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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

IN RE TIKTOK, INC. CONSUMER 

PRIVACY LITIGATION 

This Document Relates to All Cases 

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MDL No. 2948 

Case No. 1:20-cv-04699 

District Judge John Z. Lee 

Magistrate Judge Sunil R. Harjani 

JOINT CASE MANAGEMENT STATEMENT 

 As ordered by this Court in Case Management Order No. 1 on August 17, 2020 [ECF No. 

4], and Case Management Order No. 2 on September 1, 2020 [ECF No. 24], undersigned counsel 

for the parties to this MDL, which parties consist of: the plaintiffs who have reached a prospective 

settlement of the claims in the MDL (“Settling Plaintiffs”) (as identified in ECF No. 6 and in the 

signature blocks below), additional “Plaintiffs in Support of the Settlement Schedule” (as 

identified in ECF No. 6 and in the signature blocks below), including Plaintiff A.J. who supports 

the settlement schedule, non-settling plaintiffs who have proposed a litigation schedule 

(“Litigating Plaintiffs”) (as identified in the signature blocks below), Plaintiff M.E, and 

Defendants, submit this joint case management statement setting forth their respective positions 

on the topics requested by the Court: 

CMO 1, ¶9(b): List of Related Cases (Excluding Those Identified on Ex. A to CMO 1).

1. A.J. v. TikTok Inc. and ByteDance Inc., Case No. 5:20-cv-03390 (N.D. Cal. filed 5/19/2020) 

2. G.R. v. TikTok, Inc. and ByteDance, Inc., Case No. 2:20-cv-04537 (C.D. Cal. filed 5/20/2020) 

3. M.E., through guardian Anna Marie Emmerich v. TikTok Inc. and ByteDance Inc., Case No. 

5:20-cv-3555, (N.D. Cal. filed 5/27/2020) 

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4. L.M., A minor, through Guardian S.M. v. TikTok Inc. and ByteDance Inc., Case No. 3:20-cv0498 (S.D. Ill. filed 5/29/2020) 

5. C.H., a minor, by and through his Guardian, Marc Halpin v. TikTok, Inc. and ByteDance, Inc., 

Case No. 2:20-cv-05036 (C.D. Cal. filed 6/5/2020) 

6. Arpana Iyer, Brandy Johnson TikTok Inc. and ByteDance Inc., Case No. 3:20-cv-03795 (N.D. 

Cal. filed 6/9/2020) 

CMO 1, ¶9(d): Meeting of Counsel Topics.

 Settling Plaintiffs’ Position, including Plaintiffs in Support of the Settlement Schedule: 

Discussion of the topics set forth in paragraph 9(d) is not applicable in light of the 

settlement in principle Defendants have negotiated with certain Interim Counsel of Record for the 

Settling Plaintiffs. 

Defendants’ Position: 

The Federal Government has recently taken unprecedented, unconstitutional, and ultra 

vires actions against Defendants, see TikTok Inc., et al., v. Donald J. Trump, et al., No. 2:20-cv07672, ECF No. 1 (C.D. Cal. Aug. 24, 2020) (civil action seeking to enjoin presidential executive 

order against Defendants), that have placed Defendants in the unfair position of having to 

capitulate and resolve by settlement this litigation, which litigation should otherwise be dismissed 

on the pleadings. Because of Defendants’ unfairly disadvantaged bargaining position, that 

settlement is nothing short of a windfall for the proposed settlement class, and the settlement 

should therefore have little difficulty clearing the standards for approval set by Fed. R. Civ. P. 

23(e). The settling parties are currently working as fast as they can to satisfy certain conditions 

and prepare that settlement to be presented to the Court for preliminary approval, and they 

anticipate being able to do so in only 48 days (October 26, 2020). 

