In Re Quantcast Advertising Cookie Litigation

Filing 45

NOTICE OF MOTION AND MOTION to Certify Class (Preliminary Approval of Class action Settlement) filed by plaintiffs Alan Bonebrake, Byron Griffith, Mary Huebner, Jose Marquez, Austin Muhs, Brittany Sanchez, Edward Valdez, Gerardo Valdez, Kayla Valdez. Motion set for hearing on 12/16/2010 at 08:30 AM before Judge George H Wu. (Attachments: #1 Declaration of David A. Stampley, #2 Exhibit A (Settlement Agreement), #3 Exhibit B (Firm Resume))(Parisi, David)

Edward Valdez et al v. Quantcast Corporation et al

Doc. 45 Att. 3

Case 2:10-cv-05484-GW -JCG Document 45-3 #:424

Filed 12/03/10 Page 1 of 6 Page ID

Exhibit B
Dockets.Justia.com

Case 2:10-cv-05484-GW -JCG Document 45-3 K a m b e r L a w , LLC #:425

Filed 12/03/10 Page 2 of 6 Page ID
KamberLaw, LLP

100
Wall
Street,
23rd
Floor
N ew
York,
N ew
York
10005
t
212.920.3072
f
212.920.3081

1180
South
Beverly
Drive,
Ste.
601
L o s
A n g e l e s ,
C a l i f o r n i a
9 0 0 3 5
t
310.400.1050
f
310.277.0635
www.kamberlaw.com

Practice
KamberLaw
excels
in
litigating
complex
cases
brought
as
class
actions
or
by
plaintiff
groups.
The
firm
acts
with
the
spirit
of
public
service
and
community
mindedness
that
has
motivated
its
attorneys
throughout
their
legal
careers.
Our
attorneys
share
a
common
goal
of
seeking
justice
through
meaningful,
timely
vindication
of
consumer
rights.

We
specialize
in
cases
of
corporate
violations
of
consumers'
privacy
rights,
leading
one
federal
judge
to
observe,
"The
attorneys
of
KamberLaw
have
made
a
showing
that
they
possess
experience
and
expertise
in
the
areas
of
consumer
privacy
and
technology
matters
.
.
.
."
We
believe
these
cases
must
be
approached
with
skilled
legal
insight--plus
a
confident
grasp
of
the
defendant's
information
technology
model
and
business
environment.
That
is
why
our
unique
technology
expertise
and
our
backgrounds
as
defense
counsel,
corporate
compliance
counsel,
and
consultants
are
important
factors
in
our
success.
We
are
capable
of
explaining
what
went
wrong
and
communicating
a
thoughtful
view
of
how
to
make
it
right.
This
leads
to
resolutions
that
provide
timely
relief
to
affected
consumers
while
promoting
better
business
to
consumer
relationships.

With
ten
attorneys
in
offices
in
New
York
and
California,
KamberLaw
is
committed
to
advancing
the
cause
of
consumer
rights
from
coast
to
coast.
Listed
below
are
some
of
the
cases
that
exemplify
our
firm's
work
and
its
attorneys'
leadership.

S e l e c t e d Cases
New Technology and New Media
Lane,
et
al.
v.
Facebook,
Inc.,
No.
5:08
cv
03845
RS
(N.D.
Cal.
2010)
Slater
v.
Tagged,
Inc.,
No.
3:09
cv
03697
EMC
(N.D.
Cal.
2010)

Lead
counsel
in
data
privacy
case
relating
to
Facebook's
Beacon
technology.
Co
lead
counsel
in
data
privacy
case
involving
social
network
website's
acquisition
and
use
of
consumers'
email
address
book
information.

Valdez
Marquez,
et
al
v.
Netflix
Inc.,
No.
5:09
cv
05903
JW
(N.D.
Cal.
2010)
In
Re
ATI
Tech.
HDCP
Litigation,
No.
5:06
CV
01303
JW
(N.D.
Cal.
2009)

Co
lead
counsel
in
case
involving
privacy
consequences
of
release
of
anonymized
records
from
customer
database.

Co
lead
counsel
in
case
that
resulted
in
settlement
correcting
risk
of
harm
to
computer
users
caused
by
digital
rights
management
(DRM)
software
on
music
CDs.
Settlement
included
replacement
of
all
affected
music
CDs
and
an
award
of
additional
music
CDs
to
class
members.

