Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 1 of 60
`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 1 of 60
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`EXHIBIT 3
`EXHIBIT 3
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 2 of 60
`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 2 of 60
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`March 2023
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`Inside the Firm
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`We are a nationally recognized
`leader in high-stakesplaintiffs’ work,
`ranging from class and massactions,
`to public client investigations and
`A
`prosecutions.
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`edelson.com
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 3 of 60
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`★ ★ ★ ★ ★ ★ ★
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`“National reputation as a maverick in [its]
`commitment to pursuing big-ticket . . .
`cases."
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`—Law360
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 4 of 60
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`Table of Contents
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`Who We Are
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`In the News
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`Plaintiff's Class and Mass Action Practice
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`General Mass/Class Tort Litigation
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`Environmental Litigation
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`Banking, Lending, and Finance Litigation
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`Privacy and Data Security Litigation
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`General Consumer Litigation
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`Insurance Matters
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`Public Client Litigation and Investigations
`General Commercial Matters
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`Executive Committee
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`Founder & CEO
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`Global Managing Partner
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`Managing Partner, Boulder
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`Managing Partner, Chicago
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`Chief of Staff
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`Director of Human Resources
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`Associate Committee Liaison
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`Partners
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`Ryan D. Andrews
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`J. Aaron Lawson
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`Todd Logan
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`David I. Mindell
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`Roger Perlstadt
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`Jimmy Rock
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 5 of 60
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`Table of Contents
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`Nicholas Rosinia
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`Yaman Salahi
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`Ari Scharg
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`Alexander G. Tievsky
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`J. Eli Wade-Scott
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`Senior Litigation Counsel
`Associates
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`Theo Benjamin
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`Lauren Blazing
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`Megan Delurey
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`P. Solange Hilfinger-Pardo
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`Hannah Hilligoss
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`Patrick Ntchobo
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`Michael Ovca
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`Emily Penkowski
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`Albert J. Plawinski
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`Angela Reilly
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`Zoë Seaman-Grant
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`Brandt Silver-Korn
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`Schuyler Ufkes
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`Chief Information Officer
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 6 of 60
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`Who We Are
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`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.
`
` We hold records for the largest jury verdict in a privacy case ($925m),
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`the largest 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.
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` 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.
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` 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).
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`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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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 8 of 60
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`In the News
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`The firm and our attorneys regularly get recognized for our groundbreaking work. We have been named by Law360
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`as a Consumer Protection Group of the Year (2016, 2017, 2019, 2020), a Class Action Group of the Year (2019), a
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`Plaintiff's Class Action Powerhouse(2017, 2018, 2019), a Cybersecurity and Privacy Group of the Year (2017, 2018,
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`2019, 2020), a “Privacy Litigation Heavyweight,” a “Cybersecurity Trailblazer” by The National Law Journal (2016)
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`and won sole recognition in 2019 as “Elite Trial Lawyers” in Gaming Law. The National Law Journal also recognized
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`us as “Elite Trial Lawyers” in Consumer Protection (2020, 2021), Class Action (2021), Privacy/Data Breach (2020),
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`MassTorts (2020), and Sports, Entertainment and Media Law (2020). In 2019, we were recognized for the third
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`consecutive year as an “Illinois Powerhouse,” alongside Barack Ferrazzano, Winston & Strawn, Schiff Hardin and
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`Mayer Brown;in each year, we were the onlyplaintiff's firm, and the only firm with fewer than one hundred lawyers,
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`recognized. Edelson wasa twotime finalist (2021 and 2022) and one-time winner of the Diversity Initiative Award
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`(2021) by The National Law Journal, given to the plaintiffs firm demonstrating a concerted and successful effort to
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`promotediversity within its organization and the profession atlarge.
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 9 of 60
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`Our Practice
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`General Mass/Class Tort Litigation
`We currently represent, among others, labor unions seeking to recover
`losses arising out of the opioid crisis, classes of student athletes suffering
`from the long-term effects of concussive and sub-concussive injuries,
`hundreds of families suffering the ill-effects of air and water contamination in
`their communities, and individuals damaged by the “Camp Fire” in Northern
`California.
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`Representative cases and settlements include:
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` 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.
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` Representing hundreds of victims of Oregon's 2020 "Beachie Creek" and "Holiday
`Farm" fires, allegedly caused by local utility companies. The Beachie Creek and Holiday
`Farm fires together burned approximately 400,000 acres, destroyed more than 2,000
`structures, and took the lives of at least six individuals.
`
` 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.
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` Representing numerous labor unions and health and welfare funds seeking to recover
`losses arising out of the opioid crisis. See, e.g., Illinois Public Risk Fund v. Purdue Pharma
`L.P., et al., No. 2019-CH-05847 (Cir. Ct. Cook Cty., Ill.); Int’l Union of Operating Eng’rs, Local
`150, et al. v. Purdue Pharma L.P., et al., No. 2019-CH-01548 (Cir. Ct. Cook Cty., Ill.); Village
`of Addison et al. v. Actavis LLC et al., No. 2020-CH-05181 (Cir. Ct. Cook Cty., Ill.).
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 10 of 60
`Plaintiff's Class and
`Mass Action Practice
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`Environmental Litigation
`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:
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` 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.).
