UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: TIKTOK, INC., CONSUMER 

PRIVACY LITIGATION

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MDL No. 2948-A

Master Docket No. 20 C 4699

Judge Rebecca R. Pallmeyer This Document Relates to:

Bravo v. TikTok, Inc. 

Murphy v. TikTok, Inc. 

Buckley v. TikTok, Inc. 

Tado v. TikTok, Inc.

Recht v. TikTok, Inc. 

Fleming v. TikTok, Inc. 

E.K. v. TikTok, Inc. 

Androshchuk v. TikTok, Inc.

Albaran v. TikTok, Inc.

G.R. v. TikTok, Inc.

Moody v. TikTok, Inc.

Schulte v. TikTok, Inc.

Fugok v. TikTok, Inc.

23 C 225

23 C 504

23 C 841

23 C 1430

23 C 2248

23 C 2260

23 C 2262

23 C 2462

23 C 2463

23 C 2464

23 C 2465

23 C 2466

23 C 2467

DECLARATION OF BRYAN P. THOMPSON IN SUPPORT OF MOTION TO

APPOINT INTERIM CO-LEAD COUNSEL

I, Bryan Paul Thompson, an attorney, being first duly sworn on oath, deposes and 

states as follows:

1. I am and have been one of the attorneys for Plaintiff Katie Murphy for the 

duration of the above captioned case.

2. I am admitted to practice within the State Courts of Illinois, the United 

States District Court for the Northern District of Illinois, both in the General Bar and the 

Trial Bar, the United States District Court for the Central District of Illinois, the United 

States District Court for the Southern District of Illinois, the United States District Court 

Case: 1:20-cv-04699 Document #: 319-11 Filed: 02/21/24 Page 1 of 4 PageID #:14254
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for the Southern District of Indiana, the 7th Circuit Court of Appeals, the United States Tax 

Court and the United States Court of International Trade.

3. I have practiced law since 2012, almost all of which was spent specializing in 

consumer protection litigation.

4. I am a 2008 graduate of the University of Illinois Urbana-Champaign and a 

2012 graduate of Northern Illinois University College of Law, graduating Magna Cum 

Laude. 

5. I currently practice exclusively in the area of consumer protection and data 

privacy law and have been primarily practicing consumer protection law since I was 

admitted to practice in 2012. I have significant experience handling cases under the Fair 

Debt Collection Practices Act, the Illinois Consumer Fraud Act, the Credit Repair 

Organizations Act, the Fair Credit Reporting Act, the Telephone Consumer Protection Act, 

the Magnuson-Moss Warranty Act and other areas of commercial and consumer litigation, 

both on an individual and class-wide basis.

6. I am, or have been, counsel or lead counsel in hundreds of consumer 

protection cases, primarily in Illinois. I have also served as counsel in class action cases 

that were certified pursuant to a class-wide settlement, including Wingate v. Resurgence 

Capital, LLC, No. 14-cv-7753 (N.D. Ill.), Szczesniak v. National Account Services, No. 14-cv10346 (N.D. Ill.), and Badillo v. Consumer Protection Legal Center, No. 2020-CH-2962 (Cook 

County. Cir. Ct.). 

7. I have additional experience outside consumer protection law, including both 

civil and criminal practice: USA v. Sam Fakhouri, No. 10-cr-401-3 (post-trial and appellate 

representation of defendant in white-collar criminal defense case involving allegations of 

financial crimes); Morado v. City of Chicago, No. 12-cv-752 (representation of individual 

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defendant in §1983 action); Morgan v. RCN Motors, No. 2013 L 532 (17th Judicial Circuit, 

DuPage County, Illinois) (state court action with judgment, after trial, for Plaintiff on 

breach of contract and Illinois Consumer Fraud Act claims).

8. I have been selected as a Super Lawyer “Rising Star” by Chicago Magazine 

every year since 2020.

9. I have additionally held leadership positions in legal and consumer law 

focused groups, including membership in the National Association of Consumer Advocates 

Ethics Committee and Judicial Committee, Chair of the Chicago Bar Association Consumer

Law Sub-Committee, Member of the Illinois State Bar Association Committee on the 

Delivery of Legal Services and the Illinois Bar Association Committee on Privacy and 

Information Security, and elected member of the Illinois State Bar Association Assembly.

10. I also frequently present continuing legal education seminars on consumer 

law topics to legal aid organizations and bar associations.

11. I am a Certified Information Privacy Professional (CIPP/US) and have been 

since 2020.

12. As part of the pre-filing investigation of Katie Murphy v. TikTok, Inc., I spent 

significant time and resources researching the reported data security and privacy issues, 

including reviewing numerous media articles and documents and other public information 

in this matter. I also discussed the matter at length with Ms. Murphy including the purpose 

of a class action and the responsibilities she would have if she chose to pursue this case. I

undertook legal research, reviewed information provided by Ms. Murphy, drafted the 

complaint and advanced the costs to file it and serve on Defendant. Since filing, I have 

spent time reviewing other cases that were filed, communicating with counsel for

Defendant, communicating with our client, and reviewing and drafting the Motion to 

Appoint Interim Class Counsel. 

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13. Our firm is able and willing to pursue this case in conjunction with the other 

firms involved in this action and we have the time and resources to pursue this case to class 

certification.

Pursuant to 28 U.S.C. § 1746(2), I, Bryan Paul Thompson, hereby declare under 

penalty of perjury that the foregoing is true and correct.

Dated: February 21, 2024

Respectfully submitted,

By: /s/ Bryan Paul Thompson

Bryan P. Thompson

Chicago Consumer Law Center, P.C.

650 Warrenville Road, Suite 100

Lisle, IL 60532

(312) 858-3239

bryan.thompson@cclc-law.com

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