In
Re
Quantcast
Advertising
Cookie
Litig.,
No.
2:10
cv
05484
GW
(N.D.
Cal.)
(inter
alia,
active)
ISP
behavioral
ad
targeting
cases
(multiple
jurisdictions,
active)

Co
lead
counsel
in
cases
involving
the
use
of
Adobe
Flash
to
override
the
privacy
and
security
settings
on
consumers'
browsers
to
track
and
profile
consumers.
Lead
counsel
in
six
data
privacy
cases
in
various
jurisdictions
against
ISPs
engaging
in
interception
and
analysis
of
customers'
Internet
communications
for
behavioral
ad
targeting.

Case 2:10-cv-05484-GW -JCG Document 45-3 #:426

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KamberLaw
Firm
Resume
Page
2

Valentine,
et
al.
v.
NebuAd
(No.
3:08
cv
05113
THE)
(N.D.
Cal.)
(active)
In
re
Sony
BMG
CD
Technologies,
No.
05
cv
09575
(S.D.N.Y.
2006)

Lead
counsel
in
data
privacy
case
involving
ECPA
(Wiretap
Act)
implications
of
online
ad
serving
company's
use
of
behavioral
targeting
technology.
Co
lead
counsel
in
case
that
resulted
in
settlement
correcting
risk
of
harm
to
computer
users
caused
by
digital
rights
management
(DRM)
software
on
music
CDs.
Settlement
included
replacement
of
all
affected
music
CDs
and
an
award
of
additional
music
CDs
to
class
members.

Weaver
v.
WebTV,
No.
793551
(Santa
Clara
Sup
Ct.,
Cal.
2003)

Co
lead
counsel
in
certified
nationwide
consumer
class
action
case
alleging
consumer
fraud
and
deceptive
advertising
of
computer
services
and
capabilities.
The
settlement
provided
the
class
with
a
collective
award
with
a
guaranteed
minimum
face
value
of
six
million
dollars.

Wormley
v.
GeoCities,
No.
196032
(Los
Angeles
Sup.
Ct.,
Cal.
2000)

Class
Counsel
in
consumer
class
action
for
privacy
violations
that
is
believed
to
be
the
first
Internet
privacy
case
to
recover
a
benefit
for
affected
class
members.

C o n s u m e r Protection and Products Liability
Lofton
v.
Bank
of
America,
No.
3:07
cv
05892
(N.D.
Cal.
2009)

Lead
counsel
in
class
action
alleging
deceptive
imposition
of
"fuel
related
fees"
in
connection
with
airline
ticket
purchases.
Settled
for
over
$2,000,000
in
cash,
in
addition
to
other
relief.

McFerren
v.
AT&T
Mobility,
LLC,
No.
08
CV
151322
(Fulton
Cty.
Sup.
Ct.
2009)

Lead
counsel
in
class
action
settlement
involving
16
related
cases
against
largest
wireless
service
provider
in
the
nation.
Settlement
provided
virtually
full
refunds
to
a
nationwide
class
of
consumers
who
alleged
that
unauthorized
charges
for
mobile
content
were
placed
on
their
cell
phone
bills.

Barrett
v.
RC2
Corp.,
No.
07
CH
20924
(Cook
Cty.,
Ill.
2008)

Appointed
co
lead
counsel
in
lead
paint
recall
case
involving
Thomas
the
Tank
toy
trains.
Settlement
valued
at
over
$30
million
provided
class
with
full
cash
refunds
and
reimbursement
of
certain
costs
related
to
blood
testing.

In
re
HP
Power
Plug
and
Graphic
Card
Litigation,
No.
06
2254
RMW
(N.D.
Cal.
2008)
In
re
Pet
Foods
Product
Liability
Litigation,
No.
07
2867
(D.N.J.
2008)

In
class
action
relating
to
defective
personal
computer
power
plugs,
settlement
provided
for
free
repairs
and
reimbursement
of
affected
consumers'
out
of
pocket
expenses.
Appointed
co
lead
counsel
in
class
action
involving
largest
pet
food
recall
in
United
States
history.
Settlement
provided
$24
million
common
fund
and
$8
million
in
charge
backs.

