[00:00:08] Speaker 02:
I'd like to reserve five minutes for rebuttal and final.

[00:00:18] Speaker 02:
Your Honors, the final approval order and judgment in this case should be reversed because the district court failed to apply heightened scrutiny to this pre-certification class settlement that was reached prior to any decision on a contested motion for appointment of lead counsel under Rule 23 AG.

[00:00:41] Speaker 02:
and or all three sides of collusion that this court outlined in in red Bluetooth.

[00:00:52] Speaker 03:
What exactly is the deficiency here because he certainly held a hearing and considered this you know and articulated in the course of the hearing in the back and forth with counsel he clearly was considering

[00:01:26] Speaker 02:
or in any of the transcripts, why we shouldn't be concerned by these signs of collision.

[00:01:31] Speaker 03:
So it's an articulation issue.

[00:01:33] Speaker 03:
It's not that he wasn't aware of the issues.

[00:01:37] Speaker 03:
It's not that he didn't develop a record on the issues, because he clearly seems to have.

[00:01:42] Speaker 03:
It's an articulation issue, the fact that the order doesn't explain

[00:01:58] Speaker 02:
doubt, but I think more fundamentally, there's a real fairness problem with this settlement, and perhaps that's why the analysis isn't there.

[00:02:12] Speaker 02:
Most fundamentally, Your Honor, the settlement does award a disproportionate amount of fees to class counsel when compared to the relief obtained by the class.

[00:02:27] Speaker 02:
claims made settlement.

[00:02:30] Speaker 02:
So we have to look at the claims numbers that were reported at final approval in order to understand what the class is getting and compare that to the $800,000 in fees that class counsel received, right?

[00:02:45] Speaker 02:
And if we do that, which the court didn't really do in a meaningful way, we can see that it's a disproportionate award.

[00:03:00] Speaker 02:
of articulating, you know, what scrutiny was applied and the outcome of that.

[00:03:07] Speaker 01:
We address that by directing the district court to look at the fees again and perhaps reduce it.

[00:03:14] Speaker 01:
I know that's a prime result that neither side wants, but is that an option we have?

[00:03:19] Speaker 01:
Is anyone doing the settlement altogether?

[00:03:21] Speaker 02:
I think that the judgment should be reversed and I do think that directions should be given to the district court to make any award of fees commensurate with the relief actually obtained by class members.

[00:03:53] Speaker 03:
like us to do, set aside the settlement approval as well.

[00:03:58] Speaker 02:
Your Honor, I think you do have that authority, but I am also suggesting that there are fundamental fair decisions here.

[00:04:05] Speaker 02:
The question was narrower.

[00:04:06] Speaker 02:
Sure, sure, sure.

[00:04:09] Speaker 02:
And I appreciate that.

[00:04:13] Speaker 02:
If I may continue.

[00:04:15] Speaker 03:
I just want to focus.

[00:04:16] Speaker 03:
I want to understand why a reduction in the fees

[00:04:48] Speaker 03:
Why isn't then, at that point, the settlement okay under the relevant standard?

[00:04:56] Speaker 02:
Well, Your Honor, I simply think that analysis hasn't been done.

[00:04:59] Speaker 02:
If this court – It's procedural.

[00:05:03] Speaker 03:
I want to understand substantively why that is wrong.

[00:05:07] Speaker 03:
Okay.

[00:05:08] Speaker 02:
Your Honor, I think that could be accomplished if the lower court could satisfy itself and explain that settlement

[00:05:22] Speaker 02:
including the $800,000 award of attorney's fees is fair, reasonable, and adequate under the facts of this case.

[00:05:33] Speaker 02:
Does that make sense?

[00:05:57] Speaker 03:
if the fees are reduced.

[00:05:59] Speaker 02:
Okay, Your Honor.

[00:06:01] Speaker 02:
Rule 23 requires that a class settlement be fair, reasonable, and adequate to merit approval.

[00:06:07] Speaker 02:
And I think putting aside whether or not we're talking about fees specifically, we have to look at the amount that is obtained for the class in relation to the value of those claims, right?

[00:06:20] Speaker 02:
And I don't think that in

[00:06:55] Speaker 03:
argument that you've got this potential penalty under California law, but I have to say, as I went through it, that seemed to me like that's reaching for the golden ring, but not a ring you're likely to capture.

[00:07:08] Speaker 03:
There were some real reasons why.

