EXHIBIT B 

Case: 1:20-cv-04699 Document #: 197-19 Filed: 03/31/22 Page 1 of 16 PageID #:3779
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 

DECLARATION OF MICHAEL GERVAIS IN SUPPORT OF PLAINTIFFS’ PETITION 

FOR AWARD OF ATTORNEYS’ FEES FILED ON BEHALF OF SUSMAN GODFREY 

 I, MICHAEL GERVAIS, declare and state as follows: 

1. I am a partner of the law firm of Susman Godfrey. My firm’s resume is attached 

hereto as Exhibit 1. I submit this Declaration in support of Plaintiffs’ petition for an award of 

attorneys’ fees and reimbursement of costs and expenses in connection with services rendered and 

expenses incurred by my firm in connection with this litigation. 

2. My firm has acted as counsel to Plaintiffs and Plaintiffs’ settlement classes in this 

action. During the period from case inception through October 31, 2020 (the first reporting period 

pursuant to the Court’s Case Management Order No. 4: Common Benefit Fee and Expense 

Protocol [Dkt. 105], my firm conducted the following activities for the common benefit of 

Plaintiffs and the settlement classes: legal research and fact investigation to evaluate claims, 

theories, and strategy; legal research into possible defenses, including arbitration clause; drafted 

and filed a class action complaint in the Central District of California (where TikTok is 

headquartered); filed briefs in response to motion to consolidate and motion to transfer to the 

JPML; participated in multiple pre-mediation and post-mediation strategy discussions with other 

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plaintiffs’ counsel; edited draft term sheets and mediation statements; attended and participated in 

mediation that resulted in the settlement agreement that was ultimately executed; edited term sheet 

and settlement agreement through multiple rounds; argued at JPML hearing; edited joint status 

report; drafted preservation notice served on defendants; edited amended consolidated complaint 

for MDL, including reviewing hundreds of source documents to incorporate additional factual 

support; appointed to leadership group as a member of the Steering Committee; reviewed case 

filings and attended and participated in case management conference and other case hearings; 

conducted factual investigation and prepared memorandum for the leadership group related to the 

corporate structure of defendants; and participated in multiple strategy calls with the leadership 

group. The total number of hours expended on this litigation by my firm from case inception 

through October 31, 2020, is 308.50 hours. The total lodestar for my firm in this time period is 

$223,882.50. 

3. For the time period November 1, 2020 through February 28, 2022, and at the 

request of Plaintiffs’ Co-Lead Counsel, my firm conducted the following activities for the common 

benefit of Plaintiffs: assisted in written discovery, including reviewing interrogatory responses 

and providing comments and edits of written questions for deposition; reviewed draft amended 

complaint for substantive issues and provided comments and edits regarding the same; reviewed 

case filings and attended and participated in case hearings; and participated in multiple strategy 

calls with the leadership group. The total number of hours expended on this litigation by my firm 

from for the time period November 1, 2020 through February 28, 2022, is 51.50 hours. The total 

lodestar for my firm in this time period is $41,297.50. 

4. The total number of hours expended on this litigation by my firm from case 

inception through February 28, 2022, is 359.60 hours. The total lodestar for my firm is 

Case: 1:20-cv-04699 Document #: 197-19 Filed: 03/31/22 Page 3 of 16 PageID #:3781
$265,180.00. My firm’s lodestar figures are based on the firm’s current hourly billing rates. The 

hourly rates for the partners, attorneys and professional support staff in my firm are the same as 

the usual and customary hourly rates charged for their services in contingent billable matters. The 

total number of hours was determined by the examination of contemporaneous, daily time records 

regularly prepared and maintained by my firm and which have been provided to Co-Lead Counsel 

for their review. 

5. Attached hereto as Exhibit 2 is a detailed summary indicating the amount of time 

spent by the partners, attorneys and other professional support staff of my firm who have been 

involved in this litigation, and the lodestar calculation is based on my firm’s current hourly billing 

rates from case inception through February 28, 2022. 

