EXHIBIT C

Case: 1:20-cv-04699 Document #: 122-3 Filed: 02/25/21 Page 1 of 4 PageID #:2092
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PLAN OF ALLOCATION AND DISTRIBUTION OF SETTLEMENT FUNDS

Pursuant to Section 5.2 of the Settlement Agreement, the Settlement Fund shall be 

distributed according to the following preferential order:

First, payment of all expenses incurred by the Settlement Administrator for the

Notice Plan and settlement administration;

Second, payment of any taxes associated with the Settlement Fund;

Third, payment of any Fee Award plus any interest or income earned on the Fee

Award portion of the Settlement Fund and Incentive Awards within 14 days of

the Effective Date;

Fourth, payment of the remaining unallocated portion of the Settlement Fund to Class

Members in accordance with the Final Approval Order or any subsequent

order of the Court within 14 days of the Effective Date; and

Last, payment of any residue of the Settlement Fund as set forth in the Settlement 

Agreement, subject to a reduction for any associated administrative costs.

The net settlement funds, i.e., the total settlement funds, less all taxes, class notice and

claim administration expenses, any Court-approved service awards for the named plaintiffs, and 

attorneys’ fees and costs awarded by the Court to Class Counsel (“Net Settlement Funds”), will 

be distributed to qualifying claimants who are members of the Nationwide Class or Illinois 

Subclass, who submit timely and valid Claim Forms and whose Claims are approved by the 

Claims Administrator (“Authorized Claimants”).

Timing of the Distribution

The distribution of Net Settlement Funds to Authorized Claimants will take place after 

the following: (1) final approval of the settlement by the Court and/or final judgment, and the

expiration of any period for further review or appeal of the Court’s orders of approval and/orfinal

judgments or the resolution of any such review or appeal; (2) receipt of Claim Forms by the 

Claims Administrator; and (3) review of the Claim Forms by the Claims Administrator and the 

determination of the amounts to be paid to Authorized Claimants.

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Determination of Authorized Claimants

Distribution of the Net Settlement Funds will be based on Authorized Claimants’ use of 

the TikTok application (and/or its predecessor application, Musical.ly) and Authorized 

Claimants’ place of residence. Persons who used the TikTok application can submit a claim

providing the information specified in the Claim Form. The Claims Administrator will use the 

information you provide in your Claim Form to determine whether you are a member of one of 

the classes.

Allocation of Net Settlement Funds

The Net Settlement Funds will be divided into pro rata shares that are equal to the sum 

of (1) the total number of valid claims submitted by Nationwide Class members (including

Illinois Subclass members) and (2) the total number of valid claims submitted by Illinois 

Subclass members multiplied by five.

Net Settlement Funds = Value of 1

(Nationwide Valid Claims) + (Illinois Valid Claims * 5) Pro Rata Share

Each Authorized Claimant who is a member of the Illinois Subclass shall be paid six pro 

rata shares, one as a member of the Nationwide Class and five as a member of the Illinois 

Subclass. Each Authorized Claimant who is a member of the Nationwide Class and is not a 

member of the Illinois Subclass shall be paid one pro rata share.

Additional Information about Submitting a Claim

Please note that submission of a Claim Form does not necessarily assure the right to

payment out of the Net Settlement Funds. The Claims Administrator may deny, in whole or in 

part, any claim if it determines that the claimant is excluded from the definition of the settlement 

classes or if there are legal or equitable grounds for the rejection of such claim.

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Payment pursuant to the Plan of Allocation shall be conclusive against all Authorized

Claimants. No person shall have any claim against Class Counsel, the Settling Parties, the

Claims Administrator, or any other person designated by Class Counsel based on distributions

made substantially in accordance with the Plan of Allocation or further orders of the Court.

All Class Members who fail to complete and submit a valid and timely Claim Form shall

be barred from participating in distributions from the Net Settlement Funds (unless otherwise

ordered by the Court), but otherwise shall be bound by all of the terms of the settlement, including

the terms of the judgments entered and the releases given pursuant to the settlement.

The deadline for the submission of Claim Forms is DATE. You should check the

settlement website for updated information regarding the submission of Claim Forms. Please 

note that the Court may modify the Plan of Allocation without further notice to the class. Any

such modifications will be described in subsequent postings on the settlement website.

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