I n v e s t o r and Shareholder Derivative Actions
Stassi
et
al.
v.
Loch
Harris,
et
al.,
No.
GN
200180
(Travis
Cty.
Dist.
Ct.,
Tex.
2003)
In
re
Command
Systems,
No.
98
cv
3279
(S.D.N.Y.
1999)

Brought
derivative
action
on
behalf
of
technology
development
company
that
successfully
obtained
dissolution
of
corporation
and
distribution
of
assets
to
shareholders.
Securities
class
action
against
technology
company
in
which
participating
shareholders
recovered
over
80%
of
their
losses.

Case 2:10-cv-05484-GW -JCG Document 45-3 #:427

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KamberLaw
Firm
Resume
Page
3

Selected Attorney Biographies
The
attorneys
of
KamberLaw
have
been
recognized
as
leaders
in
their
fields
by
state
and
federal
legislatures,
national
and
international
media
groups,
the
courts,
and
peers.
We
have
testified
before
Congress
and
a
variety
of
federal
and
state
agencies
on
various
consumer
issues
and
have
been
asked
to
work
on
federal
and
state
legislation
involving
issues
of
import
to
consumers.
Our
attorneys
have
appeared
on
national
and
international
television
and
radio
programs
to
discuss
the
intersection
of
technology
and
the
law,
and
class
action
and
consumer
protection
issues
more
generally.

Our
reputation
for
leadership
in
class
action
litigation
has
led
state
and
federal
courts
to
appoint
us
lead
counsel
in
many
high
profile
class
action
suits.
Our
attorneys
speak
at
seminars
on
consumer
protection
and
technology
issues
to
corporate
and
consumer
audiences
in
the
United
States
and
around
the
world.
They
lecture
on
consumer
issues
and
class
action
law
at
law
schools
and
are
asked
to
serve
as
testifying
experts
in
cases
involving
various
consumer
issues.

Scott
A.
Kamber,
a
founding
member
of
KamberLaw,
has
served
as
lead
counsel
in
dozens
of
class

actions
resulting
in
hundreds
of
millions
of
dollars
in
relief
for
his
clients.
His
cases
have
set
prece
dents
for
Internet
privacy
rights
and
data
breach
liability.
Mr.
Kamber
worked
as
a
financial
consultant
and,
after
entering
private
legal
pratice,
represented
both
plaintiffs
and
defendants
in
a
wide
range
of
commercial
litigations,
initially
at
the
defense
firm
of
Hughes
Hubbard
&
Reed.
His
experience
and
understanding
of
defense
continues
to
inform
his
philosphy
of
effective
litigation.

His
interest
in
Internet
privacy
rights
began
in
the
1990s
when
he
resolved
what
is
believed
to
be
the
first
Internet
privacy
case
to
recover
a
benefit
for
impacted
class
members.
His
interest
in
consumer
rights
and
technology
extends
to
new
media,
and
he
has
led
standard
setting
litigations
and
resolutions
involving
digital
rights
management
software
for
computer
software,
video
games,
and
music.
He
is
the
only
plaintiff's
class
action
attorney
invited
to
speak
at
the
international
conference
of
data
protection
and
privacy
commissioners
and,
in
an
upcoming
speech,
by
the
Israeli
Ministry
of
Justice,
where
he
will
be
speaking
on
the
topic
of
coordinating
private
class
actions
with
government
enforcement.

