UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: TIKTOK, INC., )

CONSUMER PRIVACY ) MDL No. 2948

LITIGATION, )

) Master Docket No. 20 C 4699

)

) Judge John Z. Lee

)

) Magistrate Judge Sunil R. Harjani

This Document Relates to All Cases )

APPLICATION BY SHANNON M. MCNULTY 

FOR APPOINTMENT AS LIAISON COUNSEL AND IN SUPPORT OF THE 

LEADERSHIP APPLICATION BY THE LITIGATING PLAINTIFFS (EKWAN RHOW 

AND MEGAN JONES FOR CO-LEAD COUNSEL, KARA WOLKE, DAVID GIVEN,

AND AMANDA KLEVORN FOR THE PLAINTIFFS’ STEERING COMMITTEE)

Consistent with this Court’s Order [ECF No. 4], Shannon M. McNulty respectfully submits 

application for appointment as liaison counsel. In coordination with respected counsel for the 

Litigating Plaintiffs [See ECF No. 40], the undersigned has been proposed to serve as Liaison 

Counsel. Ms. McNulty supports the leadership plan proposed by the Litigating Plaintiffs’ and 

incorporates the Plan by reference, as if fully stated, herein. As proposed, the Plan [ECF No. 40] 

fairly, competently, and comprehensively advances, and protects, the interests of the putative class 

and their counsel. The Plan fully adheres to the Court’s case management orders. 

I. INTRODUCTION

As set forth below, the undersigned respectfully submits for appointment as liaison 

counsel, and further suggests that Ms. McNulty possesses the experience and disposition to satisfy 

the demands of this litigation and the qualifications provided by Court.

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The Manual for Complex Litigation (4th) establishes the function of liaison counsel, 

stating, in pertinent part: 

Liaison counsel. Charged with essentially administrative matters, such as 

communications between the court and other counsel (including receiving and 

distributing notices, orders, motions, and briefs on behalf of the group), convening 

meetings of counsel, advising parties of developments, and otherwise assisting in 

the coordination of activities and positions. Such counsel may act for the group in 

managing document depositories and in resolving scheduling conflicts. Liaison 

counsel will usually have offices in the same locality as the court. 

Ms. McNulty is confident she can manage the administrative matters associated with this 

litigation, and further notes her familiarity with this Court’s local rules and the more general 

practical aspects of managing litigation in the Northern District of Illinois, where Ms. McNulty is 

based. Whenever necessary, Ms. McNulty can convene and host meetings, including in-person 

when necessary1, manage document repositories, and coordinate scheduling. Ms. McNulty can 

best satisfy the Court’s criteria for liaison counsel. 

II. SATISFACTION OF CRITERIA

A. Shannon M. McNulty Is Willing and Able To Commit To This Case.

The undersigned stands ready to serve as liaison counsel. Litigation that involves global 

entities; counsel and clients across the full spectrum of time zones; additional time-sensitivities; 

and factual and legal complexities, demands the rigor, commitment and resources for which 

Clifford Law Offices is known. This Court is aware of the quality of work in matters pending in 

this District for which Ms. McNulty and her firm, Clifford Law Offices, P.C., have served as lead 

or liaison counsel. Ms. McNulty and her firm are committed to this litigation and its success. As 

1 Clifford Law Offices retained an infectious disease expert to assist in developing workspaces that made returning to work 

safer for employees and visitors to our office. Clifford Law Offices uses touchless thermal temperature scans upon egress 

from each elevator; new plexiglass partitions between workspaces; very frequent, full-time, disinfecting of high-touch 

surfaces; complimentary masks; touchless sanitizer throughout; spacing prompts and reminders; increased remote work 

resources; rotating staff assignments to reduce in-person capacity; and, an outdoor meeting space. If or when an in-person 

meeting becomes necessary, Clifford Law Offices can safely and securely host such a meeting, and has adequate space to 

safely accommodate an executive committee and/or opposing counsel. 

