Jantos v. DirecTV et al

Filing 46

ORDER granting parties' 45 Renewed Joint Motion for Preliminary Approval of Class Action Settlement. Final Approval Hearing set for 6/7/2019 at 11:00 AM in Courtroom 15206. Signed by Judge Thomas S. Zilly. (SWT)

HON. THOMAS S. ZILLY

1
2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9
10

JAMES JANTOS, individually, and on behalf
of similarly situated individuals,
Plaintiff,

11

v.
12
13
14
15

NO. 2:18-cv-00413-TSZ
ORDER GRANTING PRELIMINARY
APPROVAL OF CLASS ACTION
SETTLEMENT

DIRECTV, a Delaware Corporation;
DIRECTV, LLC, a California Limited Liability
Corporation; and QWEST CORPORATION
d/b/a CENTURYLINK QC, a Colorado
Corporation,
Defendants.

16
17
18
19
20
21
22
23
24
25

THIS MATTER comes before the Court on the parties’ renewed joint motion for
preliminary approval of class action settlement, docket no. 45, which is GRANTED as follows.
On December 12, 2018, Plaintiff James Jantos, on behalf of himself and the Settlement Class, as
defined below, and Defendants DIRECTV, DIRECTV, LLC, and QWEST CORPORATION
d/b/a CENTURYLINK QC (“Defendants”) (collectively, “the Parties”), executed an Amended
Class Action Settlement Agreement and Release of All Claims (“Settlement Agreement” or
“Agreement”), docket no. 45-1. For purposes of this Order, all of the definitions for the terms set
forth in Section I of the Parties’ Settlement Agreement shall apply. Having reviewed the
Settlement Agreement and considered the Parties’ original and renewed submissions in support

26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 1
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

of preliminary approval of the Settlement, the Court now FINDS, CONCLUDES, AND ORDERS

2

as follows:

3

I.

CERTIFICATION OF THE SETTLEMENT CLASS

4

The Agreement settles all Released Claims, as defined therein, that have been or could

5

have been brought in this putative class action. The Agreement provides for a nationwide class

6

settlement of the Released Claims concerning the alleged online accessibility by others of certain

7

information of Plaintiff and other Settlement Class Members found in their CenturyLink bills,

8

which is the subject of this litigation (the “Federal Action”) and in a corresponding lawsuit, Case

9

No. 17-2-12346-3, brought by Plaintiff in King County Superior Court for the State of

10

Washington (the “State Action”). The nationwide Settlement Class includes one subclass; namely,

11

the DIRECTV Subclass.

12
13

A.

The Court hereby finds as follows:
1.

CenturyLink has identified 855 of its current and former customers in the

14

United States and its territories as customers whose bills were potentially accessible online

15

by others, at a World Wide Web Uniform Resource Locator (“URL”) beginning with

16

“repsweb.centurylink.com,” between March 5, 2017, and May 18, 2017. Of those 855

17

CenturyLink customers, 311 also subscribed to DIRECTV services, information about

18

which was contained in their CenturyLink bills that were accessible online by others, at a

19

URL beginning with “repsweb.centurylink.com,” between March 5, 2017, and May 18,

20

2017. These numbers satisfy the numerosity requirement for class certification.

21

2.

There are questions of law and fact common to all members of the

22

Settlement Class based on the online accessibility of their CenturyLink bills by others,

23

including:

24
25

a.

Whether each Defendant qualified as a telecommunications or

satellite carrier;

26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 2
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

b.

1

Whether the information on the bills potentially accessible by

2

others online qualified as customer proprietary network information or personally

3

identifiable information concerning a subscriber;
c.

4

Whether Defendants violated federal law in connection with the

5

online accessibility by others of the Settlement Class Members’ CenturyLink bills,

6

some of which included information about DIRECTV services; and

7

d.

8

alleged violation.

9

3.

Whether class members are entitled to statutory damages for that

The Class Representative’s claims are typical of the Settlement Class and

10

the DIRECTV Subclass. The Class Representative is a member of the Settlement Class

11

and the DIRECTV Subclass and alleges he has been damaged by the same conduct of

12

Defendants that he alleges has damaged other members of the Settlement Class, including

13

the DIRECTV Subclass. The Class Representative’s claims are not in conflict with or

14

antagonistic to the claims of the Settlement Class as a whole or the claims of the

15

DIRECTV Subclass. The claims of the Class Representative and other members of the

16

Settlement Class and DIRECTV Subclass are based upon corresponding theories.

17

4.

The Settlement Class is ascertainable. The unnamed members of the

18

Settlement Class have in common that they each were identified by CenturyLink as

19

someone whose CenturyLink bill(s) were potentially accessible online by others, at a URL

20

beginning with “repsweb.centurylink.com,” between March 5, 2017, and May 18, 2017.