6. As detailed in Exhibit 3, my firm has incurred a total of $1,871.63 in unreimbursed 

expenses during the period from case inception through February 28, 2022. These expenses do not 

include my firm’s assessment payments to the common cost litigation fund maintained by CoLead Counsel. 

7. The expenses incurred in this action are reflected on the books and records of my 

firm. These books and records are prepared from expense vouchers, check records and other 

source materials and represent an accurate recordation of the expenses incurred. 

 I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

 Executed on this 25th day of March 2022 at Los Angeles, California. 

 

 /s/ Michael Gervais________________ 

 Michael Gervais 

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Exhibit 

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Susman Godfrey LLP 1 

Disclaimer: The information contained herein is revised frequently and is only accurate and current as of the date provided. Please 

call us for the most recent edition. 

The Susman Godfrey Difference 

For forty years, Susman Godfrey has focused its nationally recognized practice on just one 

thing: high-stakes commercial litigation. We are one of the nation’s leading litigation boutique 

law firms, with offices in Houston, Seattle, Los Angeles and New York. We have a unique 

perspective, the will to win, and an uncommon structure, which taken together provide the way 

to win. 

The Will to Win 

At Susman Godfrey, we want to win because we are stand-up trial attorneys, not discovery 

litigators. We approach each case as if it is headed for trial. Everything that we do is designed to 

prepare our attorneys to persuade a jury. When you are represented by Susman Godfrey, the 

opposing party will know that you are willing to take the case all the way to a verdict if 

necessary; this fact alone can make a good settlement possible. 

Susman Godfrey has a longstanding reputation as one of the premier firms of trial lawyers in the 

United States. We are often brought in on the eve of trial to "rescue" troubled cases or to take 

the reins when the case requires trial lawyers with a proven record of courtroom success. 

We also want to win because we share the risk with our clients. We prefer to work on a 

contingency-fee basis so that our time and efforts pay off only when we win. Our interests are 

aligned with our clients—we want to achieve the best-possible outcome at the lowest possible 

cost. 

Finally, we want to win because each of our attorneys shares a commitment to your success. 

Each attorney at the firm—associate as well as partner—examines every proposed contingent 

fee case and has an equal vote on whether or not to accept it. The resulting profit or loss affects 

the compensation of every attorney at the firm. This model has been a tremendous success for 

both our attorneys and our clients. In recent years, we have achieved the highest profit-perpartner results in the nation. Our associates have enjoyed performance bonuses equal to their 

annual salaries. When you win, our attorneys win. 

Unique Perspective 

Susman Godfrey represents both plaintiffs and defendants. Ours is not a cookie-cutter practice 

turning out the same case from the same side of the bar time after time. We thrive on variety, 

flexibility, and creativity. Clients appreciate the insights that our broad experience brings. "I think 

that's how they keep their tools sharp," says one. 

Many companies who have had to defend cases brought by Susman Godfrey on behalf of 

plaintiffs are so impressed with our work in the courtroom that they hire us themselves next time 

around—companies like El Paso Corporation, Georgia-Pacific Corporation, Mead Paper, and 

Nokia Corporation. 

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Susman Godfrey LLP 2 

Disclaimer: The information contained herein is revised frequently and is only accurate and current as of the date provided. Please 

call us for the most recent edition. 

We know from experience what motivates both plaintiffs and defendants. This dual perspective 

informs not just our trial tactics, but also our approach to settlement negotiations and mediation 

presentations. We are successful in court because we understand our opponent's case as well 

as our own. 

An Uncommon Structure 

At Susman Godfrey, our clients hire us to achieve the best possible result in the courtroom at 

the least possible cost. Because we learned to run our practice on a contingency-fee model 

where preparation of a case is at our expense, we have developed a very efficient approach to 

commercial litigation. We proved that big cases do not require big hours. And, because we staff 

and run all cases using the same model, clients who prefer to hire us by the hour also benefit 

from our approach. 

