Declaration of Christopher J. Cormier — In re Plaid Inc. Privacy Litigation (Dkt. 51-3, N.D. Cal. No. 4:20-cv-03056)

Record facts

U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 51-3 · 2020-07-17 · Docket on CourtListener

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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL 
CASE NO. 4:20-CV-03056-DMR
 
 
 
 
 
 
 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA 
SAN FRANCISCO DIVISION 
JAMES COTTLE and FREDERICK 
SCHOENEMAN, on behalf of themselves  
and all others similarly situated, 
Plaintiffs, 
 
v. 
PLAID INC., a Delaware corporation, 
Defendant. 
Case No.: 4:20-cv-03056-DMR
 
 
DECLARATION OF CHRISTOPHER 
J. CORMIER IN SUPPORT OF 
STIPULATION TO CONSOLIDATE 
ACTIONS AND APPOINT INTERIM 
CO-LEAD CLASS COUNSEL 
LOGAN MITCHELL, on behalf of himself  
and all others similarly situated, 
Plaintiffs, 
 
v. 
PLAID INC., a Delaware corporation, 
Defendant. 
Case No. 3:20-cv-04230-SK 
RACHEL CURTIS, ALEXA GROSSMAN, 
MALLORY GROSSMAN, STEVEN 
HANNIGAN, ALEXIS MULLEN, JORDAN 
SACKS, and NICHOLAS YEOMELAKIS, on 
behalf of themselves and all others similarly 
situated, 
Plaintiffs, 
 
v. 
PLAID INC., a Delaware corporation, 
Defendant. 
Case No. 4:20-cv-04344-DMR 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
CARRIE ANDERSON, BRIAN MCCRUDDEN, 
and JEFFREY SCHWEDOCK, on behalf of 
themselves and all others similarly situated, 
Plaintiffs, 
 
v. 
PLAID INC., a Delaware corporation, 
Defendant. 
Case No: 3:20-cv-04480-JSC   
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL 
CASE NO. 4:20-CV-03056-DMR
 
