Motion - Melvin v. Sequencing LLC, 344 F.R.D. 231 (N.D. Ill. 2023) (Illinois Genetic (2024-04-22)

Date: 2024-04-22

Full text

Exhibit B
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BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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Rafey S. Balabanian (SBN 315962)
rbalabanian@edelson.com
EDELSON PC
150 California Street, 18th Floor
San Francisco, California 94111
Tel: 415.212.9300
Fax: 415.373.9435

Counsel for Plaintiffs David Melvin, J.L., and
Putative Class
Jay Edelson (admitted pro hac vice)
jedelson@edelson.com
Ari Scharg (admitted pro hac vice)
ascharg@edelson.com
J. Eli Wade-Scott (admitted pro hac vice)
ewadescott@edelson.com
Michael Ovca (admitted pro hac vice)
movca@edelson.com
Emily Penkowski Perez (admitted pro hac
vice)
epenkowski@edelson.com
Hannah Hilligoss (admitted pro hac vice)
hhilligoss@edelson.com
EDELSON PC
350 North LaSalle Street, 14th Floor
Chicago, Illinois 60654
Tel: 312.589.6370
Fax: 312.589.6378

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

IN RE 23ANDME, INC., CUSTOMER
DATA SECURITY BREACH LITIG.

This Document Relates to:
Melvin et al. v. 23andMe, Inc., Case No. 24-
cv-00487-EMC

Case No. 24-md-03098-EMC

DECLARATION OF RAFEY S.
BALABANIAN IN SUPPORT OF
PLAINTIFFS’ MOTION TO APPOINT
INTERIM LEADERSHIP OF CLASS
ACTION

Judge: Hon. Edward M. Chen

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BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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Pursuant to 18 U.S.C. § 1746, I, Rafey S. Balabanian, hereby declare and state as follows:
1.
I am an attorney admitted to practice law before this Court. I am over the age of 18
and fully competent to make this Declaration. I have personal knowledge of the facts set forth
herein and if called upon to testify as a witness, I could and would competently testify hereto.
2.
I am the Managing Partner and Director of Nationwide Litigation of Edelson PC. My
firm represents Plaintiffs David Melvin and J.L. in the above-captioned case. I submit this
Declaration in Support of Plaintiffs’ Motion to Appoint Interim Leadership of Class Action.
Edelson’s Unparalleled Experience Litigating and Settling Complex Privacy Cases
3.
Edelson PC is a nationally recognized leader in high-stakes plaintiffs’ work, ranging
from class and mass actions to public client investigations and prosecutions. The firm has
repeatedly been recognized by Law360 as Cybersecurity & Privacy Group of the Year (2017, 2018,
2019, 2020, 2022, 2023), Consumer Protection Group of the Year (2016, 2017, 2019, 2020), and a
“Privacy Litigation Heavyweight” and “Cybersecurity Trailblazer” by the National Law Journal
(2016). The National Law Journal also recognized us as “Elite Trial Lawyers” in Consumer
Protection (2020, 2021), Class Action (2021), Privacy/Data Breach (2020), Mass Torts (2020), and
Sports, Entertainment and Media Law (2020). Just considering cases where Edelson PC has served
as lead counsel, Edelson’s verdicts and settlements exceed $5 billion.
4.
The firm’s track record in privacy cases, particularly, is unparalleled. Edelson filed
the first-ever case under the Illinois Biometric Information Privacy Act (“BIPA”), which resulted in
the largest single-state privacy settlement ever at $650 million, which was reached on the eve of
trial. See In re Facebook Biometric Information Privacy Litig., 522 F. Supp. 3d 617 (N.D. Cal.
2021).1 In approving the settlement, Judge Donato of the Northern District of California noted the
“landmark result” achieved for the Class, observing that Edelson and its co-counsel had produced a
“major win for consumers in the hotly contested area of digital privacy.” 522 F. Supp. 3d at 620-
621.
5.
We are also pioneers in litigation under the state genetic information privacy statutes

1
The Robbins Geller firm was Edelson’s co-counsel in that case and have also filed a case
here.
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CASE NO. 24-MD-03098-EMC
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specifically at issue in this case and obtained the first-ever adversarially-certified class under any
such statute. Melvin v. Sequencing LLC, 344 F.R.D. 231 (N.D. Ill. 2023) (Illinois Genetic
Information Privacy Act); see also Cole v. Gene by Gene Ltd., No. 14-cv-00004-SLG (D. Alaska)
(Alaska Genetic Information Privacy Act).
6.
We also hold the record for the largest TCPA privacy settlement at $76 million.
Birchmeier v. Caribbean Cruise Line, Inc., No. 12-cv-04069 (N.D. Ill.).
7.
The firm was lead counsel in Spokeo v. Robins, in which the Supreme Court held that
“intangible harm” could satisfy Article III standing requirements. See 136 S. Ct. 1540 (2016).
Commentators called the case “the most important privacy class action and consumer case of the
decade.”2 Litigating on behalf of the American Civil Liberties Union, we obtained a consent decree
in 2022 that permanently enjoins Clearview from selling access to its massive database of facial
vectors to any private person or company, as well as additional restrictions—a settlement that has
been called a “milestone for civil rights.”3 In short, Edelson PC is the nation’s leading class action
firm on privacy issues, with the firm’s cases “read[ing] like a time capsule of the last decade,
charting how computers have been steadfastly logging data about our searches, our friends, our
bodies.”4
8.
In 2023, Judge Lasnik of the Western District of Washington, in assessing the final
fairness of the firm’s $415 million settlement with an operator of an alleged illegal online casino,
described how the Edelson firm worked “in the Executive branch, the legislative branch, and the
Judicial branch” to secure an extraordinary result for its clients in a “unique” case—describing the
firm as “all in with high quality and very admirable lawyering[.]” Benson v. DoubleDown

2
See John K. Higgins, Supreme Court to Hear ‘Non-Injury’ Privacy Class Action, E-
COMMERCE TIMES (May 6, 2015), https://www.ecommercetimes.com/story/supreme-court-to-hear-
non-injury-privacy-class-action-82015.html.
3
See S.T.O.P. Welcomes Clearview AI, ACLU Settlement, Calls For National Ban,
SURVEILLANCE TECHNOLOGY OVERSIGHT PROJECT (May 9, 2022),
https://www.stopspying.org/latest-news/2022/5/9/stop-welcomes-clearview-ai-aclu-settlement-
calls-for-national-ban.
4
Conor Dougherty, Jay Edelson, the Class-Action Lawyer Who May Be Tech’s Least
Friended Man, N.Y. TIMES (Apr. 4, 2015),
https://www.nytimes.com/2015/04/05/technology/unpopular-in-silicon-valley.html.
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INTERIM LEADERSHIP OF CLASS ACTION

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Interactive LLC, No. 18-cv-00525, dkt. 550 (W.D. Wash. June 22, 2023). This settlement was
reached after the watershed Ninth Circuit victory for consumers against such companies in Kater v.
Churchill Downs Inc., 886 F.3d 784 (9th Cir. 2018). Since then, we have successfully litigated
consumer claims against numerous gambling companies for allegedly profiting from illegal internet
casinos—where we’ve already secured $651 million in cash relief.
9.
An Illinois appellate court recently cited a lower court’s findings that Edelson PC is
“highly experienced and more than competent,” that they had performed “an extraordinary job to
secure the amount of money for the class,” and that the settlement Edelson achieved was “truly an
extraordinary resolution to the great benefit of the class.” McCormick v. Adtalem Global Educ., Inc.
et al., 2022 IL App (1st) 201197-U, ¶ 30. In Barnes v. Aryzta, the court endorsed an expert opinion
finding that we “should ‘be counted among the elite of the profession generally and [in privacy
litigation] specifically’ because of [our] expertise in the area.” No. 17-cv-7358, 2019 WL 277716,
at *3 (N.D. Ill. Jan. 22, 2019); see also In re Facebook Priv. Litig., No. 10-cv-02389, dkt. 69 (N.D.
Cal. Dec. 10, 2010) (former Chief Judge Ware of the Northern District of California, calling the
firm “pioneers” and noting that Edelson has been at the forefront of “some of the largest consumer
class actions in the country” on those issues).
10.
When it comes to trial, the Edelson firm is a leader in actually trying class cases,
including privacy cases specifically. The firm holds the record for the largest-ever jury verdict in a
privacy case at $925 million. Wakefield v. ViSalus, Inc., No. 3:15-cv-1857-SI (D. Or. June 24,
2019).5 And just last year, the firm delivered a historic verdict, establishing liability and punitive
damages on behalf of a class of thousands of Oregon wildfire victims.6 Since then, the damages
trials co-led by Edelson have resulted in $220 million in verdicts to 36 clients, paving the way to

5
The verdict was later vacated, with the Ninth Circuit holding that the lower court had to
consider whether the damages awarded by the jury potentially violated due process. Wakefield v.
ViSalus, Inc., 51 F.4th 1109, 1125 (9th Cir. 2022).
6
Jonathan Stempel, Jury says Berkshire’s PacifiCorp owes punitive damages for 2020
Oregon wildfires, REUTERS (June 14, 2013), https://www.reuters.com/sustainability/jury-says-
berkshires-pacificorp-owes-punitive-damages-2020-oregon-wildfires-2023-06-14.
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CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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tens of billions in class-wide damages.7
Edelson’s Long Track Record Leading Consolidated Litigation
11.
The firm has significant experience leading aggregated litigation in challenging cases
presenting complex, novel issues of law.8 The firm (and I specifically) were among those who
served the Tort Claimants’ Committee in one of the largest and most complex bankruptcies in the
history of the country involving the giant West Coast utility PG&E, which resulted in a $13.5
billion settlement for the firm’s clients—fire victims. As discussed above, we successfully certified
a class for victims of the Labor Day 2020 wildfires in Portland to litigate the issue of liability and
punitive damages class-wide—prevailing on each of those issues at trial after years of litigation. See
James v. PacifiCorp, No. 20CV33885 (Multnomah Cnty. Ct., Or.).
12.
We frequently represent states in multistate investigations and litigation, including
the District of Columbia against JUUL for deceptive trade practices, and New Hampshire, Utah, and
the District of Columbia against social media companies for harming a generation of their citizens
with social media addiction. The firm (and I specifically) have been appointed interim lead counsel
in multidistrict litigation against platforms over their hosting of alleged illegal casinos. See In re
Apple Inc. App Store Simulated Casino-Style Games Litig., No. 21-md-02985-EJD (N.D. Cal.); In
re Google Play Store Simulated Casino-Style Games Litig., No. 21-md-03001-EJD (N.D. Cal.); In
re Facebook Simulated Casino-Style Games Litig., No. 21-cv-02777-EJD (N.D. Cal.). Each of these
cases involved myriad issues of first impression, in which the firm successfully worked within
coalitions (and are still doing so) to deliver extraordinary results to our clients.

7
Amanda Bronstad, Another Oregon Wildfire Verdict Brings PacifiCorp’s Total Damages to
Over $220M, Law.com (March 05, 2024), https://www.law.com/2024/03/05/another-oregon-
wildfire-verdict-brings-pacificorps-total-damages-to-220m/.
8
As discussed in our earlier brief, the Edelson firm (and I in particular) are experienced in
working with other firms to lead consolidated litigation. But should the Court wish to appoint more
firms, we encourage the Court to keep efficiency at the forefront of that decision-making. All too
often, a large slate of firms will make promises that they can efficiently litigate a case, but what
results is actually the plaintiffs’ equivalent of “churning the file” in order to justify a fee award
(both generally and to the particular firm). We have criticized this practice openly. See In re Tiktok,
Inc. Consumer Privacy Litig., No. 20-cv-4699, dkt. 212 at 13 (N.D. Ill. Apr. 14, 2022). This case
can, and should, be efficiently litigated by a single or co-lead.
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BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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Edelson’s Team Is Uniquely Equipped to Handle This Litigation
13.
As noted above, I am Edelson PC’s Managing Partner and Director of Nationwide
Litigation. I have the subject matter and complex, aggregate litigation experience to provide
effective leadership here. I have been appointed as lead class counsel in dozens of class actions in
state and federal courts across the country and have resolved numerous cases to the benefit of the
clients and classes I have represented. While much of my prior work will inform and support my
efforts here—detailed in Edelson PC’s firm resume, a true and correct copy of which is attached
hereto as Exhibit A—some are worth highlighting. First, I was one of the principal attorneys
representing Plaintiffs in the In re Facebook Biometric Information Privacy Litigation matter, in
which I was central to securing adversarial class certification and reaching a record-breaking
settlement on the eve of trial—demonstrating my expertise in privacy actions and ability to secure
excellent results for the class. Second, I have significant experience leading complex cases: I was
one of the attorneys who served on the Tort Claimant Committee in the PG&E bankruptcy and had
a significant role in helping reach a $13.5 billion settlement on behalf of fire victims, and I was
appointed interim lead counsel in the consolidated litigation seeking to hold technology platforms
liable for their hosting of illegal online casinos. My familiarity with pressing difficult issues of law
alongside other counsel will serve this class well.
14.
The team working on this matter at Edelson PC includes Jay Edelson, J. Eli Wade-
Scott, Michael Ovca, Emily Penkowski Perez, and Hannah Hilligoss. Each of these individuals’
experience is set forth in full in the firm’s resume, but a few particulars are again worth highlighting
here:
• Jay Edelson. Jay Edelson—the firm’s Founder and CEO—has been one of the
central figures in the development of modern consumer privacy law. An adjunct privacy
professor at UC Berkeley School of Law, he’s been described by the New York Times as
“Tech’s Least-Friended Man,”9 and called “probably the best known, and most innovative,

9
Dougherty, supra n.4.
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consumer privacy lawyer on the planet.”10 Mr. Edelson has been named three times as a
“Titan of the Plaintiff’s Bar” by Law360 (2014, 2021, and 2023), has been consistently
recognized both inside and outside the legal profession for his groundbreaking privacy work,
and was profiled as one of Fast Company’s “Most Creative People in Business”—the first
plaintiffs’ attorney to ever receive the award.11 Equally important, Mr. Edelson has been the
leading voice of the reform wing of the plaintiffs’ bar.12 Mr. Edelson has, and will, leverage
his unique skillset in this litigation to focus on the development of applicable claims to these
unprecedented facts, as well as litigation and negotiation strategy.
• J. Eli Wade-Scott (Harvard Law School ’14, magna cum laude). Mr. Wade-Scott is
the firm’s director of class action litigation and has been appointed class counsel in dozens
of privacy actions. He has delivered hundreds of millions of dollars to consumers in privacy
cases—always with strong settlement structures that drive unprecedented class engagement
in claiming their money at the time of settlement. Indeed, Mr. Wade-Scott is a pioneer when
it comes to the use of direct checks in privacy cases, setting a standard followed by
numerous subsequent settlements. Mr. Wade-Scott also represents governments in cases
pressing first-impression privacy issues, including on behalf of the District of Columbia
against Facebook in its litigation arising from Cambridge Analytica and on behalf of New
Mexico against Google for violations of the Children’s Online Privacy Protection Act. Mr.
Wade-Scott has been recognized as a Rising Star of the Plaintiffs’ Bar for three consecutive
years by the National Law Journal, and was profiled by Bloomberg Law as one of “Five