Given the circumstances, it is extremely unlikely, if not a virtual impossibility, that the 

settlement will not completely resolve this litigation. Rarely, if ever, do such cases return to 

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litigation on the merits after settlement. (This is true even when meritorious objections are raised 

during the settlement approval process. Such objections are typically resolved by modification, 

rather than termination, of the settlement.) For that reason, it would be a waste of Court and party 

resources to litigate the issues in paragraph 9(d) of CMO No. 1 that will be mooted by an approved 

settlement. Even so, Defendants have repeatedly made themselves available to all plaintiffs’ 

counsel to meet and confer regarding those topics and to listen to their respective proposals. 

To the extent any non-settling parties seek to learn the terms of the settlement, they will 

have those terms within 48 days (October 26, 2020) and will suffer no prejudice during these 48 

days (or less). They will have ample time to review the settlement and provide their input prior to 

any hearing on final approval. By contrast, Defendants stand to suffer great prejudice should any 

premature leak of confidential terms adversely affect their ability to comply with certain conditions 

of the Settlement or comply with the executive order that is the subject of the civil action against 

the President of the United States referred to above. The putative class will also suffer a 

tremendous loss should the efforts of any non-settling parties seeking to disrupt the settlement be 

successful and the government action against Defendants render future settlement impossible. 

Plaintiff A.J.’s Position: 

Pursuant to CMO 1 and 2, Plaintiff A.J.’s Counsel was included and participated in meet 

and confer discussions with other Interim Counsel of Record relating to scheduling matters. 

However, Plaintiff A.J.’s Counsel was not informed of, and thus did not participate in, a subsequent 

meet and confer call arranged with Defendants’ Counsel. Following direct communications with 

Defendants’ Counsel, Plaintiff A.J. proposes that the Court defer setting deadlines proposed by 

“Litigating Plaintiffs” with respect to pleadings, discovery and class certification pending (1) 

distribution of the Settlement to all Interim Counsel of Record and (2) a hearing to consider 

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approval of the proposed Settlement in accordance with the Settlement Schedule. 

Plaintiff M.E.’s Position: 

Plaintiff M.E., and her attorneys at Gibbs Law Group suggest that the Court defer setting 

a case management schedule until after it appoints co-lead counsel and gives those attorneys an 

opportunity to caucus. This case is too important, too complex, and too divisive to be rushed 

through the settlement approval process. Instead, Plaintiff suggests the Court take a similar 

approach to the one Judge George H. Wu took when faced with an early proposed settlement in 

the highly visible fuel-economy multidistrict litigation against Hyundai & Kia. Rather than judge 

the settlement immediately, at a time when it faced opposition from several other plaintiffs’ 

counsel and potential objections had yet to be fleshed out much less addressed, Judge Wu, through 

a series of status conferences and hearings, authorized supplemental discovery requested by the 

non-settling plaintiffs, requested several rounds of briefing to ensure all litigants’ concerns were 

heard and addressed, and ultimately approved a revised settlement that had the support of all but a 

few plaintiffs. The Ninth Circuit, sitting en banc, was complimentary of Judge Wu’s approach and 

affirmed his order granting final approval to a revised settlement valued at more than $210 million. 

In re Hyundai & Kia Fuel Econ. Litig., 926 F.3d 539, 572 (9th Cir. 2019) (remarking that “the 

district court performed an admirable job of managing this complex litigation” after settlement 

was announced at the initial CMC). Plaintiff M.W. believes this case shares many similarities with 

Hyundai and would benefit from a similar process.

Litigating Plaintiffs’ Position: 

 The Litigating Plaintiffs plan to proceed with discovery and setting a litigation schedule, 

as reflected in the below proposed case management schedule. The Litigating Plaintiffs believe 

that the proposed Class members’ rights should be protected by litigation, and this case should be 

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vigorously prosecuted on behalf of the proposed Classes unless and until a Settlement is filed by 

Court-appointed counsel and approved by this Court. While Defendants emphasize that the 

purported Settlement will be filed a mere 48 days from today, and that it will completely resolve 

this litigation, the Litigating Plaintiffs are cognizant of the Court’s statement in CMO 2 that no 

Interim Plaintiffs’ Counsel has the authority to “bind another Plaintiff or another putative class of 

Plaintiffs absent further order of the Court.” Accordingly, counsel for the Litigating Plaintiffs 

were prepared to discuss each of the topics set forth in paragraph 9(b) of CMO 1. 