I, CHRISTOPHER J. CORMIER, hereby declare as follows: 
1. 
I am a partner of the law firm of Burns Charest LLP (“BC”), co-counsel in Cottle 
v. Plaid, No. 3:20-cv-03056 (N.D. Cal.) (“Cottle Action”), and Proposed Interim Co-Lead 
Counsel in the above-captioned actions.  I am a member in good standing of the Bars of 
Washington, D.C. and the State of Colorado, and am admitted pro hac vice before this Court.  I 
have personal knowledge of the statements contained in this Declaration and, if called to testify, I 
could and would testify competently to them. 
2. 
I submit this declaration in support of the Parties’ Stipulation to Consolidate 
Actions and Appoint Interim Co-Lead Class Counsel.  BC is well-suited to serve as Co-Lead 
Counsel in this litigation, and has contributed significantly to the development and prosecution of 
this case.  
Federal Rule of Civil Procedure 23(g) 
3. 
This litigation involves four separately-filed putative class actions, filed by 
multiple law firms, against the same defendant alleging the same conduct.  Each action raises 
substantively similar claims.  Judicial efficiency, as well as the interests of the proposed class, 
counsel in favor of establishing leadership for the class before the litigation proceeds any further.  
When multiple related cases are pending, as they are here, “the selection and activity of class 
counsel are often critically important to the successful handling of the class action.”  Fed. R. Civ. 
P. 23(g) Advisory Committee Notes.   
4. 
Appointing BC as Interim Co-Lead Counsel comports with the Rule 23(g) factors 
that guide courts’ decision-making in appointing class counsel.  These factors are:  
i. 
the work counsel has done in identifying or investigating potential claims in the 
action; 
ii. 
counsel’s experience in handling class actions, other complex litigation, and the 
types of claims asserted in the action; 
iii. 
counsel’s knowledge of the applicable law; and 
iv. 
the resources that counsel will commit to representing the class. 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
Fed. R. Civ. P 23(g)(1)(A). 
BC’s Contributions to Development of This Litigation 
5. 
In addition to significant experience litigating various types of complex class 
actions in this District and elsewhere, discussed below, BC brings a wealth of background 
experience specific to this litigation that has guided the development of the factual allegations and 
claims in this case.  In collaboration with co-counsel in the Cottle Action (Lieff Cabraser 
Heimann & Bernstein, LLP and Herrera Purdy LLP), BC has conducted a thorough pre-filing 
investigation, which afforded counsel in the Cottle Action an understanding of Plaid’s business 
practices and the issues before the Court.  
6. 
Along with co-counsel, BC researched the history and evolution of Plaid’s 
business, including its founding and growth within the financial technology (“fintech”) industry.  
BC and co-counsel developed an understanding of Plaid’s business model, the distinctions 
between its consumer-facing and industry-facing messaging, and some of the methods Plaid uses 
and previously used to collect data from consumers and deliver that data to its fintech customers.   
7. 
That research also included an in-depth and detailed review of Plaid’s messaging 
to consumers as it developed over time, as well as any relevant disclosures by consumer-facing 
third party apps—such as Venmo, Square, CashApp—in order to understand the scope of Plaid’s 
deceptive messages conveyed to consumers, and to identify the limited information provided to 
consumers who use the relevant third party apps.   
8. 
Further, BC and co-counsel engaged in a technical review into Plaid’s conduct in 
the context of the features of the above-referenced relevant third-party apps and the impact of 
such conduct on consumer consent issues, consumer privacy, and financial privacy issues. 
9. 
With the benefit of this factual backdrop, BC and co-counsel conducted legal 
research and analysis to determine and assert the appropriate claims on behalf of Plaintiffs and the 
putative Class. 
10. 
BC is committed to providing the best possible representation for consumers in 
this action, and continues to work collaboratively with co-counsel in researching and reviewing 
Plaid’s evolving disclosures to users of the relevant apps—which, while still inadequate, have 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
been amended by Plaid even since, and possibly due to, the commencement of the Cottle 
Action—and public-facing statements regarding Plaid’s business practices and use of private 
consumer data. 
Burns Charest LLP 
11. 
Burns Charest LLP has quickly gained a reputation as a leading class action and 
complex litigation boutique.  Founded by former Susman Godfrey LLP partners in 2015, the firm 
now boasts a roster of nearly 30 talented lawyers experienced not only in successfully litigating 
complicated cases on behalf of corporate and individual plaintiffs, but in taking them to trial and 
winning.  The firm is headquartered in Dallas, and has additional offices in New Orleans and 
Washington, DC.  Every year since its founding, numerous firm lawyers have been honored by 
leading industry publications such as Best Lawyers in America, Super Lawyers, Benchmark 
Litigation, and Global Competition Review/Who’s Who Legal.   
12. 
Nine of BC’s lawyers have been named to the Best Lawyers in America 2020 
listing, eight of its lawyers have been chosen as 2020 “Super Lawyers” or “Rising Stars” by 
Super Lawyers, and two of its lawyers have been recognized among the world’s top 124 plaintiff 
antitrust lawyers in Global Competition Review’s Who’s Who Legal: Competition (2020).  
13. 
BC has been appointed to leadership positions in the following class actions:  
a. 
In re German Automotive Manufacturers Antitrust Litigation, No. 17-MD-
2796 (N.D. Cal.) (lead class counsel representing proposed nationwide class of 
direct purchasers of German luxury vehicles alleging conspiracy among 
manufacturers to restrict innovation and artificially stabilize pricing); 
b. 
In re TikTok, Inc. Privacy Litigation, No. 5:19-cv-07792-LHK (N.D. Cal.) 
