense.

The Settlement Agreement does not provide for a specific amount to be paid to the lawyers who filed 

the lawsuit but does allow the Court to award reasonable attorneys’ fees and costs incurred on behalf 

of the Class to be paid from the Settlement Fund. Class Counsel intends to request up to 33.33% of the 

Settlement Fund for attorneys’ fees and reimbursement of reasonable, actual out-of-pocket expenses

incurred in the litigation. The Court will decide the amount of fees and expenses to award.

Class Counsel will also request that Service Awards of $2,500.00 be paid to each of the Class

Representatives for their services as representatives on behalf of the SettlementClass.

OBJECTING TO THE SETTLEMENT

12. What am I giving up to stay in the Settlement Class?

13. If I exclude myself, can I still get a payment?

14. Do I have a lawyer in the case?

15. How will the lawyers be paid?

16. How do I tell the Court if I do not like the Settlement?

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If you are a Settlement Class Member (and do not exclude yourself from the Settlement Class), you can

object to any part of the Settlement. To object, you must by no later than DAY, DATE, send to the 

Settlement Administrator, Class Counsel, and Defendants’ counsel, and file with the Court, a written 

statement of the objection(s). The written statement of the objection(s) must include: (i) the name of the 

Action and a description of the objection(s), including any evidence and applicable legal authority and 

any supporting evidence you wish to introduce; (ii) your full name, address, email address, telephone 

number, mobile telephone number(s) for your device(s) used to access the App, and any and all TikTok 

usernames used; (iii) whether the objection applies only to you, a specific subset of the Settlement 

Class, or the entire Settlement Class; (iv) the identity of all counsel who represent you, including former 

or current counsel who may be entitled to compensation for any reason related to the objection, along 

with a statement of the number of times in which that counsel has objected to a class action settlement 

within five years preceding the submission of the objection, the caption of the case for each prior 

objection, and a copy of any relevant orders addressing the objection; (v) all agreements that relate to 

the objection or the process of objecting, between you or your counsel and any other person or entity; 

(vi) your (and your attorney’s) signature on the written objection; and (vii) a declaration under penalty 

of perjury that the information provided by you and your counsel is true and correct.

Court Class Counsel Defendants’ Counsel Settlement Administrator

United States 

District Court for 

the Northern 

District of Illinois, 

Eastern Division, 

Everett McKinley 

Dirksen United 

States Courthouse, 

219 South Dearborn 

Street, Chicago, IL 

60604

Katrina Carroll

Carlson Lynch, LLP,

111 W. Washington 

Street,

Suite 1240,

Chicago, IL 60602

Elizabeth A. Fegan

Fegan Scott LLC,

150 South Wacker 

Drive,

24th Floor,

Chicago, IL 60606

Ekwan E. Rhow

Bird, Marella, Boxer, 

Wolpert, Nessim, 

Drooks, Lincenberg & 

Rhow, P.C.,

1875 Century Park 

East, 23rd Floor,

Los Angeles, CA 

90067

Anthony J Weibell

Wilson Sonsini Goodrich 

& Rosati,

650 Page Mill Road,

Palo Alto, CA 94304

Musical.ly and/or TikTok Class 

Action

Attn: Objections

P.O. Box 58220

Philadelphia, PA 19102

Objecting is telling the Court that you do not like something about the Settlement. You can object to 

the Settlement only if you do not exclude yourself. Excluding yourself is telling the Court that you do 

not want to be part of the Settlement. If you exclude yourself, you have no basis to object to the 

Settlement because it no longer affects you.

THE FINAL APPROVAL HEARING

17. What is the difference between objecting and asking to be excluded?

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The Court will hold a hearing to decide whether to approve the Settlement and any requests for fees 

and expenses (“Final Approval Hearing”).

The Court has scheduled a Final Approval Hearing on DAY, DATE at TIME at the United States 

District Court for the Northern District of Illinois, Eastern Division, Everett McKinley Dirksen United 

States Courthouse, 219 South Dearborn Street, Chicago, IL 60604. The hearing may be moved to a 

different date or time without additional notice, so it is a good idea to check 

www.tiktokdataprivacysettlement.com for updates. At this hearing, the Court will consider whether the 

Settlement is fair, reasonable, and adequate. The Court will also consider the requests by Class Counsel 

for attorneys’ fees and expenses and for a Service Award to the Class Representatives. If there are 

objections, the Court will consider them at that time. After the hearing, the Court will decide whether 

to approve the Settlement. It is unknown how long these decisions will take.

No. Class Counsel will answer any questions the Court may have. But you are welcome to attend the 

hearing at your own expense. If you send an objection, you do not have to come to Court to talk about 

it. As long as you submitted your written objection on time and it complies with all the other 

requirements set forth above, the Court will consider it. You may also pay your own lawyer to attend 

the hearing, but it is not necessary.

You may ask the Court for permission to speak at the Final Approval Hearing. You cannot speak at the 

hearing if you exclude yourself from the Settlement.

IF YOU DO NOTHING

If you are a Settlement Class member and do nothing, meaning you do not file a timely Claim, you will 

not get benefits from the Settlement. Further, unless you exclude yourself, you will be bound by the

judgment entered by the Court.