10
Eric Troutman, Deserve to Win Podcast (July 18, 2022),
https://www.natlawreview.com/article/deserve-to-win-ep-3-jay-edelson-now-available-we-talk-
dobbs-javier-and-privacy.
11
Meet the lawyer who stood between Big Tech and your facial recognition data, FAST
COMPANY (Aug. 9, 2022), https://www.fastcompany.com/90764561/jay-edelson-most-creative-
people-2022.
12
Christine Schiffner, Jay Edelson in a ‘Battle for the Soul of the Plaintiffs Bar’, LAW.COM
(Sept. 19, 2022), https://www.law.com/nationallawjournal/2022/09/19/jay-edelson-in-a-battle-for-
the-soul-of-the-plaintiffs-bar/.
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BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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Fresh Faces to Know in Privacy and Cybersecurity.”13 Mr. Wade-Scott will assist Mr.
Balabanian in leading the litigation and managing the nuts-and-bolts work of day to day
class action practice, from crafting discovery strategies to settlement structure.
• Michael Ovca (Northwestern Law School ’17, cum laude). Mr. Ovca has been one
of the firm’s lead associates on technology and privacy matters since he began at Edelson in
2017 and has worked on or led more than two dozen privacy and technology actions at the
firm. Most notably, Mr. Ovca was recently the lead associate in securing the first-ever
adversarially-certified class under any state’s genetic privacy law in Melvin v. Sequencing,
Inc., 344 F.R.D. 231 (N.D. Ill. 2023) and was appointed class counsel there.
• Emily Penkowski Perez (Northwestern Law School ’20, cum laude). Ms.
Penkowski Perez not only brings substantial experience from her work on more than ten
technology/privacy actions at the firm, including her work representing the District of
Columbia in its groundbreaking action against Facebook, but also the singular perspective of
someone who has worked as an intelligence analyst for the National Security Agency, in the
Office of Counterintelligence & Cyber (previously the NSA/CSS Threat Operations Center)
and the Office of Counterterrorism. Ms. Penkowski is routinely pulled into matters in which
the firm can leverage her unique expertise.
• Hannah Hilligoss (Harvard Law School ’22, cum laude). Ms. Hilligoss’s practice
focuses on privacy and technology actions at the firm, where she has worked on numerous
technology and privacy actions since beginning at the firm. Prior to joining Edelson, Ms.
Hilligoss worked at Harvard’s Berkman Klein Center for Internet and Society, where she
authored several papers on ethics and governance in new technologies, particularly artificial
intelligence, and led a working group of Harvard faculty focused on ethical technology
development. Ms. Hilligoss’s proven ability to parse technological and privacy issues
without precedent and determine how law and policy should address them will yield

13
Andrea Vittorio, They’ve Got Next: Privacy and Cybersecurity Fresh Face Eli Wade-Scott,
BLOOMBERG LAW (Oct. 29, 2021), https://news.bloomberglaw.com/business-and-practice/theyve-
got-next-privacy-and-cybersecurity-fresh-face-eli-wade-scott.
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INTERIM LEADERSHIP OF CLASS ACTION

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significant dividends for the Class.
15.
To be clear, Edelson is not asking for this entire team of attorneys to be appointed
lead counsel—that is appropriately settled on the shoulders of one final decision-maker or organized
with a co-lead—but to highlight the depth and variety of experience that the firm brings to the case.
And the firm has resources to address every phase of the case: in addition to the dedicated
investigations and in-house forensic investigations team, as well as the deep bench of litigators
assigned to the case, the firm also has a dedicated appellate team, a dedicated trial team, and a
dedicated government affairs team (which is often pulled in if the case involves legislative
skirmishes or if the firm needs to coordinate with governmental actors).
16.
Particularly relevant is that Edelson boasts a unique-in-the-industry forensic
investigations team headed by Shawn Davis. Mr. Davis holds numerous certifications relevant to
this data breach case, including ISC2 CISSP, GIAC Forensic Examiner, and GIAC Incident Handle
(among many others). Mr. Davis serves as an in-house technical expert for the firm, including by
testifying at trial in federal court, and routinely being asked to testify before legislative bodies on
critical areas of emerging artificial intelligence, cybersecurity, and privacy. In 2020, Mr. Davis was
appointed by the Executive Office of the President to the Federal Government Advisory Committee
on Data for Evidence Building with the U.S. Department of Commerce for a two-year term. This
resource, along with the firm’s substantial subject-matter expertise, allows the firm to routinely
undertake in-house (1) complex reviews of novel and proprietary technology, (2) security
assessments, and (3) the investigation and analysis of highly confidential and complex source
code—all technical issues that have already and will continue to present themselves in this case.
17.
Nor, simply put, does the firm lack the material resources to contend with a well-
financed adversary. We’ve recovered billions of dollars for the firm’s clients, but equally important,
have demonstrated that the firm has been run soundly from a financial point of view: A good
marker is to look at how firms weathered the COVID-19 pandemic; while many plaintiffs’ firms
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BALABANIAN DECL. ISO MOT. TO APPOINT

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INTERIM LEADERSHIP OF CLASS ACTION

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(either properly or not)14 competed against their clients to take large Paycheck Protection Program
loans, our firm did not—and in fact, continued with its commitment to grow and increased salaries
and benefits for our employees. Our finances allow us to compete on price, too: we will cap any fee
request at 20% of what is actually received by the Class.
18.
A corollary factor relevant to the Class is a firm’s ability to attract the best talent.
(See Mot. to Appoint Interim Leadership, Ex. 2 (“Data Sheet”) at 20 (44% of the Class ranking this
“Very Important”).) Acknowledging that the concept of the most talented attorneys is somewhat
subjective, our firm is able to recruit top students from top law schools the old-fashioned way: by
paying associate salaries that out-pace BigLaw. It certainly doesn’t hurt that we do interesting work
that matters to our attorneys, but that’s a subject not immediately relevant to this Motion.
The Survey and Explanatory Page
19.
Our firm took the unique step of retaining Professors Alissa del Riego, J.D., and
Joseph Avery, Ph.D. and J.D., to conduct a survey of class member preferences for the lead of this
litigation: specifically, what strategies they’d like their counsel to adopt and what characteristics the
lead firm should have. This survey follows the professors’ existing work arguing that class counsel
should make efforts to communicate with the class and objectively ascertain their preferences. See
Alissa del Riego & Joseph Avery, The Class Action Megaphone: Empowering Class Members with
an Empirical Voice, 76 Stan. L. Rev. Online 1 (2023); Alissa del Riego & Joseph Avery,
Inadequate Adequacy?: Empirical Studies on Class Member Preferences of Class Counsel, 2024
Utah L. Rev. 499 (2024).
20.
As argued in the brief, we believe we uniquely fit what the Class is looking for.

14
A list of PPP loan recipients is publicly available at: PPP Borrower Search, PANDEMIC
OVERSIGHT, https://www.pandemicoversight.gov/ppp-simple-search-landing (last visited Apr. 17,
2024). Under the PPP program, a firm had to attest that the loan was necessary in light of the firm’s
finances and access to other capital. See Small Bus. Admin., Paycheck Protection Program Loans
Frequently Asked Questions, at No. 31 (July 29, 2021),
https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-
Questions.pdf. Many firms took PPP money while at the same time telling courts that they were
financially sound—both can’t be true.

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BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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Other firms are, of course, welcome to meet these preferences too. That said, and while we don’t
know exactly who will move for lead, many of the firms who have filed cases here simply do not
have deep experience in privacy actions, almost none can say they have experience in genetic
privacy cases, and they do not have a comparable track record of putting together strong
settlements.
21.
In addition to the survey, we’ve taken case-specific steps to communicate with the
Class. Edelson raised the alarm about 23andMe’s newly-announced strategy to broadly sell users’
data to third parties to help stem its apparent current cash crunch. (Melvin v. 23andMe, Inc., No. 24-
cv-00487-EMC, dkt. 27-1 (N.D. Cal.).) 23andMe had not said who the third parties were, what
measures would be in place to protect users, nor provided assurances as to how this plan didn’t
break the law—and still hasn’t. (Id.) The Court at the time viewed that issue as beyond the ambit of
the currently-pleaded complaint, which Edelson intends to amend to include. (See Melvin, dkt. 38,
Tr. at 32:4–12.) But Plaintiffs’ counsel still wanted to arm class members with the information they
needed to protect themselves, so we set up an explanatory webpage and launched an advertising
campaign to alert 23andMe customers that they may be enrolled in 23andMe’s data-sharing without
knowing it, and provided instructions on how they could opt-out.15 We got this information into the
hands of more than three million people, and our short explainer video was organically shared more
than 3,000 times on Facebook. We also attempted to work with 23andMe’s counsel to make the
process of opting out less onerous, but that effort was rebuffed.
Our Commitment to Class-Benefitting Settlement Structures and Increasing Claims Rates
22.
When it comes to litigation outcomes, the Edelson firm has been a prominent voice
for cash relief (versus credit monitoring or illusory reversionary funds) in settlements, and the
numbers speak for themselves: a total of $13.5 billion in PG&E for tort claimants, $650 million in
Facebook, $651 million and counting in internet-casino litigation, $76 million in Birchmeier, and
others. When it comes to smaller settlements, we take the same view: indeed, we were the first to
use direct checks to send out cash relief in privacy cases—there, BIPA cases filed against

15
23andMe Data Opt-Out, EDELSON PC, https://edelson.com/23andMe-data-opt-out (last
visited Apr. 17, 2024).
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11
BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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employers—establishing a higher water mark in those cases that every subsequent settlement had to
follow.
23.
We’ve also shined a spotlight on an issue that so often gets swept under the rug,
which is settlement claims rates. This matters to the Class: the Class ranked claims rates just behind
the monetary relief itself in importance. (See Mot. to Appoint Interim Leadership, Ex. 2, Data Sheet,
at 7.) Our firm routinely posts claims rates of 20% or more by designing notice and claims
processes to get real engagement from the Class, as set forth below:

CASE
CLAIMS RATE
Villagomez v. iSolved HCM, Inc.,

No. 19-CH-12932 (Cir. Ct. Cook Cnty. May 11, 2023)
45.2%
LaBarre v. Ceridian HCM, Inc.,

No. 19-CH-0648 (Cir. Ct. Cook Cnty. Nov. 30, 2022)
34.47%
Dickey v. Advanced Micro Devices, Inc.,

No. 15-cv-04922 (N.D. Cal.)
27.3%
Figueroa v. Kronos Incorporated,

No. 19-cv-01306 (N.D. Ill. Dec. 20, 2022)
26.78%
Lukis v. Whitepages, Inc.,

No. 19-cv-04871 (N.D. Ill. Sept. 28, 2022)
Two classes: 25% &
17%, respectively
Neals v. ParTech, Inc.,

No. 19-cv-05660 (N.D. Ill. July 20, 2022)
23.86%
In re Facebook Biometric Info. Priv. Litig.,

No. 15-cv-3747 (N.D. Cal. Feb. 26, 2021)
22%
Crumpton v. Octapharma Plasma, Inc.,

No. 19-cv-08402 (N.D. Ill. Feb. 16, 2022)
22%
Sosa v. Onfido, Inc.,

No. 20-cv-04247 (N.D. Ill. Dec. 4, 2023)
Two classes: 18.3% &
20.1%, respectively
Fischer v. Instant Checkmate LLC
No. 19-cv-04892 (N.D. Ill. Jan. 24, 2024)
More than 15% across
seven settlement
classes, with the
second-largest class
achieving 20%
Kusinski v. ADP LLC,

No. 17-CH-12364 (Cir. Ct. Cook Cnty. Feb. 10, 2021)
12.7%
Krause v. RocketReach, LLC,

No. 21-cv-1938 (N.D. Ill. Sept. 12, 2023)
12.11%
24.
We proactively address this issue in our settlements. In a recent settlement, Fischer,
the claims rate prior to final approval was stalling at 2.59%. Despite the likelihood that such a rate
would be approved, and with no objectors in the wings, the firm decided to ask for more time—
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12
BALABANIAN DECL. ISO MOT. TO APPOINT

CASE NO. 24-MD-03098-EMC
INTERIM LEADERSHIP OF CLASS ACTION

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delaying our fees, naturally—to try to drive a better claims rate. See Fischer v. Instant Checkmate
LLC, No. 19-cv-04892, dkt. 274 (N.D. Ill. Nov. 17, 2023); see also Allison Grande, Class Counsel
Gets Time to Grow Participation in Privacy Deal, LAW360 (Nov. 22, 2023),
https://www.law360.com/articles/1769616/class-counsel-gets-time-to-grow-participation-in-
privacy-deal. Edelson ultimately reported an aggregate claims rate of more than 15% across seven
settlement classes, with the second-largest class reaching a 20% claims rate. Fischer, No. 19-cv-
04892, dkt. 283-3, ¶ 16 (N.D. Ill. Jan. 24, 2024).
25.
Because we believe this is such an important issue, we will commit to seek the lesser
of 20% of the actual benefits to the class or the percent of valid claims. I declare under penalty of
perjury under the laws of the United States of America that the foregoing is true and correct.
Executed this 18th day of April 2024, at San Francisco, California.

/s/ Rafey S. Balabanian
Rafey S. Balabanian

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EXHIBIT A
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“National reputation as a maverick in [its]
commitment to pursuing big-ticket . . .
cases."
—Law360
★ ★ ★ ★ ★ ★ ★
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Table of Contents
Who We Are