There is no costly pyramid structure at Susman Godfrey. As a business, we are lean, mean and 

un-leveraged—with a two-to-one ratio between partners and associates. To counter the 

structural bloat of our opponents, who often have three associates for each partner, we rely on 

creativity and efficiency. 

Susman Godfrey's experience has taught what is important at trial and what can be safely 

ignored. We limit document discovery and depositions to the essential. For most depositions 

and other case-related events we send one attorney and one attorney alone to handle the 

matter. After three decades of trials, we know what we need—and what is just a waste of time 

and money. 

Unparalleled Talent 

Susman Godfrey prides itself on a talent pool as deep as any firm in the country. Clerking for a 

judge in the federal court system is considered to be the best training for a young trial attorney, 

100% of our Associates and over 90% of our Partners served in these highly sought-after 

clerkships after law school. Ten of our trial lawyers have clerked at the highest level—for 

Justices of the United States Supreme Court. 

Our associates are not document-churning drones. Each associate at Susman Godfrey is 

expected to second-chair cases in the courtroom from the start. Because we are so confident in 

their abilities, we consider associates for partnership after seven years with the firm, unless they 

joined us following a federal judicial clerkship. In that case, we give credit for the clerkship, and 

the partnership track is generally six years. We pay them top salaries and bonuses, make them 

privy to the firm's financials, and let them vote—on an equal standing with partners—on virtually 

all firm decisions. 

Each trial attorney at Susman Godfrey is invested in our unique model and stands ready to 

handle your big-stakes commercial litigation. 

Case: 1:20-cv-04699 Document #: 197-19 Filed: 03/31/22 Page 7 of 16 PageID #:3785
Susman Godfrey LLP 3 

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call us for the most recent edition. 

A Record of Winning 

One of Susman Godfrey's early cases, the Corrugated Container antitrust trial, led to one of the 

highest antitrust jury verdicts ever obtained. Since that extraordinary start, the firm has 

remained devoted to helping businesses and individuals achieve similarly extraordinary results. 

Recent high-profile victories include: 

x Secured a $600 million settlement for residents of Flint, Michigan in the nationally 

followed Flint Water Crisis litigation. 

x Won a $706.2 million unanimous jury verdict for client HouseCanary, in a breach of 

contract and misappropriation of trade secrets case against Quicken Loans affiliate, Title 

Source, Inc. The judgement appears at number four on The National Law Journal’s “Top 

100 Verdicts of the Year” list. 

x Won a $25.25 million jury verdict for client, Steven Lamar, in a contract and intellectual 

property dispute with Dr. Dre and Jimmy Iovine over the iconic Beats headphones — this 

verdict was also included on The National Law Journal’s “Top 100 Verdicts of the Year” 

list. 

x Secured a favorable settlement for Uber in its epic battle against Google’s Waymo over 

self-driving car technology. 

x Won a jury verdict valued at $128 million for client General Electric, in its legal battle 

against the Nebraska Investment Finance Authority. 

x Secured a settlement valued at $100 million for a certified class of plaintiffs in a 

copyright infringement class action against well-known music streaming service, Spotify. 

x Recovered $40 million for a class of derivatives investors in a securities class action 

against Valeant Pharmaceuticals International, Inc. The deal is believed to be the largest 

recovery ever obtained on behalf of derivative investors in history. 

x Won a $50.3 million federal jury verdict for client, Green Mountain Glass, in a patent 

infringement lawsuit against Ardagh Glass, Inc. This verdict was #34 on The National 

Law Journal’s “Top 100 Verdicts of 2017” list.

x Secured a $91.25 million settlement for insurance policy owners in 37 Besen Parkway, 

LLC v. John Hancock Life Insurance Company

x Secured nearly $600 million with various international investment banks on behalf of our 

plaintiff clients in the ongoing LIBOR antitrust class action. The agreement with these 

banks represents the resolution of claims by investors that transacted directly with the 

international banks on the panel to determine US Dollar LIBOR. Just recently the class 

that Susman Godfrey represents became the first and only class certified by the SDNY. 

x Won a $70 million judgement for Wellstat Therapeutics against BTG International, Inc. in 

a pharmaceutical contract dispute in the Delaware Court of Chancery. 

