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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

No. 20-cv-04699

Judge John Z. Lee

Magistrate Judge Sunil R. Harjani

ERIK H. LANGELAND’S APPLICATION IN SUPPORT OF JAMES ZOURAS’S

APPLICATION FOR APPOINTMENT TO PLAINTIFFS’ STEERING COMMITTEE 

AND JONATHAN JAGHER’S AND KATRINA CARROLL’S APPLICATION FOR 

APPOINTMENT AS CO-LEAD COUNSEL UNDER FED. R. CIV. P. 23(g)

Under Rule 23(g) of the Federal Rules of Civil Procedure and the Court’s August 17, 2020 

Case Management Order (“CMO 1”), ECF Doc. 4, Erik Langeland of Erik H. Langeland, P.C. 

(“EHL”) respectfully submits this response supporting the application of James Zouras for 

appointment to Plaintiffs’ Steering Committee, and the application of Jonathan Jagher and Katrina 

Carroll for their appointment as Co-Lead Counsel.

My firm was established in 2003 primarily to represent plaintiffs in complex litigation. We 

are experienced in a broad range of civil litigation matters, including employment, wage and hour 

litigation, personal injury, business disputes, medical malpractice, privacy violations, consumer 

protection, and other types of complex litigation. My firm resume is attached as Exhibit A.

My firm has been appointed lead or co-lead counsel in several complex class and collective 

actions which have collectively resulted in a total monetary recovery of millions of dollars for 

thousands of plaintiffs. In the federal district court for the Eastern District of New York alone, we 

have successfully prosecuted the following cases: Kuck v. Planet Home Lending, LLC., et al., Case No. 

17 cv 04769 (E.D.N.Y.); Cedeno v. Home Mortgage Desk, Corp., et al., Case No.: 08 cv 1168 (E.D.N.Y.); 

Daniels v. Premium Capital Funding, LLC, et al., Case No.: 08 cv 4736 (E.D.N.Y); Sexton, et al. v. 

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Franklin First Financial, et al., Case No. 08 cv 04950 (E.D.N.Y.); Searson v. Concord Mortgage Corporation, 

Case No. 07 cv 3909 (E.D.N.Y.); Franco v. Ideal Mortgage Bankers, et al., Case No. 07 cv 3956 

(E.D.N.Y.). Some of these cases, which my firm handled throughout all stages of litigation, have 

resulted in favorable reported decisions. See, e.g., Franco v. Ideal Mortg. Bankers, Ltd., 2009 WL 3150320 

(E.D.N.Y. Sept. 28, 2009); Searson v. Concord Mortg. Corp., 2009 WL 3063316 (E.D.N.Y. Sept 24, 

2009); Sexton v. Franklin First Financial, Ltd., 2009 WL 1706535 (E.D.N.Y. June 16, 2009).

My firm has worked collaboratively with James Zouras of Stephan Zouras, LLP on many 

complex class action cases for over fifteen years. Our relationship has been cordial, professional, and 

effective. Mr. Zouras is a highly-skilled litigator and would be an important addition to Plaintiffs’ 

Steering Committee.

Jon Jagher and Katrina Carroll have provided exemplary leadership and management of this 

complex case and should be appointed as Co-Lead Counsel. They have worked collaboratively with 

Plaintiffs’ and Defendants’ counsel and have skillfully forwarded the interests of the class. They 

spearheaded Plaintiffs’ mediation efforts and achieved an excellent result under difficult 

circumstances. Having realized the ultimate goal in this case—a favorable settlement for the class—

nobody is more deserving than Mr. Jagher and Ms. Carrol to serve as Co-Lead Counsel.

James Zouras Is Highly Qualified to Serve on Plaintiffs’ Steering Committee

Plaintiffs would greatly benefit by James Zouras’s participation on the Steering Committee. 

No other counsel involved in this litigation has Jim’s experience in BIPA litigation. He has been at the 

forefront in the investigation and development of privacy law and the issues surrounding the security 

of biometric data, particularly in the State of Illinois. He is prosecuting over 150 BIPA class actions in 

both federal and state court. And he has garnered significant victories in BIPA cases at the trial and 

appellate levels. He has a long track record of achieving meaningful results for the class action plaintiffs 

he represents.

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Because of his vast experience in BIPA litigation, Jim’s ability to serve the best interests of the 

class is unmatched. He is extraordinarily familiar with issues involving the collection and storage of 

biometric information, and how BIPA operates to regulate these activities. Mr. Zouras and his firm 

have been appointed as class counsel in dozens of BIPA case.

In addition to his experience and ability, Jim is also a pleasure to work with. He works well 

with both co-counsel and opposing counsel. He is collaborative and inclusive. He has reasonable 

approach to problem-solving and finding solutions. Jim is an invaluable resource and an ideal choice 

for appointment as a member of the Plaintiffs’ Steering Committee

B. Jon Jagher and Katrina Carroll Should Serve as Co-Lead Counsel

Jon Jagher and Katrina Carroll have already demonstrated their leadership and dedication to 

the class in this matter. They have worked tirelessly to investigate, organize, and prosecute this case, 

with the ultimate goal of achieving the best outcome for the class members.

Mr. Jagher and Ms. Carroll have held leadership roles in numerous other class actions, 

including data privacy cases. They are experienced and have cooperated with other plaintiffs’ counsel 

to achieve a common goal. They have encouraged inclusiveness, have communicated well with all 

counsel, and have treated all counsel fairly.

Perhaps most importantly, Mr. Jagher and Ms. Carroll have resolved this dispute, which would 

otherwise be litigated for years. They did so quickly, efficiently, with the support of the vast majority 

of plaintiff’s counsel, and in the interest of the class. The progress that they made since the inception

of the case includes the organization of all related cases, communications with plaintiffs’ counsel, 

meeting and conferring with defense counsel, and, a mediation which should result in the settlement 

of the case. Given their commitment and demonstrated effectiveness, Mr. Jagher and Ms. Carroll 

should be appointed Co-Lead Counsel for this case.

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September 8, 2020 Respectfully Submitted,

/s/ Erik H. Langeland

Erik H. Langeland

733 Third Avenue, 16th Floor

New York, NY 10017

(212) 354-6270

(212) 898-9086 fax

elangeland@langelandlaw.com

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