(executive committee member in class action alleging massive consumer privacy 
violations by secretly taking biometrics, private videos, clipboard content, user 
identifiers and device identifiers from approximately 140 million app users); 
c. 
Scola, et al. v. Facebook Inc., et al., No. 18-CIV-05135 (San Mateo Cnty. 
Superior Court, Cal.) (secured $52 million settlement, pending Court approval, as 
co-lead counsel for class of content moderators working for Facebook vendors 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
alleging trauma from viewing disturbing posts without proper protections); 
d. 
In re EpiPen (Epinephrine Injection, USP) Marketing, Sales Practices and 
Antitrust Litig., No. 17-MD-2785 (D. Kan.) (co-lead counsel for certified 
nationwide class of consumers and third-party payors of EpiPens alleging 
defendants Mylan and Pfizer violated federal and state antitrust law and federal 
RICO law by conspiring to restrict competition and illegally raise prices for the 
widely-used EpiPen); 
e. 
In re Domestic Airlines Antitrust Litig., No. 15-MC-01404 (D.D.C.) 
(executive committee firm representing proposed nationwide class of individuals 
alleging major airlines colluded to restrict airline capacity and artificially raise 
prices; $60 million in partial settlements obtained to date); 
f. 
In re West Texas Intermediate Crude Oil Commodities and Antitrust Litig., 
No. 11-CV-3600 (S.D.N.Y.) (co-lead class counsel responsible for $16.5 million 
settlement); 
g. 
In re Anadarko Basin Oil and Gas Lease Antitrust Litig., No. CIV-16-
0209-HE (W.D. Okla.) (obtained $7 million settlement as co-lead counsel for class 
of landowners alleging defendant natural gas producers conspired to rig bids and 
fix prices for mineral leases); 
h. 
Kjessler, et al. v. Zappaaz, Inc., et al., No. 18-CV-00430 (S.D. Tex.) 
(obtained $3.55 million settlement, pending Court approval, as lead class counsel 
on behalf of nationwide group of purchasers alleging suppliers of customized 
promotional products conspired to fix prices);  
i. 
In re Vehicle Carrier Servs. Antitrust Litig., No. 13-cv-3306-ES (D.N.J.) 
(co-lead counsel for class of automobile purchasers against the world’s largest 
maritime vehicle shipping companies alleging price-fixing); and 
j. 
 In re Cedar Shakes and Shingles Antitrust Litig., No. 2:19-CV-00288-MJP 
(W.D. Wash.) (co-lead counsel for class of purchasers of roofing and siding 
materials alleging manufacturers and trade association conspired to artificially 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
stabilize pricing). 
14. 
In addition to the above-mentioned cases, BC has extensive experience 
representing plaintiffs in nationwide mass tort actions.  For example, the firm serves on the 
Plaintiffs’ Executive Committee in In re Johnson & Johnson Talcum Powder Products 
Marketing, Sales Practices, and Products Liability Litigation, No. 3:16-md-02738-FLW-LHG 
(D.N.J.), and it represents a group of hospitals in state courts against the leading manufacturers 
and distributors of opioids for their role in promulgating the nationwide opioid epidemic. 
15. 
More information about BC’s track record of success on behalf of plaintiffs in 
complex class and individual litigation can be found at the firm’s website, 
www.burnscharest.com. 
The BC Team in the Instant Litigation 
16. 
The cases above and BC’s history successfully protecting consumer rights through 
class, mass and individual litigation all demonstrate that BC is well-qualified for the role of 
Interim Co-Lead Class Counsel in this action.  
17. 
I, Christopher J. Cormier, along with my partner, Warren T. Burns, will serve as 
the primary representatives for BC in meetings of Co-Lead Counsel and the Plaintiffs’ Steering 
Committee.   
18. 
I am a 2002 magna cum laude graduate of The American University’s Washington 
College of Law and a 1999 graduate of the University of Virginia (BA in Government).  As a 
partner at BC since 2018, and before that at another nationally recognized plaintiffs class action 
firm since 2011, my practice has focused on antitrust, consumer, false claims, and general 
commercial litigation on behalf of plaintiffs in state and federal courts across the country.  One 
leading industry publication reports that I am “lauded as ‘an excellent competition plaintiff 
lawyer’ who is regularly engaged in high-value antitrust proceedings before state and federal 
courts.”  I have been named one the globe’s top plaintiffs’ antitrust lawyers in the Global 
Competition Review’s Who’s Who Legal: Competition (2020), selected to the Best Lawyers in 
America (2020-2021), honored as a “Rising Star” in the field of Antitrust Litigation by Super 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
Lawyers (2016-2017), and recognized by Benchmark Plaintiff as an “Antitrust Litigation Star” 
(2013-2015).  
19. 
I have gained extensive leadership and trial experience in major class actions 
throughout my career.  For example, in 2013, I served on the trial team, as part of my role as co-
lead counsel, for the plaintiff class in In re Urethane Antitrust Litigation, No. 04-MD-1616 (D. 
Kan.), where I was instrumental in securing a $1.06 billion judgment—believed to be the largest 
ever in a federal price-fixing class action—against Dow Chemical after a month-long trial.  I also 
served as co-lead counsel for the plaintiff class in In re Plasma-Derivative Protein Therapies 
Antitrust Litigation, No. 09-C-7666 (N.D. Ill.), where I obtained $128 million in settlements in 
2013, and in In re Dental Supplies Antitrust Litigation, No. 16-CV-0696 (E.D.N.Y.), where I 
obtained $80 million in settlements in 2019.  I also was personally appointed co-lead counsel in 
In re Anadarko Basin Oil and Gas Lease Antitrust Litigation (discussed above), where I played a 
critical role in steering the case to a $7 million settlement, with the average distribution per class 
member exceeding $2,000, in 2019.  
20. 
In addition to my class action experience, I litigate whistleblower cases focused on 
anticompetitive conduct in the pharmaceutical industry before courts in this District (see U.S. ex 