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Susman Godfrey LLP 4 

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call us for the most recent edition. 

x Secured a settlement valued at $73 million while representing Flo & Eddie (the founding 

members of 60’s music group, The Turtles) along with a class of owners of pre-1972 

sound recordings for copyright violations by music provider Sirius XM. Susman Godfrey 

attorneys on this matter were named “California Lawyer Attorneys of the Year” by The 

Daily Journal for their legal work on this case. 

x Won an over $43.2 million federal court jury award in favor of Apache Deepwater LLC 

and against W&T Offshore in an oil and gas related breach of contract case having to do 

with deepwater wells in the Gulf of Mexico. This verdict was named by The National Law 

Journal as one of “The Top 100 Verdicts of 2016” and appeared on Texas Lawyer’s “Hall 

of Fame Verdicts” in 2019. 

x Secured over $1.2 billion with several international automobile parts suppliers in the In 

Re Automotive Parts (Auto Parts) price-fixing class action. The multidistrict litigation, 

pending in the United States District Court for the Eastern District of Michigan, alleges 

long-running global collusion by auto parts companies to fix prices of automotive 

component parts. 

x Secured as lead counsel in a case that challenged Phoenix Life Insurance Company’s 

and PHL Variable Insurance Company’s decision to raise the cost of insurance (“COI”) 

nationwide on life insurance policy owners. The case settled with plaintiffs receiving a 

$48.5 million cash fund, COI freeze through 2020, and a covenant by Phoenix not to 

challenge the policies, worth $9 billion in face value. 

x Secured one of the largest settlement awards ever to a single whistleblower in a False 

Claims Act case—over $450 million from Novartis Pharmaceuticals, who was accused of 

defrauding Medicare and Medicaid by illegally paying kickbacks to pharmacies so they 

would recommend Novartis’s medications to doctors and patients.

x Secured a $244 million settlement in a federal monopolization and antitrust class action 

against News Corporation (News Corp) on behalf of a certified class of more than 500 

consumer packaged goods companies. The media giant also agreed to change its 

business practices regarding in-store advertising. 

Pro Bono 

Susman Godfrey is committed to improving the laws and the legal system by representing those 

who cannot afford to pay for legal services. We encourage our attorneys to participate in pro 

bono opportunities and make firm resources available to ensure our pro bono efforts are 

meaningful and effective. 

Lawyers at Susman Godfrey are often tapped by trial and appellate courts across the country to 

assist on precedent-setting pro bono matters. We also regularly partner with various 

organizations to drive forward significant and timely pro bono litigation. These organizations 

include, among many, the American Civil Liberties Union (ACLU), the Civil Rights Corps, the 

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Susman Godfrey LLP 5 

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call us for the most recent edition. 

Texas Fair Defense Project, the Next Generation Action Network Legal Advocacy, and the 

International Rescue Committee. 

In 2021, Susman Godfrey launched its 1MRSVMX]3[RIH&YWMRIWW13&97
4VS&SRS

4VSKVEQ which provides legal representation to minority-owned businesses in Houston in 

connection with commercial litigation, such as breach of contract, fraud, and other business 

disputes. 

