EXHIBIT 15 

Case: 1:20-cv-04699 Document #: 11-16 Filed: 08/27/20 Page 1 of 3 PageID #:203
From: Weibell, Tony

To: Katrina Carroll

Cc: Tom R. Freeman; Marc E. Masters; Jonathan Rotter; Marc L. Godino; Kara Wolke; Lionel Glancy; David M. Given;

Nicholas A. Carlin; James J. Pizzirusso; Megan E. Jones; Amanda Klevorn; Korey Nelson;

dgirard@girardsharp.com; jelias@girardsharp.com; apolk@girardsharp.com; bfj@chimicles.com;

bmm@chimicles.com; Kyle Shamberg; Nicholas Lange; lweaver@bfalaw.com; akeller@dicellolevitt.com;

dmillen@fklmlaw.com; bhogan@fklmlaw.com; Jon Jagher; kjustice@fklmlaw.com; jsprengel@caffertyclobes.com;

dherrera@caffertyclobes.com; nhagman@caffertyclobes.com; rrg@gordonlawchicago.com;

jgs@sstriallawyers.com; tyiatras@gmail.com; casey@lawofficeflynn.com; francisflynn@gmail.com;

jbk@sstriallawyers.com; twolfson@ahdootwolfson.com; rahdoot@ahdootwolfson.com;

tmaya@ahdootwolfson.com; bking@ahdootwolfson.com; rstephan@stephanzouras.com;

jzouras@stephanzouras.com; aficzko@stephanzouras.com; mshannon@stephanzouras.com;

elangeland@langelandlaw.com; jtostrud@tostrudlaw.com; fbottini@bottinilaw.com; achang@bottinilaw.com;

ykolesnikov@bottinilaw.com; jcotchett@cpmlegal.com; mmolumphy@cpmlegal.com;

tredenbarger@cpmlegal.com; nrahman@cpmlegal.com; ehg@classlawgroup.com; dmb@classlawgroup.com;

jbk@classlawgroup.com; william.a.baird.1@gmail.com; jguglielmo@scott-scott.com; ecomite@scott-scott.com;

jpettigrew@scott-scott.com; ekirkwood1@bellsouth.net; Wichmann@onderlaw.com; Onder@onderlaw.com;

ssklaver@susmangodfrey.com; Kalpana Srinivasan; mgervais@susmangodfrey.com; ecc@fmcolaw.com;

kcc@fmcolaw.com; rmf@fmcolaw.com; beth@feganscott.com; melissa@feganscott.com;

jonathan@feganscott.com; Benyamin, Ryan; Kowalk, Curtis; Ekwan E. Rhow; Steuer, David; Jih, Victor

Subject: [EXTERNAL] RE: Demand Letter

Date: Tuesday, August 25, 2020 9:59:24 AM

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Hi Katrina,

Thank you for your email and for all of your efforts to coordinate the numerous plaintiff groups that

are involved in this MDL. We know it has been a Herculean effort. We have been considering

whether and to what extent the class settlement terms can be shared as you described in your

email. We are working on a solution to that problem. Normally, for myriad reasons, such things are

kept confidential until they are presented to the Court for approval. Here, some of those reasons

include the highly sensitive matters that TikTok is dealing with in terms of being courted by multiple

potential suitors for acquisition, each of whom are vying to obtain confidential information such as

these terms, the intense media pressure to obtain such confidential information, the political

operatives who are prying for potential talking points for the political speeches being made, as well

as other similar considerations. But we are working to see whether and to what extent it would be

beneficial to get around those issues and let the settlement be shared with others prior to

submission to the Court for preliminary approval.

Thanks,

Tony

___________________________________

Case: 1:20-cv-04699 Document #: 11-16 Filed: 08/27/20 Page 2 of 3 PageID #:204
Anthony J Weibell | Partner | Wilson Sonsini Goodrich & Rosati

650 Page Mill Road | Palo Alto, CA 94304-1050 | direct: 650.354.4134 | aweibell@wsgr.com

 

Case: 1:20-cv-04699 Document #: 11-16 Filed: 08/27/20 Page 3 of 3 PageID #:205