GETTING MORE INFORMATION

This Notice summarizes the proposed Settlement. You are urged to review more details in the

Settlement Agreement. For a complete, definitive statement of the Settlement terms, refer to the 

Settlement Agreement at www.tiktokdataprivacysettlement.com. You also may write with questions to

the Settlement Administrator at EMAIL ADDRESS or call the toll-free number, PHONE #

18. When and where will the Court decide whether to approve the Settlement?

19. Do I have to attend the hearing?

20. May I speak at the hearing?

21. What happens if I do nothing at all?

22. How do I get more information?

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UNITED STATES DISTRICT COURT FOR 

THE NORTHERN DISTRICT OF ILLINOIS

If you and/or your minor child used the TikTok 

and/or Musical.ly application, You May Be 

Entitled to a Payment from a Class Action 

Settlement. 

If you live in Illinois and used the TikTok app in Illinois to create

videos, you may be entitled to up to 6x the Payment. 

A federal court authorized this Notice. You are not being sued. This is not a solicitation from a 

lawyer.

A Class Action Settlement has been proposed in a case against TikTok, Inc. f/k/a Musical.ly, Inc; 

ByteDance, Inc.; Musical.ly n/k/a TikTok, Ltd. and Beijing ByteDance Technology Co. Ltd. 

(collectively, the “Defendants”). Plaintiffs alleged that Defendants violated laws by improperly 

collecting and using the personal data of people who used the TikTok - Make Your Day videosharing application (and/or its predecessor application, Musical.ly) (the “App.”).

Am I included?

You are a Settlement Class Member if you reside in the United States and used the App prior to 

DATE of issuance of the Preliminary Approval Order. You are also a member of an Illinois 

subclass if you reside in Illinois and used the App in Illinois to create videos prior to DATE of 

issuance of the Preliminary Approval Order (collectively the “Settlement Class”).

What does the Settlement provide?

The Settlement, if approved, would provide $92,000,000 to pay the members of the Settlement 

Class who file valid claims, as well as to pay Plaintiffs’ attorneys’ fees, costs, a service award for 

the named plaintiffs, and the administrative costs of the settlement. It avoids the further cost and 

risk associated with continuing the lawsuits; it pays money to those persons whose rights Plaintiffs 

contend were violated; and it releases Defendants from further liability.

If you are an Illinois resident and used the App in Illinois to create videos, you may be entitled to 

a payment up to 6 times that of non-Illinois residents due to certain claims in the lawsuit that are 

specific to Illinois residents.

For complete information, dates, and details on the benefits, visit the settlement website at 

www.tiktokdataprivacysettlement.com, or call 1-XXX-XXX-XXXX.

What are my options?

If you and/or your minor child qualify for a payment, you must complete and submit a valid Claim 

Form. You may download a Claim Form at the Settlement Website, 

www.tiktokdataprivacysettlement.com or request a Claim Form by calling the Settlement 

Administrator at 1-XXX-XXX-XXXX. 

To be valid, a Claim Form must be completed fully and accurately, signed under penalty of perjury, 

and timely submitted. You may submit a Claim Form by U.S. mail or file a Claim Form online. If 

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you send in a Claim Form by U.S. mail, it must be postmarked by DATE. If you file a Claim Form 

online, then you must do so by 11:59 p.m. EST on DATE.

If you and/or your minor child wish to be excluded from the Settlement Class, you must mail your 

exclusion request so it is postmarked no later than DATE. If you do not exclude yourself from the 

Settlement class, you may object to the Settlement by submitting a written objection by DATE. 

For specific information on how to submit a written exclusion request or objection, and the 

requirements for each, please visit www.tiktokdataprivacysettlement.com. 

Do I have a lawyer in the case?

The Court has appointed the following lawyers as “Class Counsel” to represent all members of the 

Settlement Class: Katrina Carroll, Carlson Lynch LLP; Elizabeth A. Fegan, Fegan Scott LLC; and 

Ekwan E. Rhow, Bird, Marella, Boxer, Wolpert, Nessim, Drooks, Lincenberg & Rhow, P.C. You 

will not be charged for these lawyers. If you want to be represented by another lawyer, you may 

hire one to appear in Court for you at your own expense. Class Counsel intends to request up to 

33.33% of the Settlement Fund for attorneys’ fees and reimbursement of reasonable, actual outof-pocket expenses incurred in the litigation. The Court will decide the amount of fees and 

expenses to award. Class Counsel will also request that a Service Award of $2,500.00 be paid to

each of the Class Representatives for their services as representatives of the Settlement Class.

The Court’s Fairness Hearing

The Court has scheduled a Final Approval Hearing on DAY, DATE at TIME at the United States 

District Court for the Northern District of Illinois, Eastern Division, Everett McKinley Dirksen 

United States Courthouse, 219 South Dearborn Street, Chicago, IL 60604. The hearing may be 

moved to a different date or time without additional notice, so it is a good idea to check 

www.tiktokdataprivacysettlement.com for updates. You do not need to attend this hearing to 

qualify for a settlement payment. 

At this hearing, the Court will consider whether the Settlement is fair, reasonable, and adequate. 

The Court will also consider the requests by Class Counsel for attorneys’ fees and expenses and 

for a Service Award to the Class Representatives. If there are objections, the Court will consider 

them at that time. After the hearing, the Court will decide whether to approve the Settlement. It is 

unknown how long these decisions will take.

THIS NOTICE IS ONLY A SUMMARY. THE FULL NOTICE AND THE SETTLEMENT 

AGREEMENT ARE AVAILABLE AT 

WWW.TIKTOKDATAPRIVACYSETTLEMENT.COM.

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