[00:07:30] Speaker 03:
How quickly were the lawsuits filed after the publicity about the data breach?

[00:08:10] Speaker 03:
How do we not to the extent that if we have to determine what the appropriate fair value of the claim is that inevitably is going to require some consideration of not adjudicating the merits but trying to get a sense from the perspective of early in the case where you've got a wasting insurance policy and have reason to want to try to reach an early conclusion.

[00:08:46] Speaker 03:
have to suggest that's wrong.

[00:08:49] Speaker 02:
Sure, Your Honor.

[00:08:50] Speaker 02:
Well, I think when we're talking about a claims-made settlement where there is no common fund, no non-reversionary common fund that the defendant is paying out, any fairness analysis has to turn on the value of the actual claims submitted.

[00:09:16] Speaker 02:
Here, the numbers that were submitted to the court were grossly inflated.

[00:09:20] Speaker 02:
We pointed out in our papers how the claims for out-of-pocket reimbursement, which were capped at $1,000, were claimed for 176 of those claims.

[00:09:30] Speaker 02:
They claimed a value of $384,000 more than that, which obviously doesn't work if they're capped at $1,000.

[00:09:38] Speaker 02:
But beyond that, what we didn't point out in our papers, and I'd like to

[00:09:57] Speaker 02:
been caused by this data breach which according to defendant they say they paid the ransom there's no risk the mediator in this case during his testimony said these sorts of claims are highly unusual and they're not going to be validated until after the effective date when class counsel already has their fees and they claimed another almost $200,000

[00:10:34] Speaker 01:
level seems like it does provide class members with benefit.

[00:10:38] Speaker 01:
They get credit monitoring up to $1,000 in most cases.

[00:11:13] Speaker 02:
made settlement that requires looking at validated claims numbers if you're going to do this structure.

[00:11:20] Speaker 02:
Just as in a coupon settlement, you can only get fees after the coupons are redeemed, right?

[00:11:26] Speaker 02:
Isn't this similar?

[00:11:28] Speaker 02:
We don't know what the class is getting until those claims are validated.

[00:11:33] Speaker 02:
So how can counsel be awarded fees on some hypothetical claims number?

[00:11:43] Speaker 02:
obviously inflated claims numbers.

[00:11:46] Speaker 03:
We go back to the, the fairness.

[00:11:51] Speaker 03:
You argued with some justification that perhaps the value assigned to the settlement is subject to some deflation.

[00:12:26] Speaker 03:
guarantees some certain amount to the plaintiff's attorney.

[00:12:31] Speaker 03:
But from the class perspective, the settlement approval perspective, I'm still not hearing what I think I'm waiting to hear, which is why is it we think there's more value there than was realized in the settlement?

[00:12:44] Speaker 02:
Well, Your Honor, I know Your Honor already sort of didn't seem super impressed

[00:13:09] Speaker 02:
The business that collects personal information fails to employ reasonable security measures, and the victims of that data breach are entitled to those statutory damages.

[00:13:23] Speaker 02:
I see that as a strong claim.

[00:13:26] Speaker 02:
We might disagree.

[00:13:28] Speaker 02:
We might disagree about that.

[00:13:40] Speaker 02:
your honor I'm sorry I don't have an answer on that I wish I did and I'd be happy to submit additional briefing if your honor wanted that but I think it is a relatively new provision that we're talking about and certainly there are class settlements with let's see there there's good press

[00:14:09] Speaker 02:
compromises health-related information.

[00:14:13] Speaker 02:
And there are many class settlements in that context that give California class members preferential treatment and significant recovery, right, in recognition of the value of those claims.

[00:14:28] Speaker 02:
And I would contend that the same approach should be taken here and is merited at least at this point.

[00:14:37] Speaker 03:
We have used data breaches for

[00:14:55] Speaker 03:
that establishes or gives serious support to the proposition that any actual losses have been suffered by class members.

[00:15:06] Speaker 03:
Are we simply looking off to the future and trying

[00:15:24] Speaker 02:
And, you know, those need to be, you know, should, could be sussed out.

[00:15:33] Speaker 02:
But I think fundamentally the defendant says, well, we paid this ransom and all as well.

[00:15:38] Speaker 02:
We don't know that the, that the

[00:15:55] Speaker 02:
Well, we don't know if this hacker group is going to maintain its composure that way.