However, counsel for the Settling Plaintiffs, counsel for Plaintiffs in Support of the 

Settlement Schedule, and Defendants maintain that discussion of the topics is not applicable in 

light of the purported Settlement negotiated between Defendants and certain Interim Counsel of 

Record for the Settling Plaintiffs. Defendants also continue to refuse to disclose the terms of the 

purported Settlement, despite the directive in CMO 1 ¶9(d)(v) to discuss settlement efforts. 

CMO 1, ¶(f): Proposed Case Management Schedule. 

EVENT Litigating 

Plaintiffs 

Settling Plaintiffs, 

Plaintiff A.J., and 

other Plaintiffs in 

Support of 

Settlement 

Schedule 

Defendants 

Defendants to 

disclose purported 

Settlement terms to 

all Plaintiffs’ 

counsel of record 

1 day after 

Order 

appointing 

Lead 

Counsel1

We are in favor of 

disclosure and take 

no position on the 

timing. 

October 26, 2020. This event 

proposed by non-settling 

plaintiffs is not an event 

identified in CMO No. 1. The 

terms of the Settlement are 

confidential, highly sensitive, and 

Defendants and class members 

1

 Counsel for J.S. and R.S., by their guardian, Aparna Iyer, Katherine Czajka, Brandy Johnson, 

and Karina Quinteiro, represented by Lesley Weaver and Amy Keller, believe that, after the terms 

of the purported Settlement are disclosed, the appointed Lead Counsel can discuss a briefing 

schedule on the Settlement or discuss whether further negotiations are appropriate or feasible. 

Depending on the answers to these questions, the schedule as proposed by the Litigating Plaintiffs 

may need to be modified. 

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stand to suffer great prejudice 

from any premature disclosure 

made prior to satisfaction of 

conditions in the settlement and 

preparation of the settlement for 

submission to the Court. 

Submit briefing 

schedule regarding 

disputes or agreed 

Protocol for Special 

Master for 

Preservation 

7 days after 

Order 

appointing 

Lead 

Counsel.2

We do not feel this 

is necessary in light 

of CMO 1 and 2. 

This proposed event is not an 

event identified in CMO No. 1. It 

was also obviated and rejected by 

CMO No. 2. It is a waste of Court 

and party resources, as 

Defendants are complying with 

those orders. 

Consolidated 

Amended 

Complaint 

(“CAC”) 

30 days 

after Order 

appointing 

Lead 

Counsel 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement, which is anticipated 

to be filed with the Court just 34 

days after the hearing on lead 

counsel appointment 

Defendants’ 

Motion to Dismiss 

60 days 

after filing 

CAC 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Opposition to 

Motion to Dismiss 

60 days 

after filing 

motion to 

dismiss 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Reply in Support of 

Motion to Dismiss 

45 days 

after 

opposition 

to motion to 

dismiss 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Exchange Initial 

Disclosures

October 20, 

2020 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

File joint or 

competing 

Protective Order, 

ESI Protocol, and 

other orders 

October 20, 

2020 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

2

 Defendants state that they are complying with the Court’s CMOs. Despite Litigating Plaintiffs’ 

request, Defendants have failed to confirm to the Litigating Plaintiffs that they have informed 

TikTok’s potential acquirors of the directives of CMO 2. 

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Amend Pleadings, 

Add Parties, Claims 

or Defenses

60 days 

after Order 

on motion 

to dismiss 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Substantial 

Production of 

Discovery 

May 5, 2021 Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Fact Discovery 

Cutoff 

October 5, 

2021 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Class Certification 

Brief 

October 23, 

2021 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Class Certification 

Opposition 

December 

16, 2021 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Class Certification 

Reply 

February 

12, 2022 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Fact Expert Reports March 12, 

2022 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Fact Expert 

Rebuttal Reports 

April 16, 

2022 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Fact Expert 

Deposition 

Deadline 

May 28, 

2022 

Not applicable as a 

result of the 

Settlement. 