5
In the News

7
Plaintiﬀ's Class and Mass Action Practice

General Mass/Class Tort Litigation

Environmental Litigation

Banking, Lending, and Finance Litigation

Privacy and Data Security Litigation

General Consumer Litigation

Insurance Matters

Public Client Litigation and Investigations

18
General Commercial Matters

20
Executive Committee

Founder & CEO

Global Managing Partner

Managing Partner, Boulder

Managing Partner, Chicago

Cheif Information Oﬃcer
30

Chief of Staﬀ

Director of Human Resources

Partners

Ryan D. Andrews

Natasha Fernández-Silber

34
Amy B. Hausmann

35
J. Aaron Lawson
36

Todd Logan

David I. Mindell

Roger Perlstadt

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Table of Contents

Jimmy Rock

Nicholas Rosinia

Yaman Salahi

Ari Scharg

Alexander G. Tievsky

J. Eli Wade-Scott

45
Brandt Silver-Korn

Schuyler Ufes

Aaron Colangelo

48
Of Counsel
49
Senior Litigation Counsel
50
Associates

Theo Benjamin

Lauren Blazing
52

Megan Delurey
53

Hannah Hilligoss
54

Michael Ovca

Emily Penkowski

Albert J. Plawinski

Zoë Seaman-Grant
58

Julian Li-Ying Zhu

59
Jean Larsen

60
Dan Kieselstein

61
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We hold records for the largest jury verdict in a privacy case ($925m), the
largest single-state consumer privacy settlement ($650m), and the largest
TCPA settlement ($76m). We also secured one of the most important
consumer privacy decisions in the U.S. Supreme Court (Robins v. Spokeo).
Our class actions, brought against the national banks in the wake of the
housing collapse, restored over $5 billion in home equity credit lines. We
served as counsel to a member of the 11-person Tort Claimant’s Committee
in the PG&E Bankruptcy, resulting in a historic $13.5 billion settlement. We
are the only ﬁrm to have established that online apps can constitute illegal
gambling under state law, resulting in settlements that are collectively worth
$651 million. We are co-lead counsel in the NCAA personal injury concussion
cases, leading an MDL involving over 300 class action lawsuits. And we
are representing, or have represented, regulators in cases involving the
deceptive marketing of opioids, environmental cases, privacy cases against
Facebook, Uber, Google and others, cases related to the marketing of
e-cigarettes to children, and cases asserting claims that energy companies
and for-proﬁt hospitals abused the public trust.
We have testiﬁed before the United States Senate and state legislative
and regulatory bodies on class action and consumer protection issues,
cybersecurity and privacy (including election security, children’s privacy and
surreptitious geotracking), sex abuse in children’s sports, and gambling,
and have repeatedly been asked to work on federal, state, and municipal
legislation involving a broad range of issues. We speak regularly at seminars
on consumer protection and class action issues, and routinely lecture at law
schools and other graduate programs.
We have a “one-of-a-kind” investigation team that sets us apart from others
in the plaintiﬀ's bar. Our dedicated “internal lab of computer forensic
engineers and tech-savvy lawyers” investigate issues related to “fraudulent
software and hardware, undisclosed tracking of online consumer activity
and illegal data retention,” among numerous other technology related issues
facing consumers. Cybersecurity & Privacy Practice Group of the Year,
Law360 (January 2019).
EDELSON PC is a law ﬁrm concentrating on high stakes plaintiﬀ’s work
ranging from class and mass actions to public client investigations and
prosecutions. The cases we have litigated —as either lead counsel or as
part of a broader leadership structure —have resulted in settlements and
verdicts totaling over $45 billion.
Who We Are
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Instead of chasing the headlines, our case development team
is leading the country in both identifying emerging privacy and
technology issues, as well as crafting novel legal theories to match.
Some examples of their groundbreaking accomplishments include:
demonstrating that Microsoft and Apple were continuing to collect
certain geolocation data even after consumers turned “location
services” to “oﬀ”; ﬁling multiple suits revealing mobile apps that
“listen” through phone microphones without consent; ﬁling a lawsuit
stemming from personal data collection practices of an intimate IoT
device; and ﬁling suit against a data analytics company alleging that it
had surreptitiously installed tracking software on consumer computers.
As the Hollywood
Reporter explained,
we are “accustomed
to big cases that have
lasting legacy.”
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In the News
The firm and our attorneys regularly get recognized for our groundbreaking work. We have been named by Law360
as a Consumer Protection Group of the Year (2016, 2017, 2019, 2020), a Class Action Group of the Year (2019), a
Plaintiff's Class Action Powerhouse (2017, 2018, 2019), a Cybersecurity and Privacy Group of the Year (2017, 2018,
2019, 2020, 2022, 2023), a "Privacy Litigation Heavyweight," a "Cybersecurity Trailblazer" by The National Law
Journal (2016) and won sole recognition in 2019 as "Elite Trial Lawyers" in Gaming Law. The National Law Journal
also recognized us as "Elite Trial Lawyers" in Consumer Protection (2020, 2021), Class Action (2021), Privacy/Data
Breach (2020), Mass Torts (2020), and Sports. Entertainment and Media Law (2020). In 2019, we were recognized
for the third consecutive year as an "Illinois Powerhouse," alongside Barack Ferrazzano. Winston & Strawn, Schiff
Hardin and Mayer Brown; in each year, we were the only plaintiff's firm, and the only firm with fewer than one
hundred lawyers, recognized. Edelson was a two time finalist (2021 and 2022) and one-time winner of the Diversity
Initiative Award (2021) by The National Law Journal. given to the plaintiffs firm demonstrating a concerted and
successful effort to promote diversity within its organization and the profession at large.
Our founder has been repeatedly recognized as a "Titan of the Plaintiff's Bar"
by Law360, one of "America's Top 200 Lawyers" by Forbes in 2024, one of
"America's top trial lawyers" in the mass action arena. a LawDragon 2020
and 2023 Leading Plaintiff Financial Lawyer, a top "Class Action and Mass
Tort Plaintiff's" Lawyer in Illinois by Leading Lawyers. one of "Chicago's Top
Ten Startup Founders Over Age 45" by Tech.Co (the only law firm founder to
win such an award) and as one of Fast Company's "Most Creative People in
Business"-the
first plaintiffs' attorney to ever recieve the award.
We have also been recognized by courts for our approach to litigation,
which led the then-Chief Judge of the United States Court for the Northern
District of Illinois to praise our work as "consistent with the highest standards
of the profession" and "a model of what the profession should be .... " In re
Kentucky Grilled Chicken Coupon Mktg. & Sales Practs. Litig., No. 09-cv-
07670, MDL 2103 (N.D. Ill. Apr. 04, 2012). Likewise, in appointing our firm
interim co-lead in one of the most high-profile banking cases in the country,
a federal court pointed to our ability to be "vigorous advocates, constructive
problem-solvers, and civil with their adversaries." In Re JPMorgan Chase
Home Equity Line of Credit Litig .. No. 10-cv-3647 (N.D. Ill. July 16, 2010).
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Representative cases and settlements include:
Serving as lead trial counsel, our ﬁrm secured a historic classwide jury verdict on behalf
of survivors of the 2020 Labor Day Fires in Oregon establishing classwide liability and
punitive damages—the ﬁrst known jury verdict holding a utility provider, PaciﬁCorp,
accountable for a wildﬁre. (James v. PaciﬁCorp, No. 20-CV-33885). So far in subsequent
damages trials, we have secured $220 million in damages to 36 plaintiﬀs, charting a
course to billions in liability.
Representing over 1,000 victims of the Northern California “Camp Fire,” allegedly caused
by utility company Paciﬁc Gas & Electric. Served as counsel to a member of the 11-person
Tort Claimants' Committee in the PG&E Bankruptcy, resulting in a historic $13.5 billion
settlement.
We currently represent hundreds of survivors of the Marshall Fires in Colorado.
In re Nat’l Collegiate Athletic Ass’n Single School/Single Sport Concussion Litig., No. 16-
cv-8727, MDL No. 2492 (N.D. Ill.): Appointed co-lead counsel in MDL against the NCAA, its
conferences, and member institutions alleging personal injury claims on behalf of college
football players resulting from repeated concussive and sub-concussive hits.
We currently represent, among others, classes of student athletes dealing
with the long-term eﬀects of concussive and sub-concussive injuries,
hundreds of families experiencing adverse eﬀects of air and water
contamination in their communities, individuals aﬀected by the “Camp Fire”
in Northern California, and victims of the 2020 Labor Day ﬁres in Oregon.
General Mass/Class Tort Litigation
Our Practice
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We represent hundreds of families harmed by the damaging eﬀects of
ethylene oxide exposure in their communities, consumers and businesses
whose local water supply was contaminated by a known toxic chemical,
and property owners impacted by the ﬂightpath of Navy ﬁghter planes.
Representative cases and settlements include:
Representing three state Attorneys General in their investigations into contamination
and exposure issues resulting from a “forever chemical” commonly referred to as
PFAS.
Representing a state Attorney General in investigating and potentially litigating
matters related to the problematic use of a pesticide used in homes, on agricultural
crops, lawns, and gardens, and as a fumigating agent—that is now known to have
contaminated soil and groundwater.
Representing hundreds of individuals around the country that are suﬀering the ill-
eﬀects of ethylene oxide exposure —a gas commonly used in medical sterilization
processes. We have brought over 100 personal injury and wrongful death cases
against EtO emitters across the country, as well as numerous medical monitoring class
actions. Brincks et al. v. Medline Indus., Inc., et al., No. 2020-L-008754 (Cir. Ct. Cook
Cty., Ill.); Leslie v. Steris Isomedix Operations, Inc., et al., No. 20-cv-01654 (N.D. Ill.);
Jackson v. 3M Company, et al., No. 19-cv-00522 (D.S.C.).
Representing hundreds of individuals who have been exposed through their own
drinking water and otherwise to PFAS and related "forever chemicals" used in various
applications. This exposure has allegedly led to serious health issues, including
cancer, as well as the devaluation of private property due to, among other things, the
destruction of the water supply. In conjunction with our work in this space, we have
been appointed to the Plaintiﬀ's Executive Committee in In re: Aqueous Film-Forming
Foams (AFFF) Prods. Liability Litig., 18-mn-2873-RMG, MDL No. 2873 (D.S.C.).
Representing property owners on Whidbey Island, Washington, whose homes sit
directly in the ﬂightpath of dozens of Navy ﬁghter planes. The Navy is alleged to have
signiﬁcantly increased the number of these planes at the bases at issue, as well as
the frequency of their ﬂights, to the detriment of our clients’ privacy and properties.
Pickard v. USA, No. 19-1928L (Ct. Fed. Claims); Newkirk v. USA, No. 20-628L (Ct. Fed.
Claims).
Resprensenting punitive class of students who were exposed to polychlorinated
biphenyls (PCBs) while attending contaminated schools in Vermont under Vermont's
groundbreaking statute providing for medial monitoring. Neddo v. Monsanto, 23-cv-
396 (D.Vt.)
Mass Action Practice
Environmental Litigation
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We were at the forefront of litigation arising from the aftermath of the federal
bailouts of the banks. Our suits included claims that certain banks unlawfully
suspended home credit lines based on pretextual reasons, and that certain
banks failed to honor loan modiﬁcation programs. We achieved the ﬁrst
federal appellate decision in the country recognizing the right of borrowers
to enforce HAMP plans under state law. The court noted that “[p]rompt
resolution of this matter is necessary not only for the good of the litigants
but for the good of the Country.” Wigod v. Wells Fargo Bank, N.A., 673 F.3d
547, 586 (7th Cir. 2012) (Ripple, J., concurring). Our settlements restored
billions of dollars in home credit lines to people throughout the country.
Representative cases and settlements include:
In re JP Morgan Chase Bank Home Equity Line of Credit Litig., No. 10-cv-3647 (N.D.
Ill.): Co-lead counsel in nationwide putative class action alleging illegal suspensions
of home credit lines. Settlement restored between $3.2 billion and $4.7 billion in
credit to the class.
Hamilton v. Wells Fargo Bank, N.A., No. 09-cv-04152-CW (N.D. Cal.): Lead counsel in
class actions challenging Wells Fargo’s suspensions of home equity lines of credit.
Nationwide settlement restored access to over $1 billion in credit and provides
industry leading service enhancements and injunctive relief.
In re Citibank HELOC Reduction Litig., No. 09-cv-0350-MMC (N.D. Cal.): Lead counsel
in class actions challenging Citibank’s suspensions of home equity lines of credit.
The settlement restored up to $653 million worth of credit to aﬀected borrowers.
Wigod v. Wells Fargo, No. 10-cv-2348 (N.D. Ill.): Obtained ﬁrst appellate decision
in the country recognizing the right of private litigants to sue to enforce HAMP
plans. Settlement provided class members with permanent loan modiﬁcations and
substantial cash payments.
Mass Action Practice
Banking, Lending, and Finance Litigation
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The New York Times has explained that our “cases read like a time capsule
of the last decade, charting how computers have been steadfastly logging
data about our searches, our friends, our bodies.” Courts have described
our attorneys as “pioneers in the electronic privacy class action ﬁeld,
having litigated some of the largest consumer class actions in the country
on this issue.” See In re Facebook Privacy Litig., No. 10-cv-02389 (N.D.
Cal. Dec. 10, 2010) (order appointing us interim co-lead of privacy class
action); see also In re Netﬂix Privacy Litig., No. 11-cv-00379 (N.D. Cal. Aug.
12, 2011) (appointing us sole lead counsel due, in part, to our “signiﬁcant and
particularly specialized expertise in electronic privacy litigation and class
actions”). In Barnes v. Aryzta, No. 17-cv-7358 (N.D. Ill. Jan. 22, 2019), the court
endorsed an expert opinion ﬁnding that we “should ‘be counted among
the elite of the profession generally and [in privacy litigation] speciﬁcally’
because of [our] expertise in the area.”
Representative cases and settlements include:
In re Facebook Biometric Privacy Litig., No. 15-cv-03747 (N.D.
Cal.): Filed the ﬁrst of its kind class action against Facebook under
the Illinois Biometric Information Privacy Act, alleging Facebook
collected facial recognition data from its users without authorization.
Appointed Class Counsel in securing adversarial certiﬁcation of
class of Illinois Facebook users. Case settled on the eve of trial for a
record breaking $650 million.
Wakeﬁeld v. Visalus, No. 15-cv-01857 (D. Ore. Apr. 12, 2019): Lead
counsel in class action alleging that defendant violated federal law
by making unsolicited telemarketing calls. Obtained jury verdict and
judgment equating to more than $925 million in damages to the
class. (The verdict was vacated on appeal in the Ninth Circuit, with
instructions to determine whether the result violated Due Process.
Mass Action Practice
Privacy and Data Security
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Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016): Lead counsel in the
landmark case aﬃrming the ability of plaintiﬀs to bring statutory
claims for relief in federal court. The United States Supreme Court
rejected the argument that individuals must allege “real world”
harm to have standing to sue in federal court; instead the court
recognized that “intangible” harms and even the “risk of future
harm” can establish “standing.” Commentators have called Spokeo
the most signiﬁcant consumer privacy case in recent years.
Birchmeier v. Caribbean Cruise Line, Inc., et al., No. 12-cv-4069
(N.D. Ill.): Co-lead counsel in class action alleging that defendant
violated federal law by making unsolicited telemarketing calls.
On the eve of trial, the case resulted in the largest Telephone
Consumer Protection settlement to date, totaling $76 million.
Satterﬁeld v. Simon & Schuster, Inc., 569 F.3d 946 (9th Cir.
2009): Won ﬁrst ever federal decision ﬁnding that text messages
constituted “calls” under the TCPA. In total, we have secured text
message settlements worth over $100 million.
Secured key victories establishing the liability of employers and
vendors under the Illinois Biometric Information Privacy Act,
resulting in the largest-ever settlement with a timeclock vendor
($25 million), the largest-ever settlement with a technology vendor
($28.5 million), and more than $100 million in total settlements.
Dunstan v. comScore, Inc., No. 11-cv-5807 (N.D. Ill.): Lead counsel
in certiﬁed class action accusing Internet analytics company of
improper data collection practices. The case settled for $14 million.
Mass Action Practice
Privacy and Data Security
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American Civil Liberties Union et al. v. Clearview AI, Inc., No. 2020-
CH-04353 (Cir. Ct. Cook Cty., Ill.): Successfully represented ACLU
and other public interest organizations as lead outside counsel
in a lawsuit adainst Clearview, Inc., resulting in consent decree.
The conscent decree permanently enjoins Clearview from selling
access to its massive database of facial vertors to any private
person or company, as well as prohibits Clearview from sales
to any entity within Illinois for ﬁve years, including government
agencies or police departments. The settlement has been called a
“milestone for civil rights.”
Mocek v. AllSaints USA Ltd., No. 2016-CH-10056 (Cir. Ct. Cook Cty,
Ill.): Lead counsel in a class action alleging the clothing company
AllSaints violated federal law by revealing consumer credit card
numbers and expiration dates. Case settled for $8 million with class
members receiving about $300 each.
Resnick v. Avmed, No. 10-cv-24513 (S.D. Fla.): Lead counsel in
data breach case ﬁled against a health insurance company.
Obtained landmark appellate decision endorsing common law
unjust enrichment theory, irrespective of whether identity theft
occurred. Case also resulted in the ﬁrst class action settlement in
the country to provide data breach victims with monetary payments
irrespective of whether they suﬀered identity theft.
N.P. v. Standard Innovation (US), Corp., No. 1:16-cv-08655 (N.D.
Ill.): Brought and resolved ﬁrst ever IoT privacy class action against
adult-toy manufacturer accused of collecting and recording highly
intimate and sensitive personal use data. Case resolved for $3.75
million.
Halaburda v. Bauer Publ’g Co., No. 12-cv-12831 (E.D. Mich.); Grenke
v. Hearst Commc'ns, Inc., No. 12-cv-14221 (E.D. Mich.); Fox v. Time,
Inc., No. 12-cv-14390 (E.D. Mich.): Lead counsel in consolidated
actions brought under Michigan’s Preservation of Personal
Privacy Act, alleging unlawful disclosure of subscribers’ personal
information to data miners. In a ground-breaking decision, the
court denied three motions to dismiss ﬁnding that the magazine
publishers were covered by the act and that the illegal sale of
personal information triggers an automatic $5,000 award to each
aggrieved consumer. Secured a $30 million in cash settlement and
industry-changing injunctive relief.
Mass Action Practice
Privacy and Data Security
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We have represented plaintiﬀs in consumer fraud cases in courts nationwide
against companies alleged to have been peddling fraudulent software,
engaging in online gambling businesses in violation of state law, selling
defective products, or engaging in otherwise unlawful conduct.
Representative cases and settlements include:
Having secured a watershed Ninth Circuit victory for consumers
in Kater v. Churchill Downs Inc., 886 F.3d 784 (9th Cir. 2018), we
are now pursuing consumer claims against more than a dozen
gambling companies for allegedly proﬁting oﬀ of illegal internet
casinos. Settlements in several of these cases total $651 million.
Prosecuted over 100 cases alleging that unauthorized charges for
mobile content were placed on consumer cell phone bills. See,
e.g., McFerren v. AT&T Mobility LLC, No. 08-cv-151322 (Sup. Ct.
Fulton Cty., Ga.); Paluzzi et al. v. mBlox, Inc., et al., No. 2007-CH-
37213, (Cir. Ct. Cook Cty., Ill.); Williams et al. v. Motricity, Inc. et al.,
No. 2009-CH-19089 (Cir. Ct. Cook Cty., Ill.).
Edelson PC v. Christopher Bandas, et al., No. 1:16-cv-11057 (N.D.
Ill.): Filed groundbreaking lawsuit seeking to hold professional
objectors and their law ﬁrms responsible for, among other things,
alleged practice of objecting to class action settlements in order to
extort payments for themselves, and the unauthorized practice of
law. After several years of litigation and discovery, secured ﬁrst of
its kind permanent injunction against the objector and his law ﬁrm,
which, inter alia, barred them from practicing in Illinois or asserting
objections to class action settlements in any jurisdiction absent
meeting certain criteria.
Brought numerous cases alleging that defendants deceptively
designed and marketed computer repair software. 907 F.3d 1018
(7th Cir. 2018).
Mass Action Practice
General Consumer Matters
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McCormick, et al. v. Adtalem Glob. Educ., Inc., et al., No. 2018-CH-
04872 (Cir. Ct. Cook Cty., Ill): After students at one of the country’s
largest for-proﬁt colleges, DeVry University, successfully advanced
their claims that the school allegedly induced them to enroll and
charged a premium based on inﬂated job placement statistics,
the parties agreed to a $45 million settlement—the largest private
settlement DeVry has entered into regarding the claims.
1050 W. Columbia Condo. Ass’n v. CSC ServiceWorks, Inc., No.
2019-CH-07319 (Cir. Ct. Cook Cty., Ill): Representing a class of
landlords in securing a multifaceted settlement—including a cash
component of up to $30 million—with a laundry service provider
over claims that the provider charged fees that were allegedly
not permitted in the parties' contracts. The settlement's unique
structure allows class members to choose repayment in the near
term, or to lock in more favorable rates for the next decade.
Dickey v. Advanced Micro Devices, Inc., No. 15-cv-4922 (N.D. Cal.):
Lead counsel in a complex consumer class action alleging AMD
falsely advertised computer chips to consumers as “eight-core”
processors that were, in reality, disguised four-core processors.
The case settled for $12.1 million.
Barrett v. RC2 Corp., No. 2007 CH 20924 (Cir. Ct. Cook Cty., Ill.):
Co-lead counsel in lead paint recall case involving Thomas the
Tank toy trains. Settlement provided class with full cash refunds
and reimbursement of certain costs related to blood testing.
In re Pet Food Prods. Liability Litig., No. 07-cv-2867 (D.N.J.): Part
of mediation team in class action involving largest pet food recall
in United States history. Settlement provided $24 million common
fund and $8 million in charge backs.
Mass Action Practice
General Consumer Matters
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Prior to entering academia, I was a lawyer at the national oﬃce of the American
Civil Liberties Union (ACLU) for nearly a decade, during which time I pursued
civil rights campaigns on behalf of minority groups. Based on that experience,
it strikes me that what Class Counsel have pursued here is closer in form to a
civil rights litigation campaign than it is to a series of discrete class action set-
tlements. Class Counsel saw an injustice – a thinly disguised form of gambling
preying on those most vulnerable to addictive gambling – and they sought to ﬁx
it. Their goal was not to win a case but to reform an entire industry, much like
a civil rights campaign might aim to reform a particular type of discriminato-
ry practice across an entire employment sector. To accomplish this end, Class
Counsel went far beyond what lawyers pursuing a simple class action case would
normally do. Class Counsel pursued multiple cases. Class Counsel pursued mul-
tiple defendants. Class Counsel ﬁled actions in multiple forums. Class Counsel
tested various state laws. Class Counsel built websites to help app users avoid
forced arbitration clauses, lobbied legislators and regulators, and took their ef-
forts to the media. When Class Counsel lost, they did not give up, but changed
tactics or forums and kept going. And they did all of this with their own funds,
risking millions of dollars of their own money to end this practice. What they
have achieved so far, with these initial settlements, is an astounding accomplish-
