Rupa Marya v. Warner Chappell Music Inc

Filing 305

DECLARATION of Tiffaney Janowicz in Support of NOTICE OF MOTION AND MOTION for Settlement Approval of Preliminary Approval of Proposed Class Action Settlement ; Memorandum of Points and Authorities in Support Thereof 301 filed by Plaintiffs Good Morning to You Productions Corp, Majar Productions LLC, Rupa Marya, Robert Siegel. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Manifold, Betsy)

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Senior Vice President

Tiffaney A. Janowicz, Esq.
625 Marquette Aveune, Suite 880
Minneapolis, MN 55402
D: 303.495.5501 M: 612.770.8805
E: [e-mail]

Education & Certifications
J.D. William Mitchell College of Law, 1995 (St. Paul, MN)
B.S. Marketing Education University of Minnesota, 1990 (Minneapolis, MN)
Tiffaney Janowicz leads Rust’s consumer as well as insurance and healthcare practice areas, with a depth of
experience in antitrust and product liability matters. She also provides guidance to a team of project management
professionals who handle projects in the same practice areas.
Janowicz began her career as a consultant at Rust in 1996 and was promoted to senior vice president in 2003. In
her current role, Janowicz specializes in customer relations and strategic consultation on claims administration
programs. Rust’s clients benefit from her expertise in developing and executing strategies designed to achieve
their settlement administration goals.
Janowicz has overseen all aspects of hundreds of settlements, including many of the firm’s largest claimsprocessing matters. Examples include Microsoft’s antitrust settlements for the states of California, Iowa,
Minnesota, New York and Wisconsin, as well as the multi-district litigation claiming that companies fixed the price
of Dynamic Random Access Memory (DRAM) in the United States. Janowicz has also lead many of Rust’s
insurance-related settlements and a number of credit life settlements.
Following are some additional details of cases that Rust has administered under the leadership of Janowicz.
In re Dynamic Random Memory (DRAM) Antitrust Litigation, MDL No. 1486 (N.D. Cal.). The lawsuits
combined into this multi-district litigation claimed that the Defendant companies fixed the price of DRAM
in the United States, causing individuals and businesses to pay more for DRAM and DRAM-containing
devices. The combined direct and indirect settlements totaled $310 million.
Maksimovic v. Sony of Canada Ltd., Ontario Superior Court of Justice, No. CV-11 425487-00CP.
This Canadian settlement resolved allegations that Sony failed to adequately safeguard the computer
systems used to provide the Sony PlayStation Network, the Qriocity service, and the Sony Online
Entertainment services, which were attacked by criminal intruders in April 2011. Rust managed the