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` 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.).
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` 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).
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` Our team has been designated as Panel Members on a State Attorney General’s
`Environmental Counsel Panel.
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`Plaintiff's Class and
`Mass Action Practice
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`Banking, Lending, and Finance Litigation
`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.
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`Representative cases and settlements include:
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` 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
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`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.
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` 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.
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` 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.
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`Plaintiff's Class and
`Mass Action Practice
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`Privacy and Data Security
`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.
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` 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.
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`Plaintiff's Class and
`Mass Action Practice
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`Privacy and Data Security
` Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016): Lead counsel in the
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`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.
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` 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.
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` Kusinski v. ADP LLC, No. 2017-CH-12364 (Cir. Ct. Cook Cty. Ill.):
`Secured key victories establishing the liability of time clock vendors
`under the Illinois Biometric Information Privacy Act and the largest-
`ever BIPA settlement in the employment context with a time clock
`vendor for $25 million.
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` 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.
`
` Doe v. Ann & Robert H. Lurie Children’s Hosp. of Chi., No. 2020-
`CH-04123 (Cir. Ct. Cook Cty., Ill.): Lead counsel in a class action
`alleging breach of contract, breach of confidentiality, negligent
`supervision, and other claims against Lurie Children’s Hospital
`after employees allegedly accessed medical records without
`permission.
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 14 of 60
`Plaintiff's Class and
`Mass Action Practice
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`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.): Representing the American Civil
`Liberties Union in lawsuit against Clearview AI for violating the
`Illinois Biometric Information Privacy Act through its collection and
`storage of Illinois residents’ faceprints.
` Consumer Watchdog v. Zoom Video Commc'ns, Inc., No. 20-cv-
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`02526 (D.D.C): Representing advocacy group Consumer Watchdog
`in its lawsuit against Zoom Video Communications Inc, alleging the
`company falsely promised to protect communications through end-
`to-end encryption.
`
` 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.
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` 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.
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` 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.
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` 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.
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 15 of 60
`Plaintiff's Class and
`Mass Action Practice
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`General Consumer Matters
`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:
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` 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.
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` Prosecuted over 100 cases alleging that unauthorized charges for
`mobile content were placed on consumer cell phone bills. Cases
`collectively settled for over $100 million. 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.).
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` 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.
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` Brought numerous cases alleging that defendants deceptively
`designed and marketed computer repair software. Cases
`collectively settled for over $45 million. Beaton v. SpeedyPC
`Software, 907 F.3d 1018 (7th Cir. 2018).
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 16 of 60
`Plaintiff's Class and
`Mass Action Practice
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`General Consumer Matters
` 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 was valued at over $30 million and
`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.
`
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 17 of 60
`
`★ ★ ★ ★ ★ ★ ★
`
`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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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 18 of 60
`Plaintiff's Class and
`Mass Action Practice
`
`Insurance Matters
`We have successfully represented individuals and companies in a multitude
`of insurance related actions, including dozens of businesses whose business
`interruption insurance claims were denied by various insurers in the wake
`of the COVID-19 crisis. 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:
`
` Biscuit Cafe Inc. et al. v. Society Ins., Inc., No. 20-cv-02514 (N.D. Ill.);
`America's Kids, LLC v. Zurich American Ins. Co., No. 20-cv-03520
`(N.D. Ill.); MAIA Salon Spa and Wellness Corp. et al. v. Sentinel Ins.
`Co., Ltd. et al., No. 20-cv-3805 (E.D.N.Y.); Badger Crossing, Inc. v.
`Society Ins., Inc., No. 2020CV000957 (Cir. Ct. Dane Cty., WI); and
`Sea Land Air Travel, Inc. v. Auto-Owners Inc. Co. et al., No. 20-
`005872-CB (Cir. Ct. Wayne Cty., MI): In one of the most prominent
`areas for class action litigation related to the COVID-19 pandemic,
`we were among the first to file class action lawsuits against the
`insurance industry to recover insurance benefits for business
`owners whose businesses were shuttered by the pandemic.
`We represent an array of small and family-owned businesses—
`including restaurants and eateries, movie theatres, salons, retail
`stores, healthcare providers, and travel agencies—in a labyrinthine
`legal dispute about whether commercial property insurance
`policies cover business income losses that occurred as a result
`of business interruptions related to the COVID-19 pandemic. With
`over 800 cases filed nationwide to date, we have played an active
`role in efforts to coordinate the work of plaintiffs' attorneys through
`the Insurance Law Section of the American Association for Justice
`(AAJ), including by leading various roundtables and workgroups
`as the State Co-Chairs for Illinois, Wisconsin, and Michigan of
`the Business Interruption Litigation Taskforce (BILT), a national
`collaborative of nearly 300 practitioners representing policyholders
`in insurance claims arising out of the COVID-19 pandemic.
`
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 19 of 60
`Plaintiff's Class and
`Mass Action Practice
`
`Insurance Matters
` 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.
`
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`Case 3:21-cv-03943-WHO Document 54-3 Filed 03/28/23 Page 20 of 60
`Plaintiff's Class and
`Mass Action Practice
`
`Public Client Litigation and Investigations
`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.): Representing 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): Representing 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 w