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set forth in the supporting Declaration of Shannon M. McNulty (Exhibit A), Ms. McNulty has the 

skill and experience to serve as liaison counsel. Further, Clifford Law Offices has more than 

adequate capital and personnel resources to vigorously prosecute this action, and to assist lead 

counsel, the plaintiffs’ steering committee, and this court, in whatever way suits the needs of the 

case and the class. 

B. Shannon M. McNulty Works Cooperatively With Others.

Consistent with her reputation, Ms. McNulty will work cooperatively with all plaintiff’s 

counsel and maintain the highest level of civility and candor with all counsel and the court. Ms. 

McNulty and her firm routinely engage in matters of great complexity and adversity. Irrespective 

of how adversarial any particular issue(s) may become in a case, Ms. McNulty and her firm are 

well-known for promoting civility, maintaining professionalism and making room for all who wish 

to prepare a case for the benefit of the client, the court and, ultimately, a jury. Moreover, Ms. 

McNulty is frequently requested, including by many of the plaintiff’s counsel before the Court in 

this matter, to join litigation initiated in and/or transferred to this District. The regular offers to 

collaborate are an endorsement of the reputation of Clifford Law Offices and Ms. McNulty, for 

whom civility, professionalism, and trial preparedness remain core values. 

C. Shannon M. McNulty Has the Skill and Requisite Experience to Serve As Liaison 

Counsel In This Matter. 

Ms. McNulty has successfully litigated cases against defendants located in China, Japan, 

Germany, Mexico, Canada. Ms. McNulty understands the work-up of a case involving foreign 

entities, including for third-party discovery or preservation, because her firm routinely litigates

cases involving complicated issues and significant damages against defendants from a variety of 

foreign countries. Presently, the firm has cases with global defendants and has been retained by 

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clients from countries outside of the U.S., including several from China. Clifford Law Offices is 

careful to consider cultural norms and distinctions (including for discovery and preservation) that 

facilitate the advancement of a case to trial. 

Moreover, Ms. McNulty has served in a variety of leadership positions in consolidated 

matters, including many in this District. (See, Exhibit A, Declaration). Ms. McNulty has 

experience in data breach and data security cases, and appreciates the nuances concerning the data 

security at issue in this case. (Exhibit A). Ms. McNulty has never been sanctioned; nor has she 

been the subject of any complaint of alleged wrongdoing. 

III. CONCLUSION

For these reasons, the undersigned respectfully requests that the Court appoint the 

undersigned Liaison Counsel.

 Respectfully submitted,

DATED: September 8, 2020 CLIFFORD LAW OFFICES, P.C. 

/s/ Shannon M. McNulty

Shannon M. McNulty

Kristofer S. Riddle

CLIFFORD LAW OFFICES, P.C.

120 N. LaSalle Street, 31st Floor

Chicago, Illinois 60602

312.899.9090

SMM@cliffordlaw.com

KSR@cliffordlaw.com

Attorneys for Plaintiffs Cherise Slate, on behalf of 

minor P.S.; Brenda Washington, on behalf of minor 

M.W.; Gilda Avila, on behalf of minor A.R.; Meghan 

Smith; Mikhaila Woodall, on behalf of minors C.W 

and I.W., Misty Hong; Laurel Slothwer, on behalf of 

minor A.S.; Lynn Pavalon, on behalf of minor R.P.

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CERTIFICATE OF SERVICE 

I, Shannon M. McNulty, an attorney, hereby certify that on September 8, 2020, I served 

the above and foregoing, by causing a true and accurate copy of such papers to be filed and served 

on all counsel of record via the Court’s CM/ECF electronic filing system. 

/s/ Shannon M. McNulty

Shannon M. McNulty 

CLIFFORD LAW OFFICES, P.C.

120 N. LaSalle Street, Suite 3100

Chicago, IL 60602

(312) 899-9090

SMM@cliffordlaw.com

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