In
pursuing
these
matters,
Mr.
Kamber
has
gained
extensive
courtroom
experience
and
tried
over
15
cases
to
verdict.
Beyond
litigation,
Mr.
Kamber's
commitment
to
the
value
of
effective
negotia
tion
and
dispute
resolution
has
served
him
in
an
active
and
broad
international
law
practice
that
has
taken
him
to
over
30
countries,
handling
negotiations
on
five
continents
and
structured
transactions
with
the
Olympic
Committees
of
several
Eastern
European
and
Latin
American
nations.
Mr.
Kamber
has
worked
to
vindicate
the
rights
of
African
torture
victims
and
worked
with
the
President
of
the
United
Nations
General
Assembly.
He
frequently
lectures
on
international
matters
and
is
a
regular
speaker
and
moderator
for
the
Center
for
International
Legal
Studies
based
in
Austria.
Mr.
Kamber
graduated
cum
laude
from
the
University
of
California
Hastings
College
of
the
Law
in
1991
where
he
was
Order
of
the
Coif,
Articles
Editor
for
the
Hastings
Constitutional
Law
Quarterly
and
a
member
of
the
Moot
Court
Board.
He
graduated
with
University
and
Departmental
Honors
from
The
Johns
Hopkins
University
in
1986.
He
is
admitted
to
practice
in
the
State
of
New
York
as
well
as
the
United
States
Supreme
Court,
the
United
States
Courts
of
Appeals
for
the
Second
and
Ninth
Circuits,
and
the
United
States
District
Courts
for
the
Southern
and
Eastern
Districts
of
New
York.
Mr.
Kamber
is
well
versed
in
the
procedures
and
practices
of
numerous
arbitration
forums,
both
domestic
and
international.

Case 2:10-cv-05484-GW -JCG Document 45-3 #:428

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KamberLaw
Firm
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Page
4

David
A.
Stampley,
a
partner
at
KamberLaw,
handles
class
actions
involving
consumer
data
privacy

and
security,
which
have
been
the
subject
matter
focus
of
Mr.
Stampley's
practice
for
over
ten
years.

Mr.
Stampley
has
previously
served
as
an
Assistant
Attorney
General
in
the
New
York
State
Attorney
General's
office,
where
he
led
landmark,
multistate
cases
to
protect
consumers`
online
privacy
and
security
in
enforcement
against
DoubleClick,
Ziff
Davis
Media,
Eli
Lilly
(the
prozac.com
data
breach),
and
AOL/Netscape
(SmartDownload
spyware).
In
that
role,
he
coordinated
cases
and
policy
issues
with
regulators
in
the
U.S.
and
abroad,
consumer
advocacy
organizations,
and
Internet
industry
representatives.
Mr.
Stampley
gained
extensive
trial
experience
as
an
Assistant
District
Attorney
in
the
premier
public
prosecutor's
organization,
the
Manhattan
D.A.'s
office.
Among
his
30
trials,
he
served
as
co
counsel
in
People
v.
Edward
Leary,
the
case
of
the
Manhattan
Subway
Bomber.
For
Neohapsis,
a
highly
regarded
provider
of
information
risk
management
and
security
consulting
services,
Mr.
Stampley
managed
digital
forensics
services.
He
regularly
served
as
a
member
of
Neohapsis'
consulting
teams
performing
information
technology
audits.
Mr.
Stampley
also
served
as
General
Counsel,
routinely
reviewing
the
terms
of
engagements
for
Neohapsis'
expert
services
and
for
Neohapsis'
engagement
of
expert
service
providers.

In
the
private
sector,
he
also
served
as
Director
of
Privacy
for
Reynolds
&
Reynolds,
a
global
Fortune
1000
technology
solutions
provider,
where
he
integrated
privacy
and
security
compliance
standards
into
the
solutions
development
life
cycle.
He
regularly
participated
in
the
evaluation
of
privacy
and
security
standards
for
Reynold's
solutions
and
in
its
engagement
of
technology
service
providers.
Mr.
Stampley
served
as
an
invited
expert
on
the
Platform
for
Privacy
Preferences
(P3P)
Vocabulary
Working
Group
of
the
WorldWide
Web
Consortium
(W3C).
He
is
a
Certified
Information
Privacy
Professional
and
has
been
a
Certified
Information
Systems
Security
Professional.
Mr.
Stampley
is
a
1991
graduate
of
the
University
of
Virginia
School
of
Law
where
he
was
a
Dillard
Fellow
and
received
his
B.A.
from
Mississippi
State
University
in
1979.
He
clerked
for
the
Honorable
Lenore
L.
Prather
on
the
Supreme
Court
of
Mississippi.
He
is
admitted
to
practice
in
the
State
of
New
York,
the
United
States
District
Courts
of
the
Southern
and
Eastern
Districts
of
New
York,
and
the
United
States
Supreme
Court.
Prior
to
entering
the
legal
profession,
Mr.
Stampley
worked
in
application
design
and
development
in
the
information
technology
field.