Susman Godfrey has been included on 2EXMSREP0E[.SYVREPƅW4VS&SRS,SX0MWX and our 

lawyers have been honored with awards such as 8I\EW0E[]IVƅW%XXSVRI]SJXLI

=IEV, 9RMZIVWMX]SJ8I\EW7GLSSPSJ0E[ƅW(MWXMRKYMWLIH%PYQRYWJSV'SQQYRMX]7IVZMGI

%[EVH, and 8I\EW%TTPIWIIHƅW.'LV]W(SYKLIVX]+SSH%TTPI%[EVH. 

Should you want to partner with Susman Godfrey on a pro bono initiative, you can contact our 

Pro Bono Committee at 4VS&SRS$WYWQERKSHJVI]GSQ. 

The cases below illustrate the variety and importance of the matters we litigate pro bono. 

Constitutional Challenges 

x O’Donnell v. Harris County. For decades, the Harris County Jail held tens of 

thousands of people who were arrested for misdemeanors but were financially unable to 

post bail. Though arrested for the same minor offense, a person with money could avoid 

jail entirely while an indigent person would spend days or weeks in jail before 

determination of merits. Along with Civil Rights Corps and the Texas Fair Defense 

Project, Susman Godfrey represents on a pro bono basis a class of indigent arrestees 

who challenged the constitutionality of Harris County’s money bail practices. After an 

eight-day evidentiary hearing, the US District Court found Harris County’s system 

unconstitutional and ordered broad injunctive relief. After the bail reforms went into 

effect, the US Court of Appeals for the Fifth Circuit affirmed the district court’s rulings 

that the system was unconstitutional. In the first year in which the injunctive relief was in 

effect, more than 12,000 people were released from jail. 

Human Rights/Anti-Discrimination 

x Faculty, Alumni and Students Opposed to Racial Preferences v. New York 

University Law Review. Susman Godfrey defended New York University Law Review 

against allegations that its diversity and inclusiveness initiatives violate federal bias law 

by favoring female and minority applicants and authors. The Hon. Edgardo Ramos of the 

Southern District of New York granted the motion filed by Susman Godfrey to dismiss 

the case. The Second Circuit later affirmed the decision. 

x Texas v. United States of America and the International Rescue Committee.

Represented the International Rescue Committee (IRC) pro bono when the state of 

Texas sued to block the federal government and the IRC from resettling any Syrian 

refugees in Texas. Working with the ACLU, and the Southern Poverty Law Center, the 

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Susman Godfrey LLP 6 

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call us for the most recent edition. 

team defeated the state’s multiple requests for injunctive relief. The federal district court 

later dismissed all of the state’s claims. 

x Jared Woodfill et al. v. Annise Parker et al. Served as lead trial counsel for the city of 

Houston and won a jury verdict and a final judgment in a closely-watched trial over a 

challenge to Houston’s Equal Rights Ordinance, a law that prohibits discrimination based 

on an individual’s sex, race, color, ethnicity, national origin, age, familial status, marital 

status, military status, religion, disability, sexual orientation, genetic information, gender 

identity, or pregnancy in city employment and city services, city contracts, public 

accommodations, private employment (excluding religious organizations), and housing. 

The city asked Susman Godfrey to represent it pro bono and defend the ordinance. After 

a two-week trial, the jury issued its verdict resoundingly in the city’s favor. After two 

months of post-verdict briefing, the court issued a final judgment in favor of the city. 

x International Franchise Ass’n, Inc. et al. v. City of Seattle, et al. Retained by the city 

of Seattle on a partial pro bono basis to defend its landmark $15 per hour minimum 

wage ordinance. Several Seattle franchise businesses challenged the ordinance on a 

number of legal grounds, including violation of the Equal Protection Clause and Dormant 

Commerce Clause of the US Constitution. The district court denied the plaintiff franchise 

group’s motion for a preliminary injunction and found that the plaintiffs had failed to 

demonstrate a likelihood of succeeding on the merits of any of their claims. 