rel. Silbersher v. Allergan PLC, et al., No. 3:18-cv-03018-JS (N.D. Cal.), and U.S. ex rel. 
Silbersher v. Valeant Pharms. Int’, Inc., et al., No. 3:18-cv-01496-JD (N.D. Cal.), as well as high-
value commercial litigation cases on behalf of institutional clients in the energy sector (see, e.g., 
Liquidating Trustee for the Liquidating Trust of Nighthawk Royalties LLC and Affiliated Debtors 
v. Sigma3 Integrated Reservoir Solutions, et al., No. 2019CV032775 (Arapahoe Cnty. Dist. Ct., 
Colo.), and GT Resources, LLC v. Black Hills Corp., et al., No. 2020CV30751 (Denver Cnty. 
Dist. Ct., Colo)). 
21. 
I am committed to working collaboratively and collegially with my colleagues in 
this case.  I have prior positive experience working with each of the firms proposed to be a part of 
our leadership structure, whether in current or previous cases. 
22. 
In addition to my personal experience and expertise, I will work with my partner, 
Warren T. Burns, who will bring his own wealth of experience to bear here.  
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
23. 
Warren T. Burns is a 2004 summa cum laude graduate of Tulane University 
School of Law, Editor in Chief of the Tulane Law Review, a law clerk to the Hon. Paul J. Kelly, 
Jr. of the U.S. Court of Appeals for the 10th Circuit, and a founder and co-managing partner of 
BC.  He will provide strategic guidance in this matter in addition to playing an active role in 
litigation.  Throughout the course of his career, Mr. Burns has successfully handled numerous 
large and complex class actions, antitrust cases, patent cases, and commercial cases.  A selection 
of his experience in this District includes his position as lead counsel in In re German Automotive 
Manufacturers Antitrust Litigation, No. 17-MD-2796 (N.D. Cal.), and his role as co-counsel for 
the plaintiff relator in U.S. ex rel. Silbersher v. Allergan PLC, et al., No. 3:18-cv-03018-JS (N.D. 
Cal.), and U.S. ex rel. Silbersher v. Valeant Pharms. Int’, Inc., et al., No. 3:18-cv-01496-JD (N.D. 
Cal.).   
24. 
Mr. Burns is lead or co-lead counsel or an executive committee member in many 
of the cases referenced in paragraphs 13-14 above. In addition, he has served as co-lead class 
counsel in In re Automotive Parts Antitrust Litigation, No. 2:12-md-02311 (E.D. Mich.) (co-lead 
counsel who personally negotiated settlements exceeding $100 million with foreign defendants 
while successfully organizing and managing this complex case); lead counsel in Assured 
Guaranty Municipal Corp. v. Flagstar Bank, et al., No. 11-civ-2375-JSR (S.D.N.Y.) (represented 
bond insurer in first case to go to trial related to the residential mortgage backed securities market 
meltdown, resulting in a judgment of over $100 million); co-lead class counsel in In re Universal 
Service Fund Telephone Billing Practices Litig., No. 02-md-1468(D. Kan.) (prevailed at trial on 
breach of contract claim on behalf of AT&T’s California landline customers, securing judgment 
of $16 million); and lead trial counsel in multiple cases against Chesapeake Energy for breach of 
contract and underpayment of royalties relating to the oil and gas lease for the Dallas-Ft. Worth 
International Airport. This track record shows that Mr. Burn is a trial lawyer who successfully 
litigates and tries complex individual and class actions across subject matters. He stands ready to 
do so here. 
25. 
In recognition of his accomplishments, Mr. Burns was named to the Top 100 
National Trial Lawyers in 2015, 2016 and 2020, recognized by Super Lawyers from 2011-15 and 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
again in 2019-20, voted to the International Who’s Who of Competition Lawyers every year since 
2014, and honored in the Best Lawyers in America in 2020-21. He was elected in 2016 to the 
American Law Institute, the leading independent organization in the United States producing 
scholarly work to clarify, modernize, and improve the law. And he is a Fellow of the American 
Bar Foundation, an honorary organization of attorneys, judges, law faculty, and legal scholars 
whose public and private careers have demonstrated outstanding dedication to the welfare of their 
communities and to the highest principles of the legal profession. 
26. 
Mr. Burns is committed to working collaboratively and collegially with his 
colleagues in this matter and has a well-deserved reputation in the bar as a bridge-builder.  He too 
has prior positive experience working with each of the firms proposed to be a part of our 
leadership structure, whether in current or previous cases. 
Plaintiffs’ Steering Committee 
27. 
As Plaintiffs’ Complaint demonstrates, this litigation will be a large undertaking 
and has thus far required ample investigation and attorney efforts.  Plaid’s unlawful collection and 
sale of consumer data dates back to 2013 and continues today, and involves potentially millions 
of users and a trove of data.  See, e.g., Cottle Complaint at ¶¶ 41-45.  As a result, this case will 
likely involve voluminous discovery, which—in order to ensure the security and privacy of the 
plaintiffs and the putative Class members—will require careful review and analysis.  
Furthermore, the complex technological aspects of this case will potentially involve multiple 
experts, including on topics such as mobile app coding, development, and design; cyber- and 
data-security; consumer understanding and associations with bank logos and their facsimiles; 
banking practices; and damage modeling.  Proposed Co-Lead Counsel recognizes that tasks 
associated with these case needs may have to be performed simultaneously, and will require 
substantial input from attorneys with in-depth understanding of the facts and legal issues in this 
case.  Additionally, Proposed Co-Lead Counsel believes that cooperation and collaboration 
between Plaintiffs’ attorneys can afford Plaintiffs and the Class with the best opportunity to 
achieve a meaningful result in this litigation. 
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DECL OF CHRISTOPHER J. CORMIER ISO  
STIPULATION TO CONSOLIDATE ACTIONS AND APPOINT  
INTERIM CO-LEAD CLASS COUNSEL
CASE NO. 4:20-CV-03056-DMR
 