[00:16:02] Speaker 02:
I don't know who they are.

[00:16:04] Speaker 02:
I don't think anybody knows who they are.

[00:16:06] Speaker 02:
And will somebody take advantage of this valuable private information that the hackers obtained?

[00:16:12] Speaker 02:
That seems like a real risk to me.

[00:16:14] Speaker 02:
And I think that that means class members need to remain vigilant going forward.

[00:16:19] Speaker 02:
And they're going to need to do that for years.

[00:16:22] Speaker 02:
Did you want to say something?

[00:16:23] Speaker 02:
I would like to reserve time.

[00:18:07] Speaker 03:
He just didn't tell us.

[00:18:09] Speaker 03:
He made a great record and the ruling is a cipher.

[00:18:14] Speaker 00:
What do we do with that?

[00:18:16] Speaker 00:
That is the question here.

[00:18:34] Speaker 00:
is to look at the record holistically.

[00:18:37] Speaker 00:
So the court just recognized that he developed a heck of a record here over the course of about 10 months, starting in April 22, 2022, when he took the extraordinary step of

[00:19:03] Speaker 00:
the court hearings and talks about why it is that he rejects the allegations of collusion.

[00:19:10] Speaker 00:
He doesn't.

[00:19:10] Speaker 03:
He actually, on the record, because I went through the transcript to see maybe he orally sort of laid it out.

[00:19:18] Speaker 03:
All he does, he does identify the issues.

[00:19:20] Speaker 03:
He identifies quite a bit.

[00:19:21] Speaker 03:
Oh, I'm really worried about that issue.

[00:19:23] Speaker 03:
I'm really worried about that.

[00:19:25] Speaker 03:
And then the order, nothing.

[00:20:13] Speaker 00:
made.

[00:20:14] Speaker 00:
And also, Your Honor, there's a question here about the appellants and what they didn't do at any of these hearings.

[00:20:21] Speaker 00:
So what they didn't do at the preliminary approval hearing is ask to cross-examine Mr. Friedman.

[00:20:28] Speaker 00:
They didn't ask to call any of us to testify about what happened in this mediation.

[00:20:33] Speaker 00:
They didn't help to create the record that they basically are saying,

[00:20:45] Speaker 00:
and what they call the Kicker Clause.

[00:21:42] Speaker 00:
settlement where we got together with the defendant and said okay well we'll give you sweetheart terms on class relief if you give us a big fee.

[00:21:50] Speaker 00:
There would be no point to do it over two days on just class relief.

[00:21:54] Speaker 03:
It generates more hours.

[00:21:55] Speaker 03:
I mean it's easy to come up with an explanation.

[00:21:59] Speaker 03:
One of the problems in antitrust

[00:22:57] Speaker 00:
Common Fund Settlement, for example.

[00:23:42] Speaker 00:
going to have, you know, the ability of the plaintiff's lawyers to apply to the court who has the fiduciary duty to sort of look on behalf of the class at where the money's coming from.

[00:23:55] Speaker 03:
Common Fund Settlement defendant doesn't have an incentive.

[00:23:58] Speaker 03:
They paid out $5 million.

[00:24:00] Speaker 03:
After that, the court divides it up.

[00:24:02] Speaker 03:
In this context,

[00:24:12] Speaker 03:
counsel of this amount, which could produce a pretty hefty percentage of what otherwise might have been put together as a common fund.

[00:24:23] Speaker 03:
And that's really the problem in this case, because the amount being paid to the attorneys appears to be substantially above the 25 percent benchmark level.

[00:24:46] Speaker 03:
So it seems to me it's worlds apart from the common-fund situation.

[00:24:50] Speaker 03:
If CPK is willing to say, okay, we're going to pay 800 – say okay to $800,000 to the attorneys, why isn't that money the could have instead?

[00:25:15] Speaker 00:
of collusion.

[00:25:16] Speaker 00:
Three reasons, Your Honor.

[00:25:18] Speaker 00:
First of all, the district court has their fiduciary responsibility to the class to look out for the best interests of the class and to give the exact kind of heightened scrutiny that Judge Carter gave here to the attorneys for the award.

[00:25:32] Speaker 03:
I'll acknowledge that, except that the whole argument is that the record made doesn't demonstrate that he gave the heightened scrutiny.