Death Penalty Appeals/Prisoners’ Rights

x David Daniels et al. v. Dallas County Sheriff Marian Brown. Partnered with the 

American Civil Liberties Union, ACLU of Texas, Civil Rights Corps, and the Next 

Generation Action Network Legal Advocacy Fund to bring a federal class-action lawsuit 

for emergency relief to remedy the Dallas County Jail’s ongoing failure to manage the 

extraordinary risks COVID-19 poses to its detainees, staff, and the larger community. 

x In re: Alfred DeWayne Brown. Represented a wrongfully convicted man, Alfred 

Dewayne Brown, in his now successful quest to obtain an “actual innocence” finding 

from the Harris County D.A.’s office after nearly a decade on death row for a murder he 

didn’t commit. 

x Harris v. Fischer. Secured an important pro bono appellate victory on behalf of a former 

Bedford Hills Correctional Facility inmate who alleged her Fourth and Eighth Amendment 

rights were violated during a body cavity search while she was incarcerated. In its ruling, 

the US Court of Appeals for the Second Circuit vacated the district court’s decision 

dismissing the case and remanded for further consideration. 

x Death Penalty Appeals. Handled several death penalty appeals focusing on the 

requirement for the State of Texas to release information about the chemicals used to 

put prisoners to death in order for counsel to protect the rights of their clients not to be 

subject to cruel and unusual punishment. In one case, the Susman Godfrey team 

obtained an injunction against execution due to this issue. 

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Susman Godfrey LLP 7 

Disclaimer: The information contained herein is revised frequently and is only accurate and current as of the date provided. Please 

call us for the most recent edition. 

Other Significant Pro Bono Work 

x Alley Theater v. Hanover Insurance Co. The Tony Award-winning Alley Theatre, the 

oldest professional theatre company in Texas and the third-oldest resident theatre in the 

country, suffered devastating destruction during Hurricane Harvey, incurring millions in 

losses from property damage, lost income and expenses. Susman Godfrey represented 

the Theatre pro bono in insurance litigation related to hurricane-caused business 

interruption. Susman Godfrey first secured a partial summary judgment ruling on behalf 

of Alley in a coverage lawsuit against Hanover over claims the theatre was not properly 

reimbursed for hurricane-related business interruption losses. The firm later scored a 

second victory for the theater when they settled the final piece of the litigation. 

x First Presbyterian Church of Houston v. Presbytery of the New Covenant, Inc.

Represented First Presbyterian Church of Houston (FPC), one of the oldest 

congregations in Houston, in a property dispute against the Presbyterian Church 

(PCUSA), which claimed for close to 30 years that it has a trust interest in FPC’s 

property in Houston, Texas. The Court ruled in FPC’s favor on summary judgment, 

entering final judgment and a permanent injunction against the Presbytery of the New 

Covenant and finding that the PCUSA has no interest in FPC’s property. After appellate 

arguments, the parties settled, with the denomination releasing any claim to any interest 

in FPC’s property.

x Law Center to Prevent Gun Violence. For years, Susman Godfrey has provided pro 

bono legal research, consultation, and strategy advice to the Law Center to Prevent Gun 

Violence regarding measures to regulate the sale and use of firearms. 

Office Locations 

Houston

1000 Louisiana St

Suite 5100

Houston, TX, 77002

T: 713-651-9366 

F: 713-654-6666

Los Angeles

1900 Avenue of the Stars

Suite 1400

Los Angeles, CA 90067

T: 310-789-3100 

F: 310-789-3150

New York

1301 Avenue of the Americas

32nd Floor

New York, NY 10019

T: 212-336-8330 

F: 212-336-8340

Seattle

1201 Third Avenue

Suite 3800

Seattle, WA 98101

T: 206-516-3880 

F: 206-516-3883

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Exhibit 

Case: 1:20-cv-04699 Document #: 197-19 Filed: 03/31/22 Page 13 of 16 PageID #:3791
Firm Name:

Categories: TITLE:

ATTORNEYS(P, A)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS 

HOURS

CURRENT 

HOURS

CUMULATIVE 

HOURS

HOUR

RAT

Gervais, Michael (P) 42.00 45.40 2.80 111.90 16.30 56.20 19.10 0.00 293.70 293.70 $675

Sklaver, Steven G. (P) 0.50 1.00 0.50 0.00 2.00 2.00 $1,200

Srinivasan, Kalpana (P) 1.20 2.00 1.00 10.40 1.20 3.20 14.80 9.40 0.00 43.20 43.20 $1,300

Thomas, Brandon (A) 1.20 9.10 0.90 0.00 11.20 11.20 $500

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 43.20 47.40 5.00 0.00 131.90 1.20 0.00 0.00 19.50 0.00 72.00 29.90 0.00 0.00 0.00 0.00 350.10 350.10 

NON-ATTORNEYS(LC, SPL, PL)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 PREVIOUS 

HOURS

CURRENT 

HOURS

CUMULATIVE 

HOURS

HOUR

RAT

DeGeorges, Simon (SPL) 0.20 0.60 0.00 0.80 0.80 $325Schulze, Stacy S. (SPL) 2.00 0.00 2.00 2.00 $350

Stanley, Joanna (SPL) 1.00 0.00 1.00 1.00 $350

Arreola, Norberto (PL) 5.00 0.00 5.00 5.00 $275

Moreno, Graciela (OT) 0.70 0.00 0.70 0.70 $125

0.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.00.00 0.00 0.00 $0.0

SUB-TOTAL 0.00 0.20 0.00 0.00 8.70 0.00 0.00 0.00 0.00 0.00 0.00 0.60 0.00 0.00 0.00 0.00 9.50 9.50 GRAND TOTAL: 43.20 47.60 5.00 0.00 140.60 1.20 0.00 0.00 19.50 0.00 72.00 30.50 0.00 0.00 0.00 0.00 359.60 359.60 

1) Legal Research2) Investigation / Factual Research3) Discovery  (Written / Deposition Taking &  Defending / Meet & Confer / etc. )4) Document Review (Including for depo prep, class cert, experts, liability issues,  jurisdictional issues, and meetings  re doc review)

5) Pleadings, Briefs & Motions (Drafting, Research, Serving & Filing)6) Class Certification7) Summary Judgment8) Appeals9) Court Appearance and Prep10) Experts 

11) Settlements & Mediation12) Case Management13) Class Notice 14) Trial Prep  (Exhibit & Witness List/Jury Instruction/  Vior Dire/Opening Statements/Closing  Arguments/Demonstratives/etc.)15) Trial

(P) Par(A) Ass(LC) L(SPL) S(PL) Pa

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 1

TIME REPORT SUMMARY AT HISTORIC RATES

Susman Godfrey LLP Reporting Period: Inception through 02/28/2022

 556281 

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Exhibit 

Case: 1:20-cv-04699 Document #: 197-19 Filed: 03/31/22 Page 15 of 16 PageID #:3793
CATEGORY DESCRIPTION 

(If necessary) CUMULATIVE COSTS

Litigation Assessment

Court Costs - Filing Fees $400.00

Experts/consultants

Federal Express / UPS /Ontrac

Postage / U.S. Mail

Service of Process $135.05

Messenger/delivery

Hearing Transcripts

Investigation

Lexis/westlaw $1,262.57

Photocopies - in House

Photocopies - Outside

Telephone/telecopier $4.01

Travel - Transportation

(Airplanes - Coach Fares Only)

Travel - Meals

($75 per person / day cap)

Travel - Hotels

Miscellaneous $70.00

TOTAL EXPENSES $1,871.63

IN RE: TIKTOK, INC., CONSUMER PRIVACY LITIGATION

EXHIBIT 2 

EXPENSE REPORT SUMMARY

FIRM NAME: Susman Godfrey LLP

REPORTING PERIOD: Inception through 02/28/2022

 556281 Ex 3 Expense Summary

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