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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: TIKTOK, INC.,

CONSUMER PRIVACY

LITIGATION,

This Document Relates to All Cases

MDL No. 2948

Master Docket No. 20-cv-4699 

Judge John Z. Lee

Magistrate Judge Sunil R. Harjani 

NOTICE IN SUPPORT OF MOTION TO APPOINT KATRINA CARROLL AND 

JONATHAN M. JAGHER AS CO-LEAD COUNSEL AND TO APPOINT THEIR 

PROPOSED PLAINTIFFS’ LIAISON COUNSEL AND PLAINTIFFS’ STEERING 

COMMITTEE

Plaintiff L.M., a minor, by and through Guardian S.M.., respectfully supports the 

appointment of Katrina Carroll of Carlson Lynch, LLP (“Ms. Carroll”) and Jonathan M. Jagher, 

Esq. of Freed Kanner London & Millen LLC (“Mr. Jagher”) as Co-Lead Counsel (“Proposed CoLead Counsel”), Beth Fegan of Fegan Scott LLC as Plaintiffs’ Liaison Counsel, and Robert M. 

Foote of Foote, Mielke, Chavez & O’Neil, LLC, James B. Zouras of Stephan Zouras, LLP, Michael 

Gervais of Susman Godfrey L.L.P., Tina Wolfson of Ahdoot & Wolfson, P.C., and Joseph P. 

Guglielmo of Scott+Scott Attorneys at Law LLP, for the Plaintiffs’ Steering Committee (“PSC”). 

Proposed Co-Lead Counsel are well-qualified to represent the proposed class under the 

criteria established for selection of lead counsel by Fed. R. Civ. P. 23(g)(1)(A) and the factors 

highlighted by this Court. 

First, Proposed Co-Lead Counsel have demonstrated expertise in successfully managing 

complex MDL litigation, have incredible experience and expertise litigating complex class action 

cases generally - and particularly in cases under privacy law and/or Illinois Biometric Information 

Privacy Act (“BIPA”), 740 ILCS/14 – and have represented that they are willing and available to 

commit time and financial resources to this important project.

Second, and importantly, to date, in this case, Katrina Carroll and Jonathan M. Jagher have 

Case: 1:20-cv-04699 Document #: 53 Filed: 09/08/20 Page 1 of 3 PageID #:1111
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been beyond cooperative, inviting the other class action attorneys, including undersigned counsel,

to coordinate in an organized fashion. From the minute the mediation opportunity presented itself, 

Proposed Co-Lead Counsel swiftly and efficiently worked to put together a formidable team of

experienced class action attorneys, so that the unique opportunity to resolve the case did not elude 

the class members. 

Third, Katrina Carroll and Jonathan M. Jagher have devoted a significant amount of time 

already to this case and have indicated they are willing and able to devote nearly all of their time 

to this case in the future. The additional members of the leadership structure are also willing and 

available to commit to this project, and have participated meaningfully to date.

Fourth, this team went on to achieve a settlement in principal, and now Katrina Carroll and 

Jonathon M. Jagher should be appointed Co-Lead Counsel to bring the settlement in principal to 

final approval. Should the settlement in principal not proceed to preliminary and/or final approval, 

Proposed Co-Lead Counsel and their team, as indicated above, are well-suited to litigate this case

to judgment.

For the foregoing reasons, Plaintiff L.M. a minor, by and through Guardian S.M..,

respectfully supports the appointment of Ms. Carroll and Mr. Jagher as Proposed Co-Lead Counsel 

and their proposed PSC and Liaison Counsel pursuant to Rule 23(g).

Date: 9/8/2020 By: /s/ James G. Onder

James G. Onder #06200444 

ONDERLAW, LLC 

110 E. Lockwood Ave, 2nd Floor 

St. Louis, MO 63119 

Toll Free: 866.828.4699 

Office: 314.963.9000 

Fax: 314.963-1700 

Email: Onder@onderlaw.com

ATTORNEYS FOR PLAINTIFF IN L.M.

V. TIKTOK, INC.

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CERTIFICATE OF SERVICE

I, James G. Onder, hereby certify that on September 8, 2020, I caused the foregoing to be 

filed using the Court’s CM/ECF system, and thereby electronically served it upon all registered 

ECF users in this case.

By: /s/ James G. Onder

JAMES G. ONDER

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