28. 
Thus, in addition to Interim Co-Lead Counsel of Lieff Cabraser Heimann & 
Bernstein, LLP and Herrerra Purdy LLP, Plaintiffs and the class in this litigation will benefit from 
the assistance, experience, and expertise of counsel serving on the Plaintiffs’ Steering Committee 
(“PSC”), which consists of Nussbaum Law Group, P.C.; Reinhardt, Wendorf, & Blanchfield; 
Robins Kaplan, LLP; and Spector Roseman & Kodroff, PC. Descriptions of these firms are found 
in the Declaration of Rachel Geman in Support of Stipulation to Consolidate Actions and Appoint 
Interim Co-Lead Class Counsel, and will not be repeated here in the interest of efficiency and 
brevity. 
29. 
Based on their vast experience and as evidenced by their past successes, it is my 
opinion that Proposed Co-Lead Counsel and the proposed PSC members understand the 
magnitude of personnel and financial resources this case will require and will continue to commit 
their resources to this case.  
30. 
Finally, Proposed Co-Lead Counsel will draw upon more junior attorneys and 
support staff for appropriate tasks so as to prosecute the case as efficiently as possible for the 
benefit of the Class.  Similarly, when Proposed PSC members are called upon to assist in the 
litigation, Proposed Co-Lead Counsel will make sure that tasks are assigned to individuals based 
on their appropriate expertise and skill level, so as to minimize cost to the Class. 
 
I declare under penalty of perjury under the laws of the United States that the foregoing is 
true and correct.  Executed this 17th day of July, 2020, in Washington, DC. 
 
 
 
 
 
 
 
 
Christopher J. Cormier 
 
Case 4:20-cv-03056-DMR     Document 51-3     Filed 07/17/20     Page 11 of 11

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