21

5.

The Class Representative can fairly, fully, and adequately protect the

22

interests of the Settlement Class and the DIRECTV Subclass. Plaintiff’s counsel is

23

experienced in prosecuting complex class-action litigation, and the Class Representative

24

and Class Counsel have no interest that conflicts with, or is adverse to, the interests of the

25

Settlement Class or the DIRECTV Subclass.

26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 3
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

6.

Questions of law and fact common to all members of the Settlement Class

2

predominate over any questions affecting only individual members for settlement

3

purposes.

4

7.

A nationwide class action with one subclass for settlement purposes is

5

superior to other available methods for the fair and efficient adjudication of this

6

controversy.

7

B.

8

Subclass for settlement purposes only:

9

The “Settlement Class” shall consist of all 855 current and former
customers of CenturyLink in the United States and its territories who
were identified by CenturyLink as customers whose CenturyLink
bills were potentially accessible online by others, at a URL beginning
“repsweb.centurylink.com,” between March 5, 2017, and May 18,
2017.

10
11
12
13

The “DIRECTV Subclass” shall consist of Settlement Class
Members whose CenturyLink bills were potentially accessible online
by others, at a URL beginning “repsweb.centurylink.com,” between
March 5, 2017, and May 18, 2017, and included information about
their DIRECTV services.

14
15
16
17
18
19
20
21
22
23
24

The Court hereby CERTIFIES the following Settlement Class and DIRECTV

C.

The Court appoints Plaintiff James Jantos as the Class Representative of the

Settlement Class and the DIRECTV Subclass. The Court appoints the law firms of Sirianni Youtz
Spoonemore Hamburger, and Myers & Company, PLLC as Class Counsel for the Settlement
Class and the DIRECTV Subclass.
D.

If for any reason the Settlement Agreement ultimately does not become effective,

the parties may request that this Order certifying a nationwide class and subclass be vacated and
that the Parties be returned to their respective positions in this lawsuit as those positions existed
immediately before the Parties executed the Settlement Agreement. Nothing stated in the
Settlement Agreement or in this Order shall be deemed an admission or waiver of any kind by

25
26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 4
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

any of the Parties or used as evidence against, or over the objection of, any of the Parties for any

2

purpose in this action or in any other action or proceeding of any kind.

3
4

II. PRELIMINARY APPROVAL OF THE TERMS OF THE SETTLEMENT

A.

Defendants have at all times disputed, and continue to dispute, Plaintiff’s

5

allegations in this lawsuit, deny any liability for any of the claims that have or could have been

6

alleged by Plaintiff or other members of the Settlement Class, and maintain that no customers

7

suffered any actual damages as a result of the online availability of their CenturyLink bill.

8
9

B.

The Settlement requires Defendants to provide specified benefits to each

Participating Settlement Class Member, as defined and set forth in the Settlement Agreement.

10

1.

All Settlement Class Members that have not excluded themselves from the

11

Settlement will receive an activation code for one year of three-bureau credit monitoring

12

service and $1 million in identity theft insurance, which has an approximate retail value

13

of $180.

14

2.

All DIRECTV Subclass members that have not excluded themselves from

15

the Settlement will receive, in addition to the ability to activate credit monitoring service

16

and identity theft insurance, $520 in the form of a credit to their CenturyLink bill if they

17

are a Current CenturyLink Customer. Current CenturyLink Customers may seek

18

distribution of any credit balance on their account in accordance with the usual policies

19

and procedures of CenturyLink for refunding credit balances. The initial determination of

20

who qualifies as a Current CenturyLink Customer will be based upon CenturyLink’s

21

records as of the date of this Order.

22

3.

All DIRECTV Subclass members that have not excluded themselves from

23

the Settlement and who are no longer Current CenturyLink Customers as of the date that

24

the class benefit is provided to Settlement Class Members will receive, in addition to the

25

ability to activate credit monitoring service and identity theft insurance, $520 payable by

26

check.
ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 5
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

C.

Defendants have already identified all Settlement Class Members and all

2

DIRECTV Subclass members and, therefore, no Settlement Class Member or DIRECTV Subclass

3

member will be required to prove their eligibility to receive the benefits stated herein.

4

D.