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translation of all materials into French and provided all documentation and communication in both English
and French. Rust also established a Canadian P.O. box for the matter and drop-shipped the mail to our
processing center in Minnesota.
In re Nutella Marketing and Sales Practices Litigation, No. 3:11-cv-01086-FLW-DEA (D.N.J.).
Plaintiffs claimed that Defendant Ferrero U.S.A., Inc. made representations through its marketing and
advertising of Nutella® brand hazelnut spread, improperly suggesting that Nutella is healthier than it
actually is. Rust placed notice of the settlement in magazines and banner ads on popular websites; the
settlement website received over 1 million visits and over a quarter million consumers filed claims.
In re Online DVD Rental Antitrust Litig., MDL No. 2029 (N.D. Cal.). Rust sent over 34 million email
notices to potential class members in this project. Rust has processed more than 1.1 million claims for gift
cards or cash benefit in this ongoing project. Rust also created a settlement website which has to-date
received over 2.2 million site visits.
Microsoft I-V Cases, J.C.C.P. No. 4106, (Cal. Super. Ct. S.F. County). Janowicz was responsible for
the design and management of the direct mail notice program that involved the mailing of 18 million
notice-and-claim form packages and deployment of 7 million email notices to a class consisting of
consumers who purchased at retail selected Microsoft software for use in California. During the first years
of the multi-year program, Janowicz was actively involved in the daily project activities and second in
project responsibility only to the company president. Janowicz was and continues to be responsible for
overseeing project management, claims and voucher processing, benefits and cy pres distribution, and
call center activities.
The Authors Guild, Inc. v. Google, Inc., No. 05-cv-8135 (S.D.N.Y.). Janowicz led and continues to lead
her team in the administration services provided this settlement involving rights-holders around the world.
Janowicz oversaw the translations of the claim forms and supporting materials and well as the provision
of telephone support in more than 30 languages. For this ongoing project, Rust’s CSRs assist rightsholders in claiming their books and inserts, responding to questions related to the complex settlement and
providing technical support throughout the online claims process.
Thompson v. Metropolitan Life, No. 00-CIV-5071 (W.D. Pa.). Janowicz was second in project
responsibility only to the company president in overseeing Rust’s provision of services for this settlement,
which included an estimated 25 million policies. Rust mailed more than 550,000 customized and 104,000
generic notices to potential class members. In this race-based underwriting insurance settlement, Rust
received 220,000 claim forms, forwarded them on a rolling basis to the company for their research into
class membership, and followed up on the company’s direction by mailing 80,000 “cure” letters and more
than 270,000 response letters to claimants. Rust’s call centers answered calls generated by both the
mailed notice and an extensive media campaign. During the national TV noticing campaign, there were
500 call center operators in two sites.
McNeil v. American General Life & Accident, No. 3:99-1157 (D. Tenn.). Janowicz was second in
project responsibility only to the company president in the management of Rust’s claims administration
services for a settlement covering 9 million class members. Rust mailed over 3 million notices within
approximately two weeks. Rust also arranged for an ad campaign to help reach class members for whom
the company did not have current addresses. Rust received 600,000 calls on this project, and printed and
mailed more than 440,000 payments.

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Naef v. Masonite Corp., No. CV 944033 (Ala. Cir. Ct. Mobile County). Project involved receiving and
processing according to pre-determined criteria (including proof of property ownership, proof of product
ownership, and proof of damage) more than 400,000 claims, eventually distributing more than $800
million to more than 260,000 claimants whose claims were validated. Janowicz co-directed the initial
design of the claims intake process of this 10-year claims program, and managed claims review and
contact center operations.

Thought Leadership
Co-Author, “Estimating Claims – What Every Attorney Should Know,” What We’ve Noticed, Feb.
2015
Co-Author, “Increasing Judicial Attention to Claims-Filing Rates,” What We’ve Noticed, Oct. 2014
Co-Author, “The Case for Simplified Notice and Claims,” What We’ve Noticed, July 2014
Co-Author, “Tracking Ted…,” What We’ve Noticed, April 2014
Panelist, “Crafting Class Settlement Notice Programs: Due Process, Reach, Claims Rates, and
More – Minimizing Court Scrutiny and Overcoming Objector Challenges,” Strafford CLE Webinar,
Feb. 2014
Co-Author, “Efficient, Cost-Effective Notification and Administration in Antitrust Class Actions,”
Class Action Perspectives, 2013
Co-Author, “Recent Court Decisions Indicate Greater Scrutiny of Class Notice Programs,” What
We’ve Noticed, Dec. 2013
Panelist, “Mechanics, Logistics & Statistics: How to Settle a Class Action Lawsuit,” FDCC Section
Presentations for CLE 2013 Winter Program, March 2013
Panelist, “Emerging Trends in Class Action Notice,” CLE International 6th Annual Conference Class
Actions: Hot Topics, Winning Strategies and More, June 2010
Speaker, “Class Action Notice and Claims Administration: Trends and Innovation,” Women
Antitrust Plaintiffs' Attorneys Networking Event, Aug. 2009
Author, “Anticipating Claims Filing Rates in Class Action Settlements,” Class Action Perspectives,
Nov. 2008

Bar Admissions
Licensed to practice law in Minnesota

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