[00:26:21] Speaker 00:
I fund and the third and most important thing your honor is that claims made settlements

[00:26:52] Speaker 00:
off any sort of reasonable expectations and where the attorney's fees ended up being a much smaller percentage of the whole amount that was actually paid to the class.

[00:27:01] Speaker 03:
The issue, the concern is that when you have this kind of clear sailing with a $800,000 cap, the defendant has basically said, I'm good for $800,000.

[00:27:14] Speaker 03:
If the court gives the full $800,000, I commit to it.

[00:27:18] Speaker 03:
And as between

[00:27:23] Speaker 03:
$800,000 will go on the table and, you know, the court will determine how much will go to fees, and the rest will be an additional common fund on top of the other forms of claims made relief.

[00:27:37] Speaker 03:
That'll go to the class members.

[00:27:40] Speaker 03:
The defendant is indifferent between those two.

[00:27:42] Speaker 03:
The defendant's out $800,000, potentially, either way.

[00:28:03] Speaker 00:
us a lesser award we wouldn't have appealed it and in fact

[00:28:44] Speaker 00:
include the cost of notice of administration, you come up with this amount, and you can backwards engineer to a 25 percent sort of number.

[00:28:52] Speaker 00:
But on the fees, Your Honor, it was sort of a two-part analysis.

[00:28:56] Speaker 00:
The district court here did basically evaluate the fees first and foremost on the lodestar method, and did so in accordance with the case law, which basically says for these claims made... But there's nothing in the record that the court scrutinized that lodestar at all.

[00:29:20] Speaker 01:
really scrutinized the lodestar here.

[00:29:23] Speaker 00:
Scrutinized it only in the sense that it looked at sort of the total number of hours and looked at the hourly rates, found that the hourly rates were commensurate with the hourly rates that are paid in the Los Angeles legal community.

[00:29:35] Speaker 01:
Can you address the September 22 hearing, I think you have represented to the court, that the unvalidated claims were worth about $1.16 million, and of those there were 176 or

[00:29:51] Speaker 01:
$384,000.

[00:29:52] Speaker 01:
Do you agree that that has to be corrected or has been corrected to $176,000 because it's capped $1,000 per person?

[00:30:01] Speaker 00:
Yeah, I want to explain how the

[00:30:27] Speaker 00:
that it should have been capped off.

[00:30:32] Speaker 01:
Most the value of the claims to the class is around $900,000, right?

[00:30:39] Speaker 00:
It's between $900,000 and $1,000,000, Judge Lee, and I did a rough calculation of it.

[00:30:46] Speaker 00:
If you did sort of back out

[00:31:02] Speaker 00:
the court found was reasonable, given that the percentage of the benefit here was used as a cross-check only on the lodestar.

[00:31:13] Speaker 00:
And, you know, so it's a matter of degrees.

[00:31:15] Speaker 00:
We're going from 36.3 percent to the shade over 40 percent.

[00:31:20] Speaker 00:
If you take, you know, what is this post hoc argument by appellants that they didn't give to Judge Carter that, you know, you should cut that number down.

[00:31:35] Speaker 01:
reasonable, maybe we could look at the record and say that this record does that, maybe we could do that.

[00:31:42] Speaker 01:
But with the fees, there's nothing in the record explanation.

[00:31:45] Speaker 01:
In fact, at one point earlier, the judge says, well, if the claims are worth $800,000 and the attorneys are asking for $800,000, I'm not going to approve it.

[00:31:53] Speaker 01:
And it turns out it's pretty much like that, but somehow the court approved it.

[00:31:56] Speaker 01:
And we have no idea how or why the court approved the fees.

[00:32:01] Speaker 00:
Again, Your Honor, I believe that

[00:32:22] Speaker 00:
that in preparation for this

[00:32:56] Speaker 00:
needed to do it with the supplemental briefing on the attorney's fee question that was commissioned by Judge Carter and that was submitted on November 21st, 2022.

[00:33:08] Speaker 00:
The additional hearing that he had that was specific, the December 5th, 2022 hearing, which was all about the attorney's fees.

[00:33:15] Speaker 00:
So again, this court has to decide whether or not you're going to create a bright line rule that the

[00:33:24] Speaker 00:
pen to paper and really, you know, write this all out or whether or not we can sort of adopt to a model where there's a holistic record here created over the course of many pleadings and many hearings that the court, this court, can rely upon to evaluate whether or not the district court did apply the heightened scrutiny.