ment that begins to chip away at the perncious underlying social casinos.
-William B. Rubenstein, Bruce Bromley Professor of Law at Harvard Law School and sole author of
the Newberg on Class Actions (5th Edition).
★ ★ ★ ★ ★ ★ ★
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We have successfully represented individuals and companies in a multitude
of insurance related actions. We successfully prosecuted and settled multi-
million dollar suits against J.C. Penney Life Insurance for allegedly illegally
denying life insurance beneﬁts under an unenforceable policy exclusion
and against a Wisconsin insurance company for terminating the health
insurance policies of groups of self-insureds.
Representative cases and settlements include:
Holloway v. J.C. Penney, No. 97-cv-4555 (N.D. Ill.): One of the
primary attorneys in a multi-state class action suit alleging that the
defendant illegally denied life insurance beneﬁts to the class. Case
settled, resulting in a multi-million dollar cash award to the class.
Ramlow v. Family Health Plan, 2000CV003886 (Wis. Cir. Ct.): Co-
lead counsel in a class action suit challenging defendant’s termination
of health insurance to groups of self-insureds. The plaintiﬀ won a
temporary injunction, which was sustained on appeal, prohibiting
such termination. Case eventually settled, ensuring that each class
member would remain insured.
Mass Action Practice
Insurance Matters
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We have been retained as outside counsel by states, cities, and other
regulators to handle investigations and litigation relating to environmental
issues, the marketing of opioids and e-cigarettes, privacy issues, and
general consumer fraud.
Representative cases and settlements include:
State of Idaho v. Purdue Pharma L.P., et al., No. CV01-19-10061 (Cir.
Ct. Ada Cty., Idaho): Representing the State of Idaho, and nearly
50 other governmental entities— with a cumulative constituency
of over three million Americans—in litigation against manufacturers
and distributors of prescription opioids.
District of Columbia v. Juul Labs, Inc., No. 2019 CA 07795 B
(D.C. Super. Ct.): Represented the District of Columbia in a suit
against e-cigarette giant Juul Labs, Inc. for alleged predatory and
deceptive marketing.
State of New Mexico, ex. rel. Hector Balderas v. Google, LLC, No.
20-cv-00143 (D.N.M): Represented the State of New Mexico in a
case against Google for violating the Children’s Online Privacy
Protection Act by collecting data from children under the age of 13
through its G-Suite for Education products and services.
District of Columbia v. Facebook, Inc., No. 2018 CA 8715 B (D.C.
Super. Ct.) and People of Illinois v. Facebook Inc., et al., No. 2018-
CH-03868 (Cir. Ct. Cook Cty., Ill.): Representing the District of
Columbia as well as the People of the State of Illinois (through the
Cook County State's Attorney) in lawsuits against the world's largest
social network, Facebook, and Cambridge Analytica—a London-
based electioneering ﬁrm—for allegedly collecting (or allowing the
collecting of) and misusing the private data of 50 million Facebook
users.
ComEd Bribery Litigation: Represented the Citizens Utility Board,
the statutorily-designated representative of Illinois utility ratepayers,
in pursuing Commonwealth Edison for its alleged role in a decade-
long bribery scheme.
Mass Action Practice
Public Client Litigation and Investigations
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City of Cincinnati, et al. v. FirstEnergy, et al., No. 20CV007005
(Ohio C.P.): Represented Columbus and Cincinnati in litigation
against First Energy over the largest political corruption scandal in
Ohio's history. Obtained preliminary injunction, which prevented
electric utilities from collecting more than $1 billion of new fees
from being collected from ratepayers
Village of Melrose Park v. Pipeline Health Sys. LLC, et al., No.
19-CH-03041 (Cir. Ct. Cook Cty., Ill.): Successfully represented
the Village of Melrose Park in litigation arising from the closure
of Westlake Hospital in what has been called “one of the most
complicated hospital closure disputes in the state’s history.”
In re Marriott Int’l, Inc. Customer Data Security Breach Litig., 19-md-
02879, MDL 2879 (D. Md.): Representing the City of Chicago in the
ongoing Marriott data breach litigation.
In re Equifax, Inc., Customer Data Security Breach Litig., 17-md-
02800 (N.D. Ga.): Successfully represented the City of Chicago in
the Equifax data breach litigation, securing a landmark seven-ﬁgure
settlement under Chicago's City-speciﬁc ordinance.
City of Chicago, et al. v. Uber Techs., Inc., No. 17-CH- 15594 (Cir.
Ct. Cook Cty., Ill.): Represented both the City of Chicago and the
People of the State of Illinois (through the Cook County State's
Attorney) in a lawsuit against tech giant Uber Technologies,
stemming from a 2016 data breach at the company and an alleged
cover-up that followed.
Social Media Addition: Representing several states in investigations
and litigation against social media companies for harming a
generation of their citizens with social media addiction.
Mass Action Practice
Public Client Litigation and Investigations
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Our attorneys have also handled a wide range
of general commercial litigation matters, from
partnership
and
business-to-business
disputes
to litigation involving corporate takeovers. We
have handled cases involving tens of thousands of
dollars to “bet the company” cases involving up to
hundreds of millions of dollars. Our attorneys have
collectively tried hundreds of cases, as well as scores
of arbitrations. We have routinely been brought on
to be “negotiation” counsel in various high-stakes or
otherwise complex commercial disputes.
Litigation
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Our Team
★ ★ ★ ★ ★ ★ ★
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0_312.589.6375
F_312.589.6378
jedelson@edelson.com
Jay Edelson
Founder and CEO
Secu,
ed ove, $5 billion
in settlements
and verdicts
to, his
clients
while serving
as lead counsel
(over
$45b
in total).
Law360 repeatedly described Jay as a "Titan of the Plaintiff's Bar." The American Bar
Association recognized Jay Edelson as one of the "most creative minds in the legal
industry." Jay was recognized as one of ''America's Top 200 Lawyers" by Forbes in 2024.
Jay has also been recognized as one of "America's top trial lawyers" in the mass action
arena, and was included in LawDragon's 2020 and 2023 list of Leading Plaintiff Financial
Lawyers. Law360 noted that he has "taken on some of the biggest companies and law
firms in the world and has had success where others have not." Jay was profiled as
one of Fast Company's "Most Creative People in Business"-the first planintiff's attorney
to ever recieve the award. Another publication explained that "when it comes to legal
strategy and execution, Jay is simply one of the best in the country." Professor Todd
Henderson, the Michael J. Marks Professor of Law at the University of Chicago Law
School, opined that when thinking about "who's the most innovative lawyer in the US ...
[Jay is] at or near the top of my list."
Of Counsel explained that Jay has made a career out of "battling bullies":
Big banks. Big tech firms. Big Pharma. The big business that is the NCAA.
Plaintiff's attorney Jay Edelson wages battle against many of the nation's most
fortified institutions. Not only does he refuse to back down to anyone, regardless
of their stature or deep pockets, he welcomes the challenge.
Edelson earned a monumental Victory in the US Supreme Court in what's been
characterized as one of the most important consumer privacy cases of the
last several years, Robins v. Spokeo. He and his team are leading the charge
against the NCAA in representing former college football players who suffered
concussions, and their families. And, on behalf of labor unions and governmental
bodies, he's elbow-deep in litigation against pharmaceutical companies and
distributors for their pivotal role in the opioid crisis.
Simply put, he's a transformational lawyer.
► Jay has been appointed to represent state and local regulators on some of the largest
issues of the day, ranging from opioids suits against pharmaceutical companies, to
environmental actions against polluters, to breaches of trust against energy companies
and for-profit hospitals, to privacy suits against Google, Facebook, Uber, Marriott, and
Equifax.
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Jay has received special recognition for his success in taking on Silicon Valley. The
national press has dubbed Jay and the ﬁrm the “most feared” litigators in Silicon Valley
and, according to the New York Times, tech’s “babyfaced … boogeyman.” Most recently,
Chicago Lawyer Magazine dubbed Jay “Public Enemy No. 1 in Silicon Valley.” In the
emerging area of privacy law, the international press has called Jay one of the world’s
“proﬁliertesten (most prominent)” privacy class action attorneys. The National Law
Journal has similarly recognized Jay as a “Cybersecurity Trailblazer”—one of only two
plaintiﬀ’s attorneys to win this recognition.
Jay has taught seminars on class actions and negotiations at Chicago-Kent College
of Law and privacy litigation at UC Berkeley School of Law. He has written a blog for
Thomson Reuters, called Pardon the Disruption, where he focused on ideas necessary to
reform and reinvent the legal industry and has contributed opinion pieces to TechCrunch,
Quartz, the Chicago Tribune, Law360, and others. He also served on Law360’s Privacy &
Consumer Protection editorial advisory board. In recognition of the fact that his ﬁrm runs
like a start-up that “just happens to be a law ﬁrm,” Jay was recently named to “Chicago’s
Top Ten Startup Founders over 40” by Tech.co.
Jay has been regularly appointed to lead complicated MDLs and other coordinated
litigation, including those seeking justice for college football players suﬀering from the
eﬀects of concussions to homeowners whose HELOCs were improperly slashed after the
2008 housing collapse to some of the largest privacy cases of the day.
Jay recieved his JD from the University of Michigan Law School.
For a more complete bio, see https://edelson.com/team/jay-edelson/
Jay Edelson
Founder and CEO
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O_
415.234.5342
F_415.373.9435
rba lab a nia n@edelson.com
Rafey S. Balabanian
Global Managing Partner
Director of Nationwide Litigation
Appointed
lead Llass
LOunsel
in more
than two dozen
class
actions
in state and federal
courts
across
the count,
y.
Rafey started his career as a trial lawyer, serving as a prosecutor for the City of Chicago
where he took part in dozens of trials. Rafey went on to join a litigation boutique in
Chicago where he continued his trial work, before eventually starting with Edelson in
2008. He is regarded by his peers as a highly skilled litigator, and has been appointed
lead class counsel in more than two dozen class actions in state and federal courts
across the country. His work has led to groundbreaking results in trial courts nationwide,
including a $925 million jury verdict in Wakefield v. ViSalus-the largest privacy verdict
in this nation's history. In 2020 and 2021, Rafey was recognized as a top 100 lawyer in
California by California Daily Journal.
► Rafey has been at the forefront of protecting consumer data, and in 2018 helped lead the
effort to obtain adversarial class certification for the first time in the history of the Illinois
Biometric Information Privacy Act, on behalf of a class of Illinois users. On the eve of trial,
the case settled for a record-breaking $650 million.
► Some of Rafey's more notable achievements include nationwide settlements involving
the telecom industry, including companies such as AT&T, Google, Sony, Motricity, and
Open Market.
► Rafey has been appointed to represent state Attorneys General and regulators on a
variety of issues including the District of Columbia in a suit against Facebook for the
Cambridge Analytica scandal. He also represents labor unions and governmental entities
in lawsuits against the drug manufacturers and distributors over the ongoing opioid crisis.
► Rafey has also been appointed to the Executive Committee in the NCAA concussion
cases, considered to be "one of the largest actions pending in the country, a multi district
litigation ... that currently include [more than 300) personal injury class actions filed by
college football players[.]" And he represents a member of the Tort Claimant's Committee
in the PG&E Bankruptcy action, which resulted in a historic $13.5 billion settlement.
► Rafey served as trial court counsel in Robins v. Spokeo, Inc., 2:10-cv-05306-ODW-AGR
(C.D. Cal.), which has been called the most significant consumer privacy case in recent
years.
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Rafey’s class action practice also includes his work in the privacy sphere, and he has
reached groundbreaking settlements with companies like Netﬂix, LinkedIn, Walgreens,
and Nationstar. Rafey also served as lead counsel in the case of Dunstan, et al.
v. comScore, Inc., No. 11-cv-5807 (N.D. Ill.), where he led the eﬀort to secure class
certiﬁcation of what is believed to be the largest adversarial class to be certiﬁed in a
privacy case in the history of U.S. jurisprudence.
Rafey’s work in general complex commercial litigation includes representing clients
ranging from “emerging technology” companies, real estate developers, hotels,
insurance companies, lenders, shareholders and attorneys. He has successfully litigated
numerous multi-million dollar cases, including several “bet the company” cases.
Rafey is a frequent speaker on class and mass action issues, and has served as a guest
lecturer on several occasions at UC Berkeley School of Law. Rafey also serves on the
Executive Committee of the Antitrust, Unfair Competition and Privacy Section of the
State Bar of California where he has been appointed Vice Chair of Privacy, as well as the
Executive Committee of the Privacy and Cybersecurity Section of the Bar Association of
San Francisco.
Rafey received his J.D. from the DePaul University College of Law in 2005. A native
of Colorado, Rafey received his B.A. in History, with distinction, from the University of
Colorado – Boulder in 2002.
Rafey S. Balabanian
Global Managing Partner
Director of Nationwide Litigation
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0_720.741.0084
F _720.741.0081
era p p@ede
lso n.com
Eve--Lynn J. Rapp
Managing Partner, Boulder
Secu,
ed a $76 million
settlement-
the la, gest eve, for a
TC
PA ca se-f oui days bet
01 e tria I.
Eve is a partner and Co-Chair of Edelson's Public Client team, and has extensive complex
litigation experience in class, mass, and governmental litigation, including matters on
behalf of various Attorneys General and municipalities across the country. Eve has been
appointed class counsel or led the litigation efforts in dozens of privacy and consumer
protection matters and has recovered or secured verdicts of over a billion dollars for her
clients.
► Specific to her Public Client and Government Affairs practice, Eve is presently leading
the litigation on behalf of the City of Chicago in the Marriott data breach litigation, which
seeks to hold the hotel giant accountable for a massive data breach where attackers
stole the personal date of up to 383 million guests-including
over 5 million unencrypted
passport numbers. She likewise represented the City of Chicago in the data breach
litigation against Equifax where she secured a landmark seven-figure settlement under
Chicago's City-specific ordinance.
► Eve was part of the team representing the District of Columbia in its litigation against Juul
for its deceptive e-cigarette manufacturing and sales and the State of New Mexico in its
suit against Google alleging that its G-Suite for Education product and services illegally
collected data from New Mexico school children in violation of COPPA. Eve also counsels
governments on a range of issues involving consumer protection, privacy, technology, and
data security and was recently designated a Panel Member of Delaware's Department of
Justice's Environmental Counsel Panel.
► Eve devotes a considerable amount of her practice to consumer technology and privacy
cases. Eve was appointed Class Counsel in Wakefield v. ViSalus, Inc., No. 15-cv-01857 (D.
Or.), where she led and coordinated Edelson's litigation efforts, achieved certification of
an adversarial TCPA class, and paved the way to a $925 million jury verdict. She also led
Edelson's efforts in Birchmeier v. Caribbean Cruise Line, Inc. et al., No. 12-cv-04069 (N.D.
111.),
where, after obtaining class certification and partial summary judgment, she secured
a $76 million settlement-the
largest ever for a TCPA case-four days before trial. She is
also responsible for leading one of the first "Internet of Things" cases under the Federal
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Wiretap Act against a company collecting highly sensitive personal information from
consumers, in which she obtained a $5 million (CAD) settlement that aﬀorded individual
class members over one hundred dollars in relief.
In addition to her government and privacy work, Eve has led over a dozen consumer
fraud cases, against a variety of industries, including e-cigarette sellers, on-line gaming
companies, and electronic and sport products distributors. She lead and resolved a case
against a 24 Hour Fitness for misrepresenting its “lifetime memberships.”
Due to Eve’s knowledge and practice in the data privacy, technology and consumer
protection space, Eve serves as the Chair of the San Francisco Bar Association’s
Cybersecurity and Privacy Committee, where she is responsible for hosting and speaking
about a range of cutting-edge issues. She also speaks on various panels about cutting
edge issues ranging from upcoming regulatory eﬀorts, “issues to watch,” and litigation
trends.
Eve is passionate about diversity and social justice. She works with various organizations
such as the Diverse Attorney Pipeline Program, where she helps her ﬁrm conduct
over 20 mock interviews for women of color each year in eﬀort to help expand their
postgraduate opportunities, and organizations like the East Bay Community Law Center
and Berkeley’s Women of Color Collective. As a young attorney, Eve likewise devoted a
signiﬁcant amount of time to the Chicago Lawyers’ Committee for Civil Rights Under Law’s
Settlement Assistance Project, where she represented a number of pro bono clients for
settlement purposes.
From 2015-2019, Eve was selected as an Illinois Emerging Lawyer by Leading Lawyers.
Eve received her J.D. from Loyola University of Chicago-School of Law, graduating
cum laude, with a Certiﬁcate in Trial Advocacy. During law school, she was an Associate
Editor of Loyola’s International Law Review and externed as a “711” at both the Cook
County State’s Attorney’s Oﬃce and for Cook County Commissioner Larry Suﬀredin. Eve
also clerked for both civil and criminal judges (The Honorable Judge Yvonne Lewis and
Plummer Lott) in the Supreme Court of New York. Eve graduated from the University of
Colorado, Boulder, with distinction and Phi Beta Kappa honors, receiving a B.A. in Political
Science.
Eve-Lynn Rapp
Managing Partner, Boulder
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0_312.589.6377
F_312.589.6378
brichman@edelson.com
Benjamin H. Richman
Managing Partner, Chicago
Recovered
hundreds
of millions
of dollars
for his clients.
Benjamin handles plaintiff's-side class and mass actions, helping employees in the
workplace, consumers who were sold deceptive products or had their privacy rights
violated, individuals and families suffering the ill-effects of exposure to toxic chemicals,
student athletes suffering from the effects of concussions, and labor unions and
governmental bodies seeking to recover losses arising out of the opioid crisis. He also
routinely represents technology and brick and mortar companies in a wide variety of
commercial litigation and other matters. Overall, Ben has been appointed by the federal
and state courts to be Class or Lead Counsel in dozens of cases.
► Ben represents state Attorneys General, counties, and cities in high-stakes litigation
and investigations, including the State of Idaho, in asserting claims against some of
the largest pharmaceutical manufacturers and distributors in the world related to the
ongoing opioid epidemic, including in the MDL pending in the Northern District of Ohio.
Ben also leads the team representing approximately 50 other governmental entities in
opioid litigation; the State of New Mexico in its lawsuit against Google LLC for allegedly
collecting data from children under the age of 13 through its G-Suite for Education
products and services; the District of Columbia in a suit against e-cigarette giant Juul for
alleged predatory and deceptive marketing; and was appointed as a Special Assistant
State's Attorney to prosecute Face book's violations of the Illinois Consumer Fraud Act in
the Cambridge Analytica scandal.
► Ben has been one of the primary forces behind the development of the firm's
environmental practice. Ben led a team representing hundreds of individuals across
the country suffering from the effects of exposure to ethylene oxide-a carcinogenic
chemical compound used in sterilization applications-emitted
into the air in their
communities, which included coordinating litigation across state and federal courts in
various jurisdictions; was appointed to the Plaintiffs' Executive Committee overseeing the
prosecution of the In re: Aqueous Film-Forming Foams Prods. Liability Litig., No. 18-mn-
2873, MDL No. 2873 (D.S.C) (which includes more than 500 cases against the largest
chemical manufacturers in the world, among others); and was designated as a Panel
Member on a State Attorney General's Environmental Counsel Panel, which was formed
to assist and represent the State in a wide range of environmental litigation.
► Ben is currently part of the team leading the In re National Collegiate Athletic Association
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Student-Athlete Concussion Injury Litigation – Single Sport/Single School (Football)
multidistrict litigation, bringing personal injury lawsuits against the NCAA, athletic
conferences, and its member institutions over concussion-related injuries. In addition, Ben
has and is currently acting as lead counsel in numerous class actions involving alleged
violations of class members’ common law and statutory rights (e.g., violations of Alaska’s
Genetic Privacy Act, Illinois’ Biometric Information Privacy Act, the federal Telephone
Consumer Protection Act, and others).
Some of Ben’s notable achievements include acting as class counsel in litigating and
securing a $45 million settlement of claims against for-proﬁt DeVry University related to
its allegedly false reporting of job placement statistics. He has acted as lead counsel in
securing settlements collectively worth $50 million in over a half-dozen nationwide class
actions against software companies involving claims of fraudulent marketing and unfair
business practices. He was part of the team that litigated over a half-dozen nationwide
class actions involving claims of unauthorized charges on cellular telephones. And he has
been lead counsel in numerous multi-million dollar privacy settlements, including several
that resulted in individual payments to class members reaching into the tens of thousands
of dollars and another that—in addition to securing millions of dollars in monetary relief—
also led to a waiver by the defendants of their primary defenses to claims that were not
otherwise being released.
Ben’s work in complex commercial matters includes successfully defending multiple
actions against the largest medical marijuana producer in the State of Illinois related to
the issuance of its cultivation licenses, and successfully defending one of the largest
mortgage lenders in the country on claims of unjust enrichment, securing dismissals or
settlements that ultimately amounted to a fraction of typical defense costs in such actions.
Ben has also represented startups in various matters, including licensing, intellectual
property, and mergers and acquisitions.
Each year since 2015, Ben has been recognized by Super Lawyers as a Rising Star and
Leading Lawyers as an Emerging Lawyer in both class action and mass tort litigation.
Ben received his J.D. from the University of Illinois Chicago School of Law, where he was an
Executive Editor of the Law Review and earned a Certiﬁcate in Trial Advocacy. While in law
school, Ben served as a judicial extern to the late Honorable John W. Darrah of the United
States District Court for the Northern District of Illinois. Ben also routinely guest-lectures at
various law schools on issues related to class actions, complex litigation and negotiation.
Managing Partner, Chicago
Benjamin H. Richman
►
►
►
►
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 30 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 44 of 76