Deborah
Kravitz,
senior
counsel
at
KamberLaw,
has
a
unique
career
history
that
spans
the
corpo

rate
world,
U.S.
government,
and
a
high
profile
private
practice.
She
has
focused
on
complex
civil
and
criminal
litigation,
including
SEC
enforcement
and
securities
litigation,
white
collar
criminal
defense,
and
corporate
compliance.
In
addition
to
practicing
with
defense
firms
of
national
and
international
stature,
most
recently
with
Heller
Ehrman,
Ms.
Kravitz
served
as
a
federal
prosecutor
in
the
Tax
Division
of
the
Department
of
Justice.
In
addition,
as
the
chief
compliance
officer
of
a
global
company
serving
the
oil
and
gas
industry,
Ms.
Kravitz
was
an
integral
member
of
the
senior
management
team
and
was
responsible
for
the
implementation
of
a
global
compliance
program
during
a
period
of
time
when
the
company
was
under
a
deferred
prosecution
agreement
arising
from
violations
of
the
Foreign
Corrupt
Practices
Act.
This
broad
range
of
experience
allows
Ms.
Kravitz
to
develop
practical
solutions
to
a
wide
array
of
commercial,
litigation,
and
compliance
matters.
Ms.
Kravitz
graduated
with
honors
from
the
University
of
Maryland
School
of
Law
in
1991,
where
she
was
an
assistant
editor
for
the
Law
Review
and
member
of
the
Moot
Court
Board.
Following
law
school,
Ms.
Kravitz
clerked
for
the
Honorable
Deborah
K.
Chasanow
in
the
U.S.
District
of
Maryland.
Ms.
Kravitz
received
her
B.A.
in
International
Studies
from
the
Johns
Hopkins
University
in
1987.
She
is
admitted
to
practice
in
the
State
of
Maryland
and
the
District
of
Columbia.

Case 2:10-cv-05484-GW -JCG Document 45-3 #:429

Filed 12/03/10 Page 6 of 6 Page ID
KamberLaw
Firm
Resume
Page
5

Dana
B.
Rubin,
a
senior
associate
at
KamberLaw,
focuses
on
a
wide
range
of
class
action
issues.

Previously,
Ms.
Rubin
played
a
role
in
numerous
private
and
class
actions
on
behalf
of
shareholders
and
consumers.
She
has
also
represented
both
plaintiffs
and
defendants
in
employment
litigation
and
civil
rights
matters.
Ms.
Rubin
received
her
J.D.
in
1999
from
Fordham
University
School
of
Law,
where
she
was
an
Associate
Editor
of
the
Intellectual
Property,
Media
&
Entertainment
Law
Journal.
She
graduated
with
honors
from
the
University
of
Maryland,
College
Park
in
1993.
Ms.
Rubin
is
admitted
in
the
State
Courts
of
New
York
and
the
United
States
District
Courts
for
the
Southern
and
Eastern
Districts
of
New
York
and
is
a
member
of
the
New
York
State
Bar
Association.

Julian
Hammond,
senior
counsel
at
KamberLaw,
began
his
career
as
a
barrister
in
Sydney,
Australia

handling
a
variety
of
cases
from
securities
and
product
liability
class
actions
to
eminent
domain
issues.
Mr.
Hammond
has
represented
large
corporations
in
commercial
matters
and
advised
pollution
victims
following
a
large
oil
spill.
After
receiving
a
Masters
of
Law
from
the
NYU
School
of
Law,
he
focused
his
practice
on
employment
issues
from
sexual
harassment
to
wage
and
hour
cases.

Mr.
Hammond
received
his
law
degree
summa
cum
laude
from
the
University
of
Technology,
Sydney,
and
received
a
Masters
of
Law
from
New
York
University
Law
School.
He
was
on
the
Law
Student
Editorial
Board
at
the
University
of
Technology.
Mr.
Hammond
received
a
Bachelors
of
Commerce
from
the
University
of
New
South
Wales.
He
has
taught
legal
history
and
jurisprudence
and
property
law
at
the
University
of
Technology,
Sydney.
Mr.
Hammond
is
admitted
in
New
York,
California,
and
New
South
Wales,
Australia.