[00:33:44] Speaker 01:
What's your best case for justifying with a cross check, something like 42 percent here?

[00:33:50] Speaker 00:
Your Honor, in terms of that percentage,

[00:34:16] Speaker 01:
I would disagree with that.

[00:34:27] Speaker 00:
I think that number one, the benefits here are just

[00:34:55] Speaker 00:
And in terms of the penalty, she get to 1.8 percent.

[00:34:59] Speaker 00:
That seems to make Judge Lee's point.

[00:35:02] Speaker 00:
Well, I've never been able to figure out exactly what causes class members to make claims or not make claims, Your Honor.

[00:35:09] Speaker 00:
But, you know, I would say that $900,000 of claimed relief is not nothing.

[00:35:15] Speaker 00:
It'd justify 42 percent.

[00:36:30] Speaker 00:
And so, basically, you know, is this good value for a case of this type, a doubtful and disputed case that is negotiated right on the heels of the Trans-Union decision, Trans-Union versus Ramirez, which talks, you know, very much about, you know, people not having claims who don't suffer any injury.

[00:36:51] Speaker 00:
This is a good value for the class.

[00:36:54] Speaker 00:
I see I'm way over my time, and I apologize.

[00:37:29] Speaker 03:
the parties structured the settlement.

[00:38:21] Speaker 03:
exceptionally weak.

[00:38:23] Speaker 03:
And this goes back to your

[00:38:56] Speaker 03:
program leader.

[00:39:33] Speaker 03:
will delete any data.

[00:40:05] Speaker 03:
relying upon jailhouse informants.

[00:40:08] Speaker 03:
And one of the points he made very clearly is that they're criminals, and you can only trust them so far.

[00:40:14] Speaker 03:
And I sit and hear this, and let me pose the question that's really gnawed at me the most, which is that suppose your criminal turns out

[00:40:29] Speaker 03:
organization that go rogue and the dark web is out there and it may be the number of social security numbers breached were limited but what

[00:41:24] Speaker 03:
everyone.

[00:41:25] Speaker 03:
Anyone who wants to opt out can opt out.

[00:41:28] Speaker 03:
So people who are worried about the risk you lay out, we did in fact have four people opt out.

[00:41:33] Speaker 03:
Four out of how many?

[00:41:53] Speaker 03:
gets caught up in it sometime down the road.

[00:41:56] Speaker 03:
I mean, this isn't just this case.

[00:41:57] Speaker 03:
It's the data breach cottage industry, the settlement cottage industry that's developed and leads me wondering, gee, what happens to the guy

[00:42:42] Speaker 03:
I have a further question.

[00:42:46] Speaker 03:
This is a difficult thing, so we want to hear from you.

[00:42:49] Speaker 03:
It is, and that's why in these cases, frequently what we do is we challenge whether the plaintiffs even have Article III standing, because the theoretical harm that you've outlined, it's not imminent harm, and these people can't show actual damage at this point.

[00:43:31] Speaker 03:
for CPK's person explaining, whatever caused that, we had no information about his debit account.

[00:43:38] Speaker 03:
So he may have had somebody try and do something fraudulent with his debit account, but employees don't tell CPK usernames or passwords or their debit account.

[00:43:47] Speaker 03:
Yeah, we don't do that.

[00:43:48] Speaker 03:
Same thing with his Amazon account.

[00:43:50] Speaker 03:
He may have had something bad happen with his Amazon account, but he hadn't given to CPK any information about his Amazon account.

[00:44:40] Speaker 03:
must give a reasoned response to all non-frivolous objections.

[00:44:46] Speaker 03:
And then we went on to say here the district court did not satisfy this procedural standard.

[00:44:53] Speaker 03:
We take no position on the substantive fairness of the agreement because the record before us does not allow us to undertake even our deferential substantive review.

[00:45:02] Speaker 03:
Why don't we have the same problem here?

[00:45:03] Speaker 03:
Because he laid all the problems on the table and he said on the record, yeah, that's a really big problem.

[00:45:15] Speaker 03:
I think it's fairly clear from the record as a whole that Judge Carter did take quite seriously these allegations of collusion and examined that.

[00:45:27] Speaker 03:
No question, but I don't know why he said he was troubled by it and then the next day he wasn't and I don't know why.

[00:45:40] Speaker 03:
It's like, offer something to actually prove it.