0_312.589.6373
F_312.589.6378
sdavis@edelson.com
Shawn Davis
Chief Information Officer
Experience
testifying
in fede,
a I cou,
t, b1 iefing membe,
s
of U.S.
Congress
on Capitol
Hill.
Shawn leads a technical team in investigating claims involving privacy violations and
tech-related abuse. His team's investigations have included claims arising out of the
fraudulent development, marketing, and sale of computer software, unlawful tracking
of consumers through digital devices, unlawful collection, storage, and dissemination of
consumer data, large-scale data breaches, receipt of unsolicited communications, and
other deceptive marketing practices.
► Shawn has experience testifying in federal court, briefing members of U.S. Congress on
Capitol Hill, and is routinely asked to testify before legislative bodies on critical areas of
cybersecurity and privacy, including those impacting the security of our country's voting
system, issues surrounding children's privacy (with a special emphasis on surreptitious
geotracking), and other ways data collectors and aggregators exploit and manipulate
people's private lives. Shawn has taught courses on cybersecurity and forensics at the
undergraduate and graduate levels and has provided training and presentations to other
technology professionals as well as members of law enforcement, including the FBI.
► Shawn's investigative work has forced major companies (from national hotel chains
to medical groups to magazine publishers) to fix previously unrecognized security
vulnerabilities. His work has also uncovered numerous issues of companies
surreptitiously tracking consumers, which has led to groundbreaking lawsuits
► Prior to joining Edelson PC, Shawn worked for Motorola Solutions in the Security
and Federal Operations Centers as an Information Protection Specialist. Shawn's
responsibilities included network and computer forensic analysis, malware analysis,
threat mitigation, and incident handling for various commercial and government entities.
► Shawn is an Adjunct Industry Associate Professor for the School of Applied Technology
at the Illinois Institute of Technology (IIT) where he has been teaching since December
of 2013. Additionally, Shawn is a faculty member of the IIT Center for Cyber Security and
Forensics Education which is a collaborative space between business, government,
academia, and security professionals. Shawn's contributions aided in IIT's designation
as a National Center of Academic Excellence in Information Assurance by the National
Security Agency.
► Shawn graduated with high honors from the Illinois Institute of Technology with a Masters
of Information Technology Management with a specialization in Computer and Network
Security. During graduate school, Shawn was inducted into Gamma Nu Eta, the National
Information Technology Honor Society.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 31 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 45 of 76

0_312.572.7219
F_312.589.6378
kmcca
nn@edelson.com
Kelsey McCann
Chief of Staff
As a result
of her efforts,
Edelson
is conside,ed
one of the
most diverse
"high stakes"
plaintiff's
firms in the country.
Kelsey weighs in on and executes strategic planning, including HR issues, public
relations, pro bono initiatives, staffing and the firm's general strategic vision.
► As the Chair of the Hiring Committee, Kelsey develops and executes the firm's
recruitment efforts, including screening and evaluating lateral hires (including attorneys
and non-attorneys) for both permanent and temporary work. She also leads the Summer
Associate committee, where she evaluates law students and college interns for the firm's
summer program and structuring the various aspects of the summer program, including
the firm's unique training model.
► Kelsey's creation and leadership of diversity efforts within the firm has made her a
national thought leader. She created novel outreach programs to law schools, law
school groups, and attorney organizations in order to broaden the pool of applicants the
firm was seeing. Today, as a result of her efforts, Edelson PC is considered one of the
most diverse "high stakes" plaintiff's firms in the country, and was recently awarded the
Diversity Initiative Award, given to the plaintiff's firm demonstrating a successful effort
to promote diversity within its organization and the profession at large by The National
Law Journal. The firm also has been recognized as having the second highest lawyer
satisfaction rate in the country by law360 and the highest one nationally by Above the
Law.
► In 2022, Kelsey was recognized as a DEIA Visionary by the LA Times.
► Kelsey also works with the different practice groups and the individual employees to set
and execute short and long term individual and firm-specific goals.
► Kelsey also works with the different practice groups and the individual employees to set
and execute short and long term individual and firm-specific goals.
► Kelsey graduated summa cum laude with dual degrees from DePaul University.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 32 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 46 of 76

0_312.239.3361
F_312.589.6378
tgreen@edelson.com
Tasha Green
Director of Human Resources
Recieved
her Masters
in Counseling
Psychology
from The
Chicago
School
of Professional
Psychology.
Tasha's work focuses on the day-to-day HR management of the firm.
► Tasha is the Director of Human Resources at Edelson PC and a member of the Executive
Committee. Tasha conducts on boarding for new staff and serves as point of contact for
related inquires, ensures the firm's compliance by processing renewals for attorneys and
the firm yearly, as well as reviews, gets approval from leadership, and processes all plan
changes for benefits enrollments and transactions.
► Tasha assists in the maintenance of company culture, conducts phone and in- person
interviews, aids in the hiring decision process, and retains confidentiality of sensitive/
privileged information, among other activities.
► Tasha began her career at Edelson PC in 2014 as a Legal Assistant.
► Tasha graduated from The Chicago School of Professional Psychology wiht a Masters in
Counseling Psychology.
► Tasha recieved her BA from National Louis University in Chicago.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 33 of 62
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0_312.589.6374
F_312.589.6378
rand
rews@ed
e Ison
.com
Ryan D. Andrews
Partner
Litigated
issues
of first imp, ession
nationwide
secu,
ing
path
marking
victories.
Ryan presently leads the firm's complex case resolution and appellate practice group,
which oversees the firm's class settlements, class notice programs, and briefing on
issues of first impression.
► Ryan has been appointed class counsel in numerous federal and state class actions
nationwide that have resulted in over $100 million in refunds to consumers, including:
Sattetfield v. Simon & Schuster, No. 06-cv-2893 (N.D. Cal.); Ellison v Steve Madden, Ltd.,
No. 11-cv-5935 (C.D. Cal.); Robles v. Lucky Brand Dungarees, Inc., No. 10-cv-04846 (N.D.
Cal.); Lozano v. 20th Century Fox, No. 09-cv-06344 (N.D. 111.);
Paluzzi v. Cel/co P'ship, No.
2007 CH 37213 (Cir. Ct. Cook Cty., 111.);
and Lofton v. Bank of America Corp., No. 07-5892
(N.D. Cal.).
► Representative reported decisions include: Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016);
Kater v. Churchill Downs Inc., 886 F.3d 784 (9th Cir. 2018); Warciak v. Subway Rests., Inc.,
880 F.3d 870 (7th Cir. 2018), cert. denied, 138 S. Ct. 2692 (2018); Beaton v. SpeedyPC
Software, 907 F.3d 1018 (7th Cir. 2018), cert. denied, 139 S. Ct. 1465 (2019); Klaudia Sekura
v. Krishna Schaumburg Tan, Inc., 2018 IL App (1st) 180175; Yershov v. Gannett Satellite
Info. Network, Inc., 820 F. 3d 482 (1st Cir. 2016); Resnick v. AvMed, Inc., 693 F. 3d 1317 (11th
Cir. 2012); and Sattetfield v. Simon & Schuster, Inc., 569 F.3d 946 (9th Cir. 2009).
► Ryan graduated from the University of Michigan, earning his B.A., with distinction, in
Political Science and Communications. Ryan received his J.D. with High Honors from the
Chicago-Kent College of Law and was named Order of the Coif. Ryan has served as an
Adjunct Professor of Law at Chicago-Kent, teaching a third-year seminar on class actions.
While in law school, Ryan was a Notes & Comments Editor for The Chicago-Kent Law
Review, earned CALI awards for the highest grade in five classes, and was a teaching
assistant for both Property Law and Legal Writing courses. Ryan externed for the
Honorable Joan B. Gottschall in the United State District Court for the Northern District of
Illinois.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 34 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 48 of 76