On a preliminary basis, therefore, taking into account (1) the defenses asserted by

5

Defendants, (2) the risks to the Settlement Class Members that Defendants would successfully

6

defend against claims arising out of the facts and legal theories pleaded and asserted in this case,

7

whether litigated by members of the Settlement Class themselves or on their behalf in a class

8

action, (3) the statutory damages provision in the Satellite Home Viewer Extension and

9

Reauthorization Act, the violation of which is alleged by the DIRECTV Subclass only, and the

10

non-availability of statutory damages under the Telecommunications Act, the violation of which

11

is alleged by all Settlement Class Members, and (4) the length of time that would be required for

12

members of the Settlement Class, or any group of members of the Settlement Class, to obtain final

13

judgment through one or more trials and appeals, the Settlement appears fair, reasonable, and

14

adequate. Moreover, the Parties have reached the Settlement after litigating the claims and

15

defenses raised in this case and corresponding State Action, both formal and informal discovery

16

conducted by the Plaintiff, Class Counsel, and Defendants, and an arm’s-length negotiation that

17

included a full-day mediation session and subsequent negotiations. Further, according to the

18

Parties, they reached the terms of the Settlement Agreement without agreeing on the reasonable

19

amount of attorneys’ fees and litigation expenses to be awarded to Class Counsel, which further

20

suggests that the Settlement is the product of an arm’s-length negotiation process. For all these

21

reasons, the Settlement falls within the appropriate range of possible approval and does not appear

22

in any way to be the product of collusion.

23
24

E.

Accordingly, it is ORDERED and ADJUDGED that the Settlement Agreement

and corresponding Settlement are hereby preliminarily approved.

25
26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 6
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

III. APPROVAL OF THE CLASS NOTICE, PLANS FOR ITS DISTRIBUTION
TO SETTLEMENT CLASS MEMBERS, AND RESPONSIBILITIES OF THE
SETTLEMENT ADMINISTRATOR AND THE PARTIES

A.

As provided for in the Settlement Agreement, the Parties have submitted (i) a form

of Class Notice, including a Request for Exclusion form, and Frequently Asked Questions and
Answers (“FAQ”), to be mailed and emailed to Settlement Class Members; (ii) a plan for
distributing the Class Notice; (iii) a plan for establishing a Settlement Website, which will include
the FAQ and other information and documents that the Parties jointly agree to post concerning
the nature of the case and the status of the Settlement, including a copy of the Class Notice, a
copy of the FAQ, information relating to relevant deadlines, a copy of Class Counsel’s Fee
Application, a complete copy of the Settlement Agreement, and relevant orders of the Court.
B.

The proposed plan for distributing and publishing the Class Notice, FAQ, and

Settlement Website appears reasonably likely to notify members of the Settlement Class of the
Settlement. The proposed plan for publishing the Class Notice on the Settlement Website and for
mailing and emailing (if Defendants can reasonably verify an email address) the Class Notice to
Settlement Class Members is fair and reasonable.

The proposed plan satisfies the notice

requirements of Federal Rule of Civil Procedure 23(e) and all applicable federal laws.
C.

The Class Notice, FAQ, and Settlement Website will fairly, accurately, and

reasonably inform members of the Settlement Class of (1) appropriate information about the
nature of this litigation and the essential terms of the Settlement Agreement; (2) appropriate
information about how to obtain additional information regarding this matter and the Settlement
Agreement; and (3) appropriate information about, and means for, objecting to or excluding
themselves from, the Settlement, if they wish to do so. The Class Notice and Settlement Website
also fairly and adequately inform members of the Settlement Class that if they do not comply with
the specified procedures and deadline for excluding themselves from the Settlement, they will be
bound by the Settlement and lose any opportunity to bring any of the Released Claims against the
Released Parties.

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 7
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

D.

The Court, having reviewed the proposed Class Notice, the proposed FAQ, and

2

the proposed plan for distributing and disseminating each of them, finds and concludes that the

3

proposed plan for distributing and disseminating each of them will provide the best notice

4

practicable under the circumstances and satisfies all requirements of federal and Washington laws

5

and due process. According, the Court hereby ORDERS as follows:

6
7

1.

The form and content of the proposed Class Notice and FAQ are hereby

approved with the following modifications:
a.

8

In Paragraphs 10 and 12 of the proposed Class Notice, and

9

Paragraph 17 of the FAQ, the Parties have included language suggesting that the

10

Final Approval Hearing might occur on a date different from the one set forth in

11

the Class Notice and that the Final Approval Hearing could be rescheduled without

12

notice to the Settlement Class Members. These passages should be deleted

13

because they do not reflect the Court’s views. If the Final Approval Hearing must

14

be continued for any reason, the Court will require that notice be sent to all

15

Settlement Class Members.
b.

16

In the last sentence of Paragraph 13 of the proposed Class Notice,

17

the Parties suggest that Settlement Class Members will receive settlement benefits

18

if the Court approves the Settlement, but they have not mentioned the possibility

19

of an appeal or appellate decision affecting the Settlement, and the statement is

20

therefore inaccurate and potentially misleading, and it must be revised.

21

2.

Promptly following the entry of this Order, the Parties and Settlement

22