[00:45:43] Speaker 03:
We had a hearing.

[00:45:44] Speaker 03:
I was there.

[00:45:45] Speaker 03:
If anybody wanted to swear me in and have me give testimony, okay, I was there.

[00:45:49] Speaker 03:
They didn't ask for that.

[00:45:50] Speaker 03:
Mr. Leets was there.

[00:45:51] Speaker 03:
The transcript reflects Mr. Leets was there.

[00:45:54] Speaker 03:
Ms.

[00:45:54] Speaker 03:
Byrd was there.

[00:45:55] Speaker 03:
But he doesn't say on the transcript, any explanation is, ah, now I see it, and this resolves my complaint.

[00:46:11] Speaker 03:
the very next day the order comes out of his

[00:46:37] Speaker 03:
actually ask us to bring in the mediator and put people under oath and testify.

[00:46:41] Speaker 03:
And that transcript reflects that after hearing the mediator's testimony, Judge Carter was satisfied.

[00:46:48] Speaker 03:
So I believe the record as a whole does meet this Court's requirements.

[00:46:55] Speaker 03:
Any other questions, Your Honor?

[00:46:57] Speaker 03:
Thank you very much, Your Honor.

[00:47:07] Speaker 02:
I'd just like to take a minute to look at the record, which everybody seems to agree is quite important.

[00:47:13] Speaker 02:
After questioning the mediator, the district court called the settlement reversionary, said $800,000 in fees is too much.

[00:47:35] Speaker 02:
about it, we quoted it in our papers.

[00:47:39] Speaker 02:
As Your Honor noted, the District Court never explained why all of these issues shouldn't cause us any concern or why he was satisfied that despite these issues, the settlement was fair, reasonable, and adequate.

[00:47:54] Speaker 02:
There's just nothing in the record to address those obviously glaring concerns.

[00:48:12] Speaker 02:
is that by the time they got to mediation, the settling plaintiffs and defendants had already agreed on a claims-made structure.

[00:48:22] Speaker 02:
And they were just negotiating amounts, is the way the mediator put it, to fill that in.

[00:48:27] Speaker 02:
So they'd already agreed on this preferential structure for defendants by the time they got there.

[00:48:35] Speaker 02:
And as we pointed out in our papers, the mediator said,

[00:48:41] Speaker 02:
He's done over a dozen data breach settlements in all, except for one, which was a health data breach settlement had been settled on a claims made basis, which I find astonishing given the large number of data breach settlements that do settle on a common fund basis.

[00:49:01] Speaker 02:
And what's the claims rate from the common fund?

[00:49:06] Speaker 02:
It varies, Your Honor.

[00:49:25] Speaker 02:
The difference is it gives the money out from the defender.

[00:49:57] Speaker 02:
Your Honor, I'm not sure that the claims rate is going to be higher in a claims made versus a common fund settlement, but we do know that there is a common fund settlement.

[00:50:09] Speaker 03:
The argument I thought I was hearing, the problem here is that they had a claims made structure from the beginning, and aha, that's a problem, but it turns out if there's not really a difference in the claims rate, that's not a problem, it's not an indicator at all.

[00:50:22] Speaker 03:
It's how much is out there to be claimed that makes the difference, and that's a different question.

[00:50:33] Speaker 02:
and you cannot make that determination until all the claims are in and have been scrutinized.

[00:50:39] Speaker 02:
I do want to make one more point with regards to what you can do for folks who may suffer harm in five years, and that's get them as much as possible now.

[00:51:01] Speaker 02:
reasonably soon thereafter, when it could be, you know, we've negotiated settlements where the credit monitoring takes effect after expiration of any similar service that the claimant may have, which would provide an added benefit.

[00:51:14] Speaker 03:
I didn't say anything about what payouts were actually made, how many of the claims made were actually allowed and paid.

[00:51:24] Speaker 02:
No, Your Honor, they have not been validated.

[00:51:26] Speaker 02:
The one thing the record

[00:51:32] Speaker 02:
at some point in the future, presumably, if this settlement were affirmed, the administrator would sit down and look at these claims and decide which were valid and how much they could be honored for.

[00:51:45] Speaker 02:
And I think, by the way, looking at these numbers, I see the total value of the settlement to class members coming to both $761,000.

[00:51:55] Speaker 02:
That's excluding the notice administration.

[00:52:12] Speaker 02:
do that here.