0_628.241.1135
F_312.589.6378
nferna
ndezsilber@
edelson.com
Natasha Fernandez--Silber
Partner
Specializes
in generic
drug suppression
cases
involving
"pay-for-delay"
dea Is & othe, anticompetitive
schemes.
Natasha's practice focuses on antitrust class actions and other forms of complex
litigation.
► Prior to joining Edelson, Natasha was a partner at a boutique antitrust class action firm
where she specialized in generic drug suppression cases involving "pay-for-delay"
deals and other anticompetitive schemes. She has also represented purchasers of
e-cigarettes, textbooks, pesticides, and other consumer products
► Representative cases decisions include: Reece v. Altria Group, No. 20-02345 (N.D.
Cal.) - Steering Committee member representing direct purchasers of Juul products
in suit alleging anticompetitive agreement between Juul and Altria; In re Inclusive
Access Course Materials Antitrust Litig., No. 20-02946 (S.D.N.Y.) - Appointed Co-Lead
Interim Counsel on behalf of college students alleging textbook publishers and retailers
conspired to restrict sales of course materials to specific on line format to foreclose
competition and raise prices; In re Actos Antitrust Litig., No. 15-03278 (S.D.N.Y) - Counsel
for direct purchasers in suit alleging Takeda delayed generic competition for diabetes
drug by misrepresenting scope of patents listed in Orange Book; In re Ranbaxy Generic
Drug Application Antitrust Litig., No. 19-02878 (D. Mass.) - Counsel for direct purchasers
in suit alleging Ranbaxy fraudulently obtained tentative AN DA approvals (and first-to-file
exclusivities), delaying generic competition in three drug markets; In re lntuniv Antitrust
Litig., No. 16-12653 (D. Mass.) - Counsel for direct purchasers in suit alleging reverse
payment scheme to monopolize market for ADHD drug.
► Natasha clerked for the Honorable Ann Claire Williams on the Seventh Circuit Court of
Appeals.
► Natasha received her J.D. from the New York University School of Law.
► Natasha is admitted in New York, Michigan, Southern District of New York, Seventh
Circuit Court of Appeals.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 35 of 62
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0_773.389.2237
F_312.589.6378
a bha
usma
n n@edeIson.com
Amy B. Hausmann
Partner
Se,ved
as a law cle, k to the Honorable
Michael
P. Shea
of
the U.S.
Dist,
ict Cou,
t to, District
of Connecticut.
Amy's practice focuses on consumer and privacy-related class actions, as well as
government enforcement litigation.
► Specific to her public client practice, Amy secured preliminary injunction on behalf of the
Cities of Cincinnati, Columbus, Dayton, and Toledo in action against FirstEnergy Corp.
for alleged violations of the Ohio Corrupt Practices Act, saving the Cities and all Ohio
consumers from paying $170 million per year in added electric bill fees. City of Cindnnati
v. FirstEnergy Corp., No. 20 CV 7005 (Ohio Ct. Common Pleas).
► Amy represents consumers who have suffered losses to illegal interest casinos. Three
of those cases recently settled for approximately $200 million, with damages-adjusted
claims rates of 15%-33% and class members recovering up to hundreds of thousands of
dollars. The largest of the remaining cases is set for trial in November 2021. See, e.g.,
Benson v. OoubleDown Interactive, LLC, No. 18-cv-525 (W.D. Wash.); Wilson v. PTT, LLC,
No. 18-cv-5275 (W.D. Wash); Reed v. Scientific Games Corp., No. 18-cv-565 (W.D. Wash.).
► Amy received her J.D. from Yale Law School where she participated in the San Francisco
Affirmative Litigation Project, a clinic partnering with the San Francisco City Attorney's
Office to bring suits challenging unfair and deceptive business practices. She also
participated in the Housing Clinic of the Jerome N. Frank Legal Services Organization,
defending homeowners in judicial foreclosure proceedings and bringing affirmative suits
against mortgage lenders and servicers. She served as Co-Chair of the law school's
Clinical Student Board and as a Practical Scholarship Editor on the Yale Law Journal,
helping solicit and publish pieces based on legal practice or clinical experience.
► Before law school, Amy worked as a legal assistant at a plaintiffs' firm in New York City
focusing on employment and False Claims Act cases.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 36 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 50 of 76

O_
415.234.5344
F_415.373.9435
alawson@edelson.com
J. Aaron Lawson
Partner
A, gued
in four
federal
Courts
of App
ea Is and numerous
dist,
ict courts
a, ound
the country.
Aaron's practice focuses on appeals and complex motion practice. Aaron regularly
litigates complex issues in both trial and appellate courts, including jurisdictional issues
and class certification.
► Aaron has argued in four federal Courts of Appeals and numerous district courts around
the country. In 2019, Aaron won and successfully defended class certification in a case
challenging Facebook's collection of facial recognition data gathered through the
platform's photo tagging feature. The case settled on the eve of trial for a record breaking
$650 million. In re Facebook Biometric Info. Privacy Litig., 326 F.R.D. 535 (N.D. Cal. 2018);
932 F.3d 1264 (9th Cir. 2019). W
► Aaron won and successfully defended class certification in case involving allegedly
fraudulently advertised computer software. Beaton v. SpeedyPC Software, No. 13-cv-
08389 (N.D. 111.);
907 F.3d 1018 (7th Cir. 2018).
► Aaron helped achieve a landmark decision affirming the ability of plaintiffs to bring
statutory claims for relief in federal court. Robins v. Spokeo, No. 10-cv-5306 (C.D. Cal.).
► In addition to his work at Edelson PC, Aaron serves on the Privacy Subcommittee of the
California Lawyers Association's Antitrust, UCL & Privacy Section, and edits the yearly
treatise produced by the subcommittee
► Prior to joining Edelson PC, Aaron served for two years as a Staff Attorney for the United
States Court of Appeals for the Seventh Circuit, handling appeals involving a wide variety
of subject matter, including consumer-protection law, employment law, criminal law, and
federal habeas corpus.
► While at the University of Michigan Law School, Aaron served as the Managing Editor for
the Michigan Journal of Race & Law, and participated in the Federal Appellate Clinic. In
the clinic, Aaron briefed a direct criminal appeal to the United States Court of Appeals for
the Sixth Circuit, and successfully convinced the court to vacate his client's sentence.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 37 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 51 of 76

O_
415.638.9853
F_415.373.9435
tlogan@edelson.com
Todd Logan
Partner
Led the litigation
and settlement
of a variety
of class
action
cases
alleging
claims
under
federal,
state,
and local laws.
Todd focuses his practice on class and mass actions and large-scale governmental suits.
► Todd is routinely appointed by courts nationwide to serve as class counsel in major
class action litigation. In recent years, Todd has been appointed Class Counsel in,
and led the litigation of, several related cases alleging that internet slot machine apps
constitute illegal gambling. These cases hace so far recovered more than $651 million for
consumers, with class members recovering up to hundreds of thousands of dollars.
► Todd represents Butte County residents who lost their homes and businesses in the
Camp Fire, governments and other entities seeking to recover losses arising out of the
nationwide opioid epidemic, former NCAA football players suffering from the harmful
effects of concussions, consumers seeking compensation for their gambling losses to
illegal internet casinos, and consumers who have been defrauded or otherwise suffered
damages under state consumer protection laws.
► In recent years, Todd has led the litigation and settlement of a variety of class action
cases alleging claims under federal, state, and local laws. For example, in Dickey v.
Advanced Micro DeVices, Inc., No. 15-cv-04922, 2019 WL 251488, (N.D. Cal. Jan. 17,
2019), Todd briefed and argued a successful motion for nationwide class certification in a
complex consumer class action alleging claims under California Law. In Robins v. Spokeo,
No. 10-cv-5306 (C.D. Cal.), after remand from both the Supreme Court and the Ninth
Circuit, Todd led the litigation of the class' claims under the Fair Credit Reporting Act for
more than a year before the case entered settlement posture on favorable terms. And
in Sekura v. L.A. Tan Enterprises, Inc., No. 2015-CH-16694 (Cir. Ct. Cook Cty., 111.),
Todd
represented a class of consumers alleging claims under Illinois' Biometric Information
Privacy Act (BIPA) and ultimately obtained a seven-figure class action settlement - the
first ever BIPA class action settlement.
► Before becoming a lawyer, Todd built SOL databases for a technology company and
worked at various levels in state and local government. Todd received his J.D. cum laude
from Harvard Law School, where he was Managing Editor of the Harvard Journal of Law
and Technology. Todd also assisted Professor William B. Rubenstein with research and
analysis on a wide variety of class action issues, and is credited for his work in more than
eighty sections of Newberg on Class Actions.
► From 2016-17, Todd served as a judicial law clerk for the Honorable James Donato of the
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 38 of 62
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0_312.572.7213
F_312.589.6378
dmindell@edelson.com
David I. Mindell
Partner
Co-Chair, Public Client and Government Affairs group
Luunsels
guve1
nments
and state and fede,
a I lawmakers
on a range
of policy
issues.
David represents state Attorneys General, counties, and cities in high-stakes litigation
and investigations involving consumer protection, information security and privacy
violations, the opioid crisis, and other areas of enforcement that protect government
interests and vulnerable communities. David also counsels governments and state and
federal lawmakers on a range of policy issues involving consumer protection, privacy,
technology, and data security.
► In addition to his Public Client and Government Affairs practice, David helps direct
the firm's Investigations team, including the group's internal lab "of computer forensic
engineers and tech-savvy lawyers (who study) fraudulent software and hardware,
undisclosed tracking of online consumer activity and illegal data retention." Cybersecurity
& Privacy Practice Group of the Year, Law360 (Jan. 2019). His team's research has led
to lawsuits involving the fraudulent development, marketing and sale of computer
software, unlawful tracking of consumers through mobile-devices and computers,
unlawful collection, storage, and dissemination of consumer data, mobile-device
privacy violations, large-scale data breaches, unlawful collection and use of biometric
information, unlawful collection and use of genetic information, and the Bitcoin industry.
► David also helps oversee the firm's class and mass action investigations, including
claims against helmet manufacturers and the National Collegiate Athletic Association
by thousands of former high school, college, and professional football players suffering
from the long-term effects of concussive and sub-concussive hits; claims on behalf of
hundreds of families and business who lost their homes, businesses, and even loved
ones in the "Camp Fire• that ravaged thousands of acres of Northern California in
November 2018; and on behalf of survivors of sexual abuse.
► Prior to joining Edelson PC, David co-founded several tech, real estate, and hospitality
related ventures, including a tech startup that was acquired by a well-known international
corporation within its first three years. David has advised tech companies on a variety
of legal and strategic business-related issues, including how to handle and protect
consumer data. He has also consulted with startups on the formation of business plans,
product development, and launch.
► While in law school, David was a research assistant for University of Chicago Law School
Kauffman and Bigelow Fellow, Matthew Tokson, and for the preeminent cybersecurity
professor, Hank Perritt at the Chicago-Kent College of Law. David's research included
cyberattack and denial of service vulnerabilities of the internet, intellectual property
rights, and privacy issues.
► David has spoken to a wide range of audiences about his investigations and practice.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 39 of 62
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0_312.267.2079
F_312.589.6378
rpe rlsta
dt@ed
els on .com
Roger Perlstadt
Partner
Briefed
appeals
and motions
in numerous
fede,
a I and
state appellate
courts.
Roger's practice focuses on appeals and critical motions. He has briefed appeals and
motions in numerous federal and state appellate courts, including the United States
Supreme Court's seminal case of Spokeo, Inc. v. Robins, and has argued multiple times
before the United States Courts of Appeals for the Sixth, Seventh, Eighth, and Ninth
Circuits.
► Roger has briefed complex issues at the trial court level in cases throughout the country.
These cases generally involve matters of first impression relating to new statutes or
novel uses of long-standing statutes, as well as the intersection of privacy law and
emerging technologies.
► Prior to joining Edelson PC, Roger was an associate at a litigation boutique in Chicago,
and a Visiting Assistant Professor at the University of Florida Levin College of Law. He
has published articles on the Federal Arbitration Act in various law reviews.
► Roger has been named a Rising Star by Illinois Super Lawyer Magazine four times since
2010.
► Roger graduated from the University of Chicago Law School, where he was a member
of the University of Chicago Law Review. After law school, he served as a clerk to the
Honorable Elaine E. Bucklo of the United States District Court for the Northern District of
Illinois.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 40 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 54 of 76

0_202.987.6302
jrock@edelson.com
Jimmy Rock
Managing Partner, Washington, D.C. Office, Edelson PC
Jimmy
spent
twelve
years
with the Office
of the Atto,
ney
Gene,
a I for the Dist,
ict of Columbia.
Jimmy Rock is a partner at Edelson PC where his work focuses on consumer protection
and environmental cases. He also leads the firm's Public Clients litigation group.
► Prior to joining Edelson PC, Jimmy spent twelve years with the Office of the Attorney
General for the District of Columbia where he helped to start OAG's Office of Consumer
Protection and transform it into once of the preeminent State AG consumer practices.
► Jimmy served for five years as an Assistant Deputy Attorney General managing OAG's
Public Advocacy Division, a 40+ lawyer group that enforced the District's consumer
protection, antitrust, workers' rights, housing, nonprofit and environmental laws.
► Jimmy led a trial team against one of the largest on line travel companies for failing to
pay District sales taxes on service fees charged for selling hotel rooms, recovering more
than $90 million in unpaid taxes and fees. To this day, this remains the largest litigated
affirmative judgment obtained by the D.C. Attorney General's Office. D.C. v. Expedia, Inc.,
120 A.3d 623 (D.C. 2015).
► Jimmy was the lead attorney on a consumer protection enforcement case stemming
from a multistate investigation into Marriott's deceptive advertising of hotel rooms with
mandatory resort fees included in the nightly room rate. O.C. v. Marriott Int'/, Inc., No. 2019-
CA-004497 B (D.C. Super. Ct.).
► In 2015, Jimmy recived the Attorney General's Distinguished Service Award for Trial of
Affirmative Litigation.
► From 2014-2018, Jimmy served as an Adjunct Professor at Georgetown University Law
Center teaching a year-long course on Civil Litigation Practice and Procedure.
► Jimmy recieved his J.D. with honors from Emory University school of law.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 41 of 62
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0_773.389.2281
F_312.589.6378
nrosinia@edelson.com
Nicholas Rosinia
Partner
Experience
handling
high-stakes
trials
before
judges,
juries,
and arbitration
panels.
Nick's practice focuses on litigating class actions, mass torts, and high-profile matters
on behalf of government entities. In addition to his trial experience, Nick has managed
extensive pre-trial discovery, crafted major motions and briefs, taken and defended
scores of depositions, worked with expert witnesses to develop and defend their
opinions and reports, and presented argument in federal and state courts.
► Nick is a trial lawyer with more than eight years of experience litigating and leading
teams of lawyers through eight- and nine-figure disputes from initial advice to jury verdict.
Nick second-chaired two major, multi-week arbitration hearings, and played key roles
during an eight-day bench trial and a six-week jury trial.
► Currently, Nick represents hundreds of survivors of wildfires in Oregon who lost their
homes, businesses, and livelihoods over the 2020 Labor Day weekend. Nick successfully
represented a putative class of ADT customers in litigation against ADT and one of its
former technicians. Nick is additionally assisting with the litigation of several government
enforcement actions on behalf of the District of Columbia, including Facebook for its role
in the Cambridge Analytica scandal and JUUL Labs for its e-cigarette marketing practices.
► Nick represented a putative class of California raisin growers seeking just compensation
from the federal government under the Fifth Amendment's Takings Clause. Following
a Supreme Court decision establishing the predicate legal theory, Nick helped
conceptualize and develop an ensuing class action that ultimately resulted in an eight-
figure class-action settlement. Ciapessoni, et. al. v. The United States of America, No.
1:15-cv-00938 (Court of Federal Claims 2015). Along the way, Nick drafted the complaint,
worked directly with the class representatives, and helped devise a novel statute of
limitations theory that ultimately prevailed and paved the way for the class's recovery.
► Prior to joining Edelson PC, Nick worked at two prominent, international law firms.
► Nick recieved his J.D. magna cum laude from Washington University in St. Louis School
of Law.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 42 of 62
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O_
415.638.9903
F_415.373.9435
ysa
la hi@edelson.com
Yaman Salahi
Partner
::>ecurea
$465m
in pandemic
assistance
for incarcerated
people
&
recovered
over $100m
for workers
challenging
no-poach
agreements.
Yaman spearheads the firm's antitrust practice, and has experience litigating consumer
protection, civil rights, privacy, and administrative law claims, including in complex class
action proceedings and multi- district litigation.
► Yaman devised the legal strategy, researched the legal theories, and briefed all merits motions
challenging the Trump administration's denial of COVID-19 stimulus relief under the CARES Act
to people in prison. Yaman was the lead author of the winning motion for class certification,
preliminary injunction, and summary judgment, which ultimately resulted in over $465 million in
cash assistance to over 385,000 people living in prison, and prevented the IRS from recouping
over $1 billion already issued. Yaman also authored a successful opposition to the IRS's attempt
in the Ninth Circuit Court of Appeals to stay the district court's rulings pending appeal. Scholl v.
Mnuchin, No. 20-cv-5309-PJH (N.D. Cal.).
► In antitrust no-poach litigation, Yaman helped obtain a $54.5 million settlement for medical
professors and $19 million for other faculty at Duke University and University of North Carolina-
Chapel Hill, and $48.95 million for railway industry workers.
► Yaman briefed, argued, and won an appeal in the Eleventh Circuit establishing that franchisors
and their franchisees constitute separate entities capable of conspiracy under the antitrust
laws, a question of first impression. Arrington v. Burger King Worldwide, Inc., et al., 47 F. 4th
1247 (11th Cir. 2022).
► Before joining Edelson PC, Yaman was a Partner at another prominent plaintiff-side class action
firm in San Francisco.
► From 2017-2018, Ya man served as a judicial law clerk for the Honorable Edward M. Chen in the
Northern District of California.
► From 2013-2016 Ya man worked as a a Staff Attorney in the National Security and Civil Rights
Program at Asian Americans Advancing Justice-Asian Law Caucus, where he focused on legal
issues surrounding government surveillance and freedom of speech, and an Arthur Liman
Fellow at the American Civil liberties Union of Southern California.
► Yaman received his J.D. Yale Law School in 2012.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 43 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 57 of 76

0_312.239.3362
F_312.589.6378
ascha
rg@edelson.com
Ari J. Scharg
Partner
Co-Chair, Government Affairs Group
ReLugrnzed
as one uf the leading
experts
on privacy
and
emerging
technologies.
Ari is a Partner at Edelson PC, Chair of the Public Impact Group, and Co-Chair of the
firm's Public Client and Government Affairs Group, where he leverages his experience
litigating hundreds of complex class and mass action lawsuits to help state and local
governments investigate and prosecute consumer fraud, data privacy, and other areas of
enforcement that protect government interests and vulnerable communities.
► Ari has been appointed as a Special Assistant Cook County State's Attorney to litigate cases
against Facebook and Cambridge Analytica for their alleged misuse of consumer data and
against Uber for its alleged violations of the state's data breach notification law and information
security requirements. He represented the Illinois Citizens Utility Board in litigation against
Commonwealth Edison for its alleged role in a decade-long bribery scheme, and serves as
Special Counsel for Columbus and Cincinnati in litigation alleging money laundering and
corruption against FirstEnergy, where he recently secured a preliminary injunction blocking
more than $1 billion of new fees from being collected from ratepayers. Ari also represent a
broad range of stakeholders in litigation against opioid companies, including governments,
municipal risk pools, labor unions, and health and welfare funds.
► Ari is passionate about social justice causes, and in 2017, the Michigan State Bar Foundation
presented both Edelson PC and Ari, personally, with its Access to Justice Award for
"significantly advancing access to justice for the poor· through his consumer class actions.
► As Special Counsel for Melrose Park, Ari served as lead trial counsel in first-of-its-kind litigation
seeking to block the closure of Westlake Hospital, a community hospital providing safety net
services to medically and socially vulnerable minority populations. Village of Melrose Park v.
Pipeline Health System LLC, et al., No. 19-CH-03041 (Cir. Ct. Cook Cty., 111.).
In what has been
called ·one of the most complicated hospital closure disputes in the state's history," Ari worked
tirelessly to preserve access to healthcare for the community by securing a series of in-court
victories, including a temporary restraining order prohibiting the owners from closing the
hospital, and later, after a full-day evidentiary hearing, an order holding the owner in contempt
for attempting to shut down hospital services prematurely.
► Recognized as a leader on privacy and emerging technologies, Ari serves on the Executive
Oversight Council for the Array of Things Project where he advises on privacy and data
security matters, founded and chaired the Illinois State Bar Association's Privacy and
Information Security Section (2017-2019), and served as Co-Chair of the Illinois Blockchain and
Distributed Ledgers Task Force. Ari also enjoys working with law students through the Diverse
Attorney Pipeline Program (DAPP) and Berkeley's Women of Color Collective.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 44 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 58 of 76

0_312.589.6379
F_312.589.6378
atievsky@edelson.com
Alexander G. Tievsky
Partner
Obtained
p1
elimina
ry injunction
p1
eventing
electric
utilities
f1om
collecting
mo1e
than
$1 billion
in surcha1ges.
Alex concentrates on complex motion practice and appeals in consumer class action
litigation.
► Alex has briefed and argued cases in numerous federal appellate and district courts, and
he has successfully defended consumers' right to have their claims heard in a federal
forum, including, for example, defeating Facebook's attempt to deprive its users of a
federal forum to adjudicate their claims for wrongful collection of biometric information
in violation of a state privacy statute in In re Facebook Biometric Info. PriVacy Litig., 290
F. Supp. 3d 948 (N.D. Cal. 2018), aff'd 932 F.3d 1264 (9th Cir. 2019); receiving preliminary
injunction preventing electric utilities from collecting surcharges imposed by Ohio
House Bill 6 on the basis that Cincinnati and Columbus were likely to succeed on their
allegations that the bill was the product of a bribery scheme involving the former speaker
of the Ohio House of Representatives in Cindnnati & Columbus v. Rrst Energy Corp.,
No. 20-CV-7005 (Franklin Cty., Ohio Ct. of Common Pleas 2020); winning reversal of
summary judgment in Telephone Consumer Protection Act (TCPA) case on the basis that
the defendant could be held liable for ratifying the actions of its callers, even though it
did not place the calls itself in Henderson v. United Student Aid Funds, Inc., 918 F.3d 1068
(9th Cir. 2019); and winning reversal of district court's dismissal in first-of-its-kind ruling
that so-called "free to play" casino apps are illegal gambling, which allows consumers to
recover their losses under Washington law. See Kater v. Churchill Downs, Inc., 886 F.3d
784 (9th Cir. 2018)
► Alex received his J.D. from the Northwestern University School of Law, where he
graduated from the two-year accelerated J.D. program. While in law school, Alex was
Media Editor of the Northwestern University Law Review. He also worked as a member
of the Bluhm Legal Clinic's Center on Wrongful Convictions. Alex maintains a relationship
with the Center and focuses his public service work on seeking to overturn unjust
criminal convictions in Cook County.
► Alex is admitted to the state bars of Illinois and Washington and is a member of both the
Lesbian and Gay Bar Association of Chicago and QLaw, the LGBTQ+ Bar Association of
Washington.
► Alex's past experiences include developing internal tools for an enterprise software
company and working as a full-time cheesemonger. He received his A.B. in linguistics
with general honors from the College of the University of Chicago.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 45 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 59 of 76

0_312.242.0859
F_312.589.6378
ewa
de scott@ede
lso n.co
m
J. Eli Wade--Scott
Partner
Chair, Class Action Practice Group
L1t1gatiny
novel
questions
of privacy
law and
I eturned
more
than $100
million
to his clients.
Eli's practice focuses on privacy- and tech-related class actions and enforcement actions
brought by governments. Eli has been appointed to represent states and cities to handle
high-profile litigation.
► Eli is frequently appointed to represent states and cities to handle high-profile litigation,
including by the District of Columbia against JUUL, Inc. in litigation arising from the youth vaping
epidemic, by the State of New Mexico to prosecute Google's violations of the Children's Online
Privacy Protection Act, and as a Special Assistant State's Attorney for Illinois and the District of
Columbia in litigation against Facebook arising from the Cambridge Analytica scandal.
► Eli has been repeatedly appointed class counsel in dozens of cases pressing novel questions of
law, and has returned more than $100 million to his clients.
► Lead counsel in a novel putative class action against ADT over security flaws in its home
security system that allowed a technician to surreptitiously spy on families-including
children-in
their most intimate moments at home. Successfully resolved action.
► Successfully represented ACLU and other public interest organizations as lead outside counsel
in a lawsuit against Clearview, Inc., resulting in consent decree. The consent decree permanently
enjoins Clearview from selling access to its massive database of facial vectors to any private
person or company, as well as prohibits Clearview from sales to any entity within Illinois for five
years, including government agencies or police departments. American Civil Liberties Union
v. Clearview Al, Inc., No. 20 CH 4353 (Cir. Ct. Cook Cty.). The settlement has been called a
"milestone for civil rights."
► Before joining Edelson PC, Eli served as a law clerk to the Honorable Rebecca Pallmeyer of the
Northern District of Illinois. Eli has also worked as a Skadden Fellow at Legal Aid Chicago, Cook
County's federally-funded legal aid provider. There, Eli represented dozens of low-income
tenants in affirmative litigation against their landlords to remedy dangerous housing conditions.
► Eli received his J.D. magna cum laude from Harvard Law School, where he was an Executive
Editor on the Harvard Law and Policy Review and a research assistant to Professor Vicki C.
Jackson.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 46 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 60 of 76

O_
415.234.5345
F_415.373.9435
bsilverkorn@edelson.com
Brandt Silver--Korn
Partner
Represents
over 1,000
victims
who suffered
losses
in the
2018
Camp
Fire.
Brandt's practice focuses on class and mass actions and large-scale governmental
suits. His current clients include families who lost their homes and businesses in the
Camp Fire, communities that have been severely impacted by the opioid epidemic, and
consumers who have suffered gambling losses to illegal internet casinos.
► Brandt represents over 1,000 victims, from residents to business owners, who suffered
the devastating loss of their homes, property, and loved ones in the 2018 Camp Fire.
The lawsuit alleges that the fire was caused by PG&E's equipment, resulting from PG&E's
failure to maintain their electrical infrastructure in Butte County. The case resulted in a
historic $13.5 billion settlement.
► Brandt represents consumers in seven class action lawsuits alleging that various online
"social casinos" violate state gambling laws. Brandt has taken a leading role both in
discovery and in briefing in these cases, and recently provided live testimony to the
Washington State Legislature.
► Brandt serves as counsel for the State of Idaho in the State's opioid litigation, where he
is part of the team spearheading lawsuits against the nation's leading manufacturers and
distributors of opioid products.
► Brandt received his J.D. from Stanford Law School, where he was awarded the Gerald
Gunther Prize for Outstanding Performance in Criminal Law, and the John Hart Ely Prize
for Outstanding Performance in Mental Health Law. While in law school, Brandt was
also the leading author of several simulations for the Gould Negotiation and Mediation
Program.
► Prior to law school, Brandt graduated sum ma cum laude from Middlebury College with a
degree in English and American Literatures.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 47 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 61 of 76

0_312.819.2104
F_312.589.6378
suf kes@ede
Ison
.com
Schuyler Ufkes
Partner
Currently
litigating
consumer
class
actions
on behalf
of
employees
under
the Illinois
Biometric
Information
Privacy
Act
Schuyler focuses on consumer and privacy-related class actions.
► Schuyler is currently litigating nearly a dozen consumer class actions on behalf
of employees under the Illinois Biometric Information Privacy Act ("BIPA•) for their
employers' failure to comply with the Act's notice and consent requirements before
collecting, storing, and in some instances disclosing their biometric data. Schuyler is
also litigating several Telephone Consumer Protection Act cases brought by recipients
harassing debt-collection calls as well as spam text messages.
► Schuyler received his J.D. magna cum laude, and Order of the Coif, from the Chicago-
Kent College of Law. While in law school, Schuyler served as an Executive Articles
Editor for the Chicago-Kent Law Review and was a member of the Moot Court Honor
Society. Schuyler earned five CALI awards for receiving the highest grade in Legal
Writing II, Legal Writing Ill, Pretrial Litigation, Supreme Court Review, and Professional
Responsibility.
► Prior to law school, Schuyler graduated with High Honors from the University of Illinois
Urbana-Champaign earning a degree in Consumer Economics and Finance.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 48 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 62 of 76

0_771.200.1527
T_202.270.4777
F_312.589.6378
a co la n gel o@e
d el son.
com
Aaron Colangelo
Partner
► Aaron is a Partner at Edelson PC, where his work focuses on redressing environmental
harms and protecting public health. Before joining Edelson PC, Aaron spent two decades
litigating environmental cases with the Natural Resources Defense Council. At NRDC,
Aaron served as counsel in more than 150 cases, including lawsuits related to drinking
water contamination, migrant farmworker health, hazardous waste cleanup, coastal water
quality, food safety, energy efficiency, air pollution, climate change, and toxics in consumer
products. Aaron also spent five years as NRDC's litigation co-director, where he helped
lead a team of 40 lawyers and paralegals and oversaw a nationwide litigation docket. He
has argued in dozens of federal and state courts, including in the U.S. Supreme Court, and
he taught environmental litigation for four years as an adjunct professor at the Howard
University School of Law.
► Prior to working with Edelson PC, Aaron acted as lead counsel in several high-impact
environmental lawsuits, including actions to strengthen federal standards for lead in
drinking water NRDC v. EPA, No. 21-1020 (D.C. Cir.), enforce the Clean Water Act to abate
stormwater pollution L.A. County Flood Control District v. NRDC, 568 U.S. 78 (2013),
protect children from toxic exposures (NRDC v. EPA, 658 F.3d 200 (2d Cir. 2011); NRDC v.
Consumer Product Safety Commission, 597 F. Supp. 2d 370 (S.D.N.Y. 2009)), and reduce
pathogens in coastal waters (NRDC v. Johnson, 2008 WL 11343609 (C.D.Cal. 2008), 2008
WL 11342972 (C.D.Cal. 2008), 2007 WL 1121799 (C.D.Cal. 2007)).
► Represented environmental interests in litigation against major federal entities,
challenging the U.S. Navy's munitions testing program (Potomac Riverkeeper v. U.S.
Department of the Navy, No. 23-cv-1650 (D.Md.)) and advocating for safer consumer
products and environmental practices to ensure public health and environmental safety.
► Recognized as a leader in environmental law, with inclusion in the Lawdragon Green 500
(2023) and the Lawdragon 500 Leading Environmental and Energy Lawyers (2021).
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 49 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 63 of 76

0_206-206-8317
F_312.589.6378
cva ugh n@ede
Isa n. com
Caitlin Vaughn
Of Counsel
Responsible
for the management,
identification,
and
investigation
of public
client cases.
Caitlin's practice focuses on investigating and developing civil cases that are targeted
at protecting consumers, workers, government interests and vulnerable communities for
the Investigations team.
► Caitlin previously served as the Director of Public Client Case Development for a
prominent plaintiffs firm where she was responsible for the management, identification, and
investigation of public client cases.
► Caitlin has extensive state government experience having worked for the New York State
Senate for ten years in the capacity of Counsel to Chairs of the Senate Aging, Codes and
Health Committees. She also served as the Director of the bipartisan Joint Legislative
Commission on Rural Resources. In those roles she was responsible for the management
of the legislative and policy agendas of various state senators. Her work has resulted in
the passage of statewide laws related to concussion management policies in schools,
telehealth parity, Lyme disease prevention, and elder abuse, among other things.
► In addition to her legal work, Caitlin completed her Ph.D. at Georgetown University with a
dissertation that studied the potential for political bias in state retirement system investment
strategies. During her graduate school tenure, she also worked as a Duke University
Health Policy Fellow at the World Health Organization in Geneva, Switzerland. While
there, she worked on research and presentations for WHO Member States and advocacy
organizations focusing on tobacco control policy and prevention.
► Caitlin received her J.D. from Syracuse University College of Law.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 50 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 64 of 76

0_217.350.2191
F_312.589.6378
schappleknowlton@edelson.com
Shantel Chapple Knowlton
Senior Litigation Counsel
Se, ved to, six yea rs as a Deputy
Atto,
ney Genera
I at the
Office
of the Ida ho Atto,
ney General.
Shantel's practice focuses on environmental mass tort and consumer protection
litigation.
► Prior to joining Edelson, Shantel served for six years as a Deputy Attorney General at
the Office of the Idaho Attorney General in both the Natural Resources and Consumer
Protection Divisions. In the Natural Resources Division, Shantel represented the State
of Idaho in water-rights adjudications, primarily litigating federal-reserved and Indian
water rights. In the Consumer Protection Division, Shantel represented the State of
Idaho in several multistate consumer protection actions. Most notably, Shantel pursued
investigations and litigation against a variety of companies to hold them accountable for
their contribution to the opioid crisis.
► Prior to serving at the Idaho Attorney General's Office, Shantel clerked for the Honorable
Justice Jim Jones at the Idaho Supreme Court.
► Shantel graduated summa cum /aude with a J.D. from Lewis & Clark Law School. During
law school, Shantel externed for the Honorable B. Lynn Win mill at the U.S. District Court
for the District of Idaho and served as a Law Clerk at the Oregon Department of Justice
in the Special Litigation Unit. Shantel was also a member of the Lewis & Clark Law Review
and a founding member of the Lewis & Clark chapter of Law Students for Reproductive
Justice (If/When/How).
► Shantel received dual S.S. degrees in Psychology and Sociology from the University of
Idaho.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 51 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 65 of 76

0_312.572.7212
F_312.589.6378
tbenja
min@edelson.com
Theo Benjamin
Associate
Led the litigation
and settlement
of a variety
of class
action
cases
alleging
claims
under
federal,
state,
and local laws.
Theo's practice focuses on consumer protection, privacy, complex environmental cases,
and bankruptcy.
► Theo is a member of the firm's Public Client and Government Affairs teams. Since joining
the firm, Theo has actively litigated a variety of complex actions on behalf of state
attorneys general, including over youth vaping, e-cigarettes, big-tech data breaches,
misuses of consumer data, and environmental actions over water and land contamination
and natural resources damages from toxic chemicals. These efforts have led to multi-
million-dollar settlements for government clients, including a $462 million multistate
settlement against JUUL Labs, the largest litigated settlement the District of Columbia
has ever secured under the Consumer Protection and Procedures Act ("CPPA").
► Theo is currently litigating several government consumer protection and environmental
actions against tech-industry giants and chemical companies, including Meta Platforms,
Inc. and Velsicol Chemical LLC. He also represents dozens of municipalities in litigation
against manufacturers and distributors of opioids, which has helped paved the way for
landmark national opioid settlements with Johnson & Johnson, Teva, Cardinal, McKesson,
and AmerisourceBergen.
► Theo received his J.D. from Northwestern Pritzker School of Law, where he served as a
Comment Editor for Northwestern's Journal of Criminal Law & Criminology and founded
Northwestern's chapter of the International Refugee Assistance Project where he helped
provide legal aid, representation, and policy research to refugees and asylum seekers
undergoing the U.S. resettlement process.
► Theo has represented clients in complex class action litigation, including on behalf of
consumers under the Illinois Biometric Information Privacy Act ("BIPA") and the California
Invasion of Privacy Act ("CIPA").
► Theo received his J.D. from Northwestern Pritzker School of Law, where he served as a
Comment Editor for Northwestern's Journal of Criminal Law & Criminology and founded
Northwestern's chapter of the International Refugee Assistance Project where he helped
provide legal aid, representation, and policy research to refugees and asylum seekers
undergoing the U.S. resettlement process.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 52 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 66 of 76

0_628.251.2045
F_415.373.9435
lb lazi
ng@ede
lso
n.co
m
Lauren Blazing
Associate
Authored
reports
and coordinated
media
outreach
to combat
gender
and racial
disparities
in the Service
Academies.
Lauren's practice focuses on mass torts and class actions.
► Lauren received her J.D. from Yale Law School, where she co-chaired the Title IX
Working Group and served as a research assistant studying Intentional Violence in
International Sport with Professor Alice M. Miller.
► At Yale, Lauren co-directed the HAVEN Medical Legal Partnership, which provides legal
services to underserved and undocumented patients at the university's community health
clinic. She also participated in the Jerome S. Frank Veterans Legal Services Clinic, where
her team worked to combat racial and gender inequities in the U.S. Military Service
Academies.
► Before joining Edelson, Lauren clerked for the Honorable Janet C. Hall in the U.S. District
Court for the District of Connecticut.
► Lauren graduated summa cum /aude from Duke University with a degree in Political
Science Cultural Anthropology.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 53 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 67 of 76

0_872.257.3787
F_312.589.6378
mde
I urey@ede
Ison.
com
Megan Delurey
Associate
Successfully
represented
an asylum
seeker
fleeing
persecution
on the basis
of her LGBTQ
identity.
Megan's practice focuses on representing the firm's clients at trial ..
► Megan received her J.D. from the University of Chicago Law School, where she was
involved in the school's clinical programs in both environmental and immigration law. While
working in the Immigrants' Rights Clinic, Megan provided legal aid services to immigrant
communities in Chicago. In the environmental law clinic, Megan advocated on behalf of an
environmental justice and renewable energy nonprofit in state administrative proceedings
► At the University of Chicago Law School. Megan was an editor for The University of
Chicago Legal Forum and organized the journal's annual symposium.
► Prior to joining Edelson, Megan worked at a prominent international law firm where
she gained significant trial experience. She also maintained an active pro bono practice.
including representing women who were forced to flee Afghanistan during the fall of Kabul in
their asylum proceedings.
► Megan graduated from Washington University in St. Louis. where she earned her BA in
Anthropology and her MSW from the top-ranked Brown School of Social Work. Upon earning
her master's degree, Megan worked for a research lab applying systems sciences to social
issues and taught a graduate-level course in participatory system dynamics. In this role. she
founded the Changing Systems Summit, an annual event that trains students to use systems
thinking tools to address equity issues in their communities.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 54 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 68 of 76

0_773.906.5348
F_312.589.6378
h hi I ligoss@ede
Ison.
com
Hannah Hilligoss
Associate
Co-authored
a , eport
analyzing
the impacts
of Al on human
rights
to, the Be,
kman
Klein
Cente,
for Internet
and Society.
Hannah focuses on consumer and privacy-related class actions.
► Hannah received her J.D. from Harvard Law School, where she was a Student Editor on
the American Journal of Law and Equality and was on the Public Interest Committee for the
Women's Law Association.
► At Harvard, Hannah participated in the Cyberlaw Clinic, where she counseled an anti-
disinformation e-newsletter on their response to a cease and desist letter alleging Lanham
Act violations; drafted an amicus brief opposing national digital identity laws for a large
NGO; and worked with a documentary filmmaker to determine what third-party footage in
his film was fair use and what needed to be licensed.
► Prior to law school, Hannah worked at Harvard's Berkman Klein Center for Internet
and Society, developing ethical approaches to Al development and deployment and
combatting algorithmic discrimination in hiring and in the criminal justice system.
► Hannah graduated magna cum laude from Boston College with a degree in International
Studies.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 55 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 69 of 76

0_312.561.4106
F_312.589.6378
movca@edelson.com
Michael Ovca
Associate
Led m01
e than two dozen
p, ivacy
and tech class
actions.
Michael focuses on consumer, privacy-related and technology-related class actions.
► Michael leads groundbreaking work in seeking to protect consumer genetic privacy
under state genetic information privacy laws. Michael secured the first-ever adversarial
class certification in such a case, and was appointed class counsel there. Melvin v.
Sequendng LLC, 344 F.R.D. 231 (N.D. Ill. 2023).
► Michael also represents consumers in the firm's working holding companies accountable
for improperly using individual's identities to advertise their products in violation of
state right-of-publicity laws. In that work, Michael has helped secure numerous first-of-
their-kind rulings that led the way to record-breaking settlements. See Ascher v. Instant
Checkmate LLC No. 19-cv-04892 (N.D. Ill. Jan. 24, 2024)
► Michael has also represented governments, representing the City of Chicago against
Uber; various cities and towns in Illinois against opiate manufacturers, distributors, and
prescribes, and a village seeking to prevent closure of a hospital.
► Michael received his J.D. cum laude from Northwestern University, where he was an
associate editor of the Journal of Criminal Law and Criminology, and a member of several
award-winning trial and moot court teams.
► Prior to law school, Michael graduated sum ma cum laude with a degree in political
science from the University of Illinois.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 56 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 70 of 76

0_312.874.7650
F_312.589.6378
epenkowski@edelson.com
Emily Penkowski
Associate
Cum
laude
from
Northwestern
Unive,
sity
P, itzke,
School
of Law
Emily's practice focuses on representing governments, as well as privacy- and tech-
related class actions.
► Emily received her J.D. cum laude from Northwestern University Pritzker School of Law,
where she served as an Associate Editor of Northwestern University Law Review and
a Problem Writer for the 2020 Julius Miner Moot Court Board. Emily participated in the
Bluhm Legal Clinic's Supreme Court Clinic, where she worked on cases before the
Supreme Court including Ritzen Group, Inc. v. Jackson Masonry, LLC, 140 S. Ct. 582,
584 (2020). She placed on the Dean's List every semester and served on the student
executive boards for the Moot Court Society and the Collaboration for Justice, a justice
system reform-oriented student group.
► Emily spent her law school summers at the Maryland Office of the Attorney General and
the U.S. Attorney's Office for the Western District of Washington. In the Western District of
Washington, Emily assisted in prosecuting cryptocurrency money laundering, cybercrime,
and complex frauds. In Maryland, she wrote criminal appeals briefs for the State in the
Maryland Court of Special Appeals.
► Before entering law school, Emily worked as an intelligence analyst for the National
Security Agency, in the Office of Counterintelligence & Cyber (previously the NSA/CSS
Threat Operations Center) and the Office of Counterterrorism. She analyzed significant,
technical, complex, and short-suspense intelligence in support of law enforcement,
military, computer network defense, diplomatic, and other intelligence efforts, while
serving as a "reporting expert" for over three hundred analysts on an agency-wide
project. She also briefed NSA and military leadership on cyber and counterintelligence
threats to the U.S. government and military.
► As a digital network analyst, Emily increased intelligence coverage on a counterterrorism
target through social network analysis, including eigenvector and cluster analysis, used
metric databases to manage and prioritize intelligence collection, and worked with
collectors to streamline data flows and eliminate duplicative sources of information.
► Emily received her Bachelor of Science in International Studies, specializing in
Security and Intelligence, at Ohio State. She also received minors in Computer and
Information Science and Mandarin Chinese. She began learning Mandarin in high
school. During college, Emily interned at the National Security Agency, in the Office of
Counterproliferation, and at Huntington National Bank, on its Anti-Money Laundering and
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 57 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 71 of 76

0_720.741.0085
F _720.741.0081
aplawinski@edelson.com
Albert J. Plawinski
Associate
Wo,
ks on the development
of envi,
onmenta
I mass
tort
and mass
action
cases.
Albert identifies and evaluates potential cases and works with the firm's computer
forensic engineers to investigate privacy violations by consumer products and loT
devices.
► Albert works on the development of the environmental mass tort and mass action cases,
including preparing lawsuits on behalf of (1) victims of the California Camp Fire-the
largest and most devastating fire in California's history; (2) individuals exposed to toxic
chemicals in their drinking water; and (3) individuals exposed to carcinogenic ethylene
oxide.
► Albert received his J.D. from the Chicago-Kent College of Law. While in law school, Albert
served as the Web Editor of the Chicago-Kent Journal of Intellectual Property. Albert was
also a research assistant for Professor Hank Perritt for whom he researched various legal
issues relating to the emerging consumer drone market-e.g., data collection by drone
manufacturers and federal preemption obstacles for states and municipalities seeking
to legislate the use of drones. Additionally, Albert earned a CALI award for receiving the
highest course grade in Litigation Technology.
► Prior to law school, Albert graduated with Highest Distinctions with a degree in Political
Science from the University of Illinois at Urbana-Champaign.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 58 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 72 of 76

0_773.668.0328
F_312.589.6378
zseaman-grant@edelson.com
Zoe Seaman-Grant
Associate
Editor
of the Michigan
Joui
nal of Gende,
& Law
at the
University
of Michigan
Law
School.
Zoe's practice focuses on environmental and mass tort actions.
► Zoe received her J.D. from University of Michigan. During her time at Michigan, Zoe
served as a board member for Sexual Assault & Harassment Legal Advocacy Services
(SAHLAS), an organization that offered support to University of Michigan students filing
sexual misconduct complaints under Title IX.
► Zoe interned with the New York Attorney General's Torts Department and Davis Polk &
Wardwell. While in school, she worked as a Faculty Research Assistant at the University of
Michigan Law Library.
► Before law school, Zoe served as an AmeriCorps member with Reading Partners DC, a
nonprofit organization providing literacy support to public school students in Washington,
DC.
► Zoe graduated from Bates College, where she earned her B.A. in Women's and Gender
Studies. She completed an honors thesis titled "Constructing Womanhood and the
Female Cyborg: A Feminist Reading of Ex Machina and Westworld."
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 59 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 73 of 76

0_217.576.9229
F_312.589.6378
jzhu@edelson.com
Julian Li--Ying
Zhu
Associate
► Julian received his J.D. with Honors from the University of Chicago Law School, where
he was involved in the school's clinical program in environmental law and a writer for the
Chicago Journal of International Law (CJIL). He presented on the antitrust implications of
worldwide pharmaceutical settlements at CJIL.'.s annual symposium and was President of
the school's Public Interest Law Society.
► Prior to joining Edelson, Julian was an honors attorney in the U.S. Department of Justice's
Antitrust Division, where he primarily focused Section 1 investigations.
► Before law school, Julian was a policy analyst and writer for Restore Justice, a nonprofit
organization that advocates for the compassionate reform of Illinois' criminal justice
system for currently and formerly incarcerated Illinoisans. He was also a writer for the
BioCentury and a Science Policy Fellow at the Science and Technology Policy Institute in
Washington, DC.
► Julian graduated with Honors from the University of California, Berkley, where he
received a B.A. in Rhetoric and Molecular & Cellular Biology. As an undergraduate, Julian
was a writer and editor for the Triple Helix and the Berkeley Scientific Journals. He also
volunteered at the Neighborhood Justice Clinic of the East Bay Community Law Center
and conducted research for Professor David Oppenheimer on the history of diversity and
race-based hiring in California.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 60 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 74 of 76

O_
415.907.7478
F_312.589.6378
jlarsen@edelson.com
Jean Larsen
Associate
► Jean graduated cum laude with a degree in Politics and International Relations and
a minor in Geology from Scripps College and received my J.D. from the University of
California, Berkeley. She handles consumer protection investigations and litigation on
behalf of government clients.
► She is an Associate with the Public Client Team at Edelson PC. She handles
investigations and litigation on behalf of several state attorneys general against some of
the largest tech companies, including Meta and TikTok. At Berkeley Law, Jean served as
the President of the American Constitution Society and was a member of the Samuelson
Law, Technology, and Public Policy Clinic. Prior to law school she worked on political
campaigns and in government, most recently as a researcher on the Senate Judiciary
Committee.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 61 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 75 of 76

0_628.241.2926
F_312.589.6378
dki
esel
stei
n@ed
e Isa
n .com
Dan Kieselstein
Associate*
► Dan is an Associate* at Edelson PC. Dan received his J.D. from Harvard Law School,
where was involved in a number of student practice organizations and clinics focused on
public interest work. Dan was a student attorney at both the Criminal Justice Institute
and Harvard Defenders, both of which provide criminal defense representation for
indigent clients. He also interned at Brooklyn Defender Services, Public Advocates, and
the Advancement Project, and was president of Harvard Law School's branch of the
ACLU.
► Following law school, Dan worked for three years as a Staff Attorney at Brooklyn
Defender Services, where he represented indigent defendants in cases ranging from
misdemeanors to violent felonies. He then spent two years as a Law Clerk for the
Honorable Chief Judge Laura Taylor Swain of the Southern District of New York.
► Dan received Pro Bono Honors from Harvard Law School, which is awarded to
graduating students who complete over 1,000 hours of pro bono work.
*Admitted only in New York. Illinois admission pending. Supervised by a member of the
Illinois Bar.
Case 3:24-cv-00487-EMC Document 42-1 Filed 04/18/24 Page 62 of 62
Case 3:24-md-03098-EMC Document 9-2 Filed 04/22/24 Page 76 of 76

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Motion - Melvin v. Sequencing LLC, 344 F.R.D. 231 (N.D. Ill. 2023) (Illinois Genetic (2024-04-22)

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