Not applicable as a result of the 

Settlement. 

Respectfully Submitted, 

INTERIM COUNSEL OF RECORD FOR LITIGATING PLAINTIFFS: 

DATED: September 8, 2020 GLANCY PRONGAY & MURRAY LLP

By: /s/ Kara M. Wolke 

Kara M. Wolke 

1925 Century Park East, Suite 2100 

Los Angeles, California 90067-2561 

Telephone: (310) 201-9150 

Email: kwolke@glancylaw.com

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BIRD, MARELLA, BOXER, WOLPERT, 

NESSIM, DROOKS, LINCENBERG & 

RHOW, P.C. 

Ekwan E. Rhow 

1875 Century Park East, 23rd Floor 

Telephone: (310) 201-2100 

Email: erhow@birdmarella.com 

PHILLIPS, ERLEWINE, GIVEN & 

CARLIN LLP 

David M. Given 

39 Mesa Street, Suite 201, The Presidio 

San Francisco, CA 94129 

Telephone: (415) 398-0900 

Email: dmg@phillaw.com 

HAUSFELD LLP 

Megan E. Jones 

600 Montgomery Street, Suite 3200 

San Francisco, CA 94111 

Telephone: (415) 633-1908 

Email: mjones@hausfeld.com 

BURNS CHAREST LLP 

Amanda Klevorn 

365 Canal Street, Suite 1170 

New Orleans, Louisiana 70115 

Telephone: (504) 779-2845 

Email: aklevorn@burnscharest.com 

LAWRENCE KAMIN, LLP 

Peter E. Cooper 

300 S. Wacker Dr., Ste. 500 

Chicago, IL 60606 

Telephone: (312) 372-1947 

Email: pcooper@lawrencekamin.com 

CLIFFORD LAW OFFICES 

Rober A. Clifford 

Shannon M. McNulty 

120 N LaSalle Street, 31st Floor 

Chicago, IL 60602 

Telephone: (312) 625-6192 

Email: rac@cliffordlaw.com 

Email: smm@cliffordlaw.com 

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BLEICHMAR FONTI & AULD LLP

 By: /s/ Lesley E. Weaver 

 Lesley E. Weaver 

555 12th Street, Suite 1600 

 Oakland, CA 94607 

 Telephone: (415) 445-4003 

 email: lweaver@bflaw.com 

DICELLO LEVITT GUTZLER 

By: /s/ Amy E. Keller 

Amy E. Keller 

10 North Dearborn Street, 6th floor 

Chicago, IL 60602 

Telephone: (312) 214-7300 

Email: Akeller@dicellolevitt.com 

INTERIM COUNSEL OF RECORD FOR THE SETTLING PLAINTIFFS: 

Dated: September 8, 2020 CARLSON LYNCH LLP 

By: /s/ Katrina Carroll 

Katrina Carroll 

Kyle A. Shamberg 

Nicholas R. Lange 

111 W. Washington Street, Suite 1240 

Chicago, IL 60602 

Telephone: (312) 750-1265 

Email: kcarroll@carlsonlynch.com 

Email: kshamberg@ carlsonlynch.com 

Email: nlange@carlsonlynch.com 

FREED KANNER LONDON & 

MILLEN LLC 

Jonathan M. Jagher 

Kimberly A. Justice 

923 Fayette St. 

Conshohocken, PA 19428 

Tel.: (610) 234-6487 

Fax: (224) 632-4521 

Email: jjagher@fklmlaw.com 

Email: kjustice@fklmlaw.com 

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FREED KANNER LONDON & 

MILLEN LLC 

Douglas A. Millen 

Brian M. Hogan 

2201 Waukegan Road, Suite 130 

Bannockburn, Illinois 60015 

Tel.: (224) 632-4500 

Fax: (224) 632-4521 

Email: dmillen@fklmlaw.com 

Email: bhogan@fklmlaw.com 

CAFFERTY CLOBES MERIWETHER 

& SPRENGEL LLP 

Jennifer W. Sprengel 

Daniel O. Herrera 

Nickolas J. Hagman 

150 S. Wacker, Suite 3000 

Chicago, Illinois 60606 

Telephone: 312-782-4880 

Facsimile: 318-782-4485 

Email: jsprengel@caffertyclobes.com 

Email: dherrera@caffertyclobes.com 

Email: nhagman@caffertyclobes.com 

SAUDER SCHELKOPF LLC 

Joseph G. Sauder 

Joseph B. Kenney 

1109 Lancaster Avenue 

Berwyn, PA 19312 

Telephone: (610) 200-0580 

Fax: (610) 421-1326 

Email: jgs@sstriallawyers.com 

Email: jbk@sstriallawyers.com 

GORDON LAW OFFICES, LTD. 

Richard R. Gordon

111 West Washington Street 

Suite 1240 

Chicago, Illinois 60602 

Tel: (312) 332-5200 

Fax: (312) 242-4966 

Email: rrg@gordonlawchicago.com 

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STEPHAN ZOURAS, LLP 

James B. Zouras 

Ryan F. Stephan 

Andrew C. Ficzko 

Megan E. Shannon 

100 N. Riverside Plaza, Suite 2150 

Chicago, Illinois 60606 

312.233.1550 

312.233.1560 f 

Email: rstephan@stephanzouras.com 

Email: jzouras@stephanzouras.com 

Email: aficzko@stephanzouras.com 

Email: mshannon@stephanzouras.com 

ERIK LANGELAND, P.C. 

Erik H. Langeland 

(pro hac vice forthcoming) 

733 Third Avenue, 15th Floor 

New York, N.Y. 10017 

Tel: (212) 354-6270 

Email: elangeland@langelandlaw.com 

TOSTRUD LAW GROUP, P.C. 

Jon A. Tostrud 

1925 Century Park East, Suite 2100 

Los Angeles, CA 90067 

Tel: (310) 278-2600 

Email: jtostrud@tostrudlaw.com 

FEGAN SCOTT LLC 

Elizabeth A. Fegan 

150 S. Wacker Dr., 24th Floor 

Chicago, IL 60606 

Phone: 312.741.1019 

Fax: 312.264.0100 

Email: beth@feganscott.com 

FEGAN SCOTT LLC 

Melissa Ryan Clark 

Jonathan D. Lindenfeld 

140 Broadway, 46th Floor 

New York, NY 10005 

Phone: 332.216.2101 

Fax: 917.725.9346 

Email: melissa@feganscott.com 

Email: jonathan@feganscott.com 

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FOOTE, MIELKE, CHAVEZ 

& O’NEIL, LLC 

Kathleen C. Chavez 

Elizabeth C. Chavez 

Robert Foote 

10 W. State Street, Suite 200 

Geneva, IL 60134 

Tel. No.: (630) 232-7450 

Fax No.: (630) 232-7452 

Email: ecc@fmcolaw.com 

Email: kcc@fmcolaw.com 

Email: rmf@fmcolaw.com 

CONSUMER PROTECTION LEGAL, LLC 

Tiffany M. Yiatras 

8235 Forsyth Boulevard, Suite 1100 

Saint Louis, MO 63105-1643 

Telephone: 314-541-0317 

Email: tiffany@consumerprotectionlegal.com 

SCOTT+SCOTT 

Joseph P. Guglielmo 

230 Park Avenue, 17th Floor 

New York, NY 10169 

Telephone: 212-223-6444 

Facsimile: 212-223-6334 

Email: jguglielmo@scott-scott.com 

SUSMAN GODFREY L.L.P. 

Michael Gervais 

1900 Avenue of the Stars, Suite 1400 

Los Angeles, CA 90067 

Tel: (310) 789-3100 

Fax: (310) 789-3150 

Email: mgervais@susmangodfrey.com 

AHDOOT & WOLFSON, PC 

Tina Wolfson 

10728 Lindbrook Drive 

Los Angeles, CA 90024 

Tel: (310) 474-9111 

Fax: (310) 474-8585 

Email: twolfson@ahdootwolfson.com 

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INTERIM COUNSEL OF RECORD FOR PLAINTIFF A.J.: 

Dated: September 8, 2020 COTCHETT, PITRE & McCARTHY LLP 

By: /s/ Mark C. Molumphy 

Mark C. Molumphy 

Julia Peng 

Tyson Redenbarger 

Noorjahan Rahman 

San Francisco Airport Office Center 

840 Malcolm Road, Suite 200 

Burlingame, California 94010 

Telephone: (650) 697-6000 

Facsimile: (650) 697-0577 

Email: mmolumphy@cpmlegal.com 

Email: jpeng@cpmlegal.com 

Email: tredenbarger@cpmlegal.com 

Email: nrahman@cpmlegal.com 

BOTTINI & BOTTINI, INC. 

By: /s/ Albert Y. Chang 

Albert Y. Chang 

Francis A. Bottini, Jr. 

Yury A. Kolesnikov 

7817 Ivanhoe Avenue, Suite 102 

La Jolla, California 92037 

Telephone: (858) 914-2001 

Facsimile: (858) 914-2002 

Email: fbottini@bottinilaw.com 

Email: achang@bottinilaw.com 

Email: ykolesnikov@bottinilaw.com 

INTERIM COUNSEL OF RECORD FOR OTHER PLAINTIFFS IN SUPPORT OF THE 

SETTLEMENT SCHEDULE: 

GIRARD SHARP LLP 

Daniel Girard 

Jordan Elias 

Adam Polk 

601 California Street, Suite 1400 

San Francisco, CA, 94108 

Tel: (415) 981-4800 

Email: dgirard@girardsharp.com 

Email: jelias@girardsharp.com 

Email: apolk@girardsharp.com 

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CHIMICLES SCHWARTZ KRINER & 

DONALDSON SMITH-LLP 

Benjamin F. Johns 

Beena M. McDonald 

361 W. Lancaster Avenue 

Haverford, Pennsylvania 19041 

Telephone: (610) 642-8500 

Facsimile: (610) 649-3633 

Email: bfj@chimicles.com 

Email: bmm@chimicles.com 

LAW OFFICE OF FRANCIS J. FLYNN, JR. 

Francis J. “Casey” Flynn, Jr. 

3518A Arsenal Street 

Saint Louis, Missouri 63118 

Telephone: (314) 662-2836 

Email: casey@lawofficeflynn.com 

ONDERLAW, LLC 

Lawana S. Wichmann 

James G. Onder 

110 E. Lockwood Ave, 2nd Floor 

St. Louis, MO 63119 

Telephone: (314) 963.9000 

Facsimile: (314) 963-1700 

Email: Wichmann@onderlaw.com 

Email: Onder@onderlaw.com 

INTERIM COUNSEL OF RECORD FOR PLAINTIFF M.E.:

Dated: September 8, 2020 GIBBS LAW GROUP LLP 

By: /s/ Eric H. Gibbs 

Eric H. Gibbs 

505 14th Street, Suite 111 

Oakland, CA 94612 

Telephone: (510) 350-9700 

ehg@classlawgroup.com 

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COUNSEL FOR DEFENDANTS BYTEDANCE INC. AND TIKTOK INC.: 

Dated: September 8, 2020 WILSON SONSINI GOODRICH 

& ROSATI 

Professional Corporation 

By: /s/ Anthony J Weibell 

Anthony J. Weibell 

650 Page Mill Road 

Palo Alto, CA 94304-1050 

Telephone: (650) 493-9300 

Facsimile: (650) 565-5100 

Email: aweibell@wsgr.com 

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CERTIFICATE OF SERVICE 

I hereby certify that on September 8, 2020, the foregoing document was filed electronically 

through the Court’s Electronic Case Filing System. Service of this document is being made upon 

all counsel of record in this case by the Notice of Electronic Filing issued through the Court’s 

Electronic Case Filing System on this date. 

/s/ Kara M. Wolke 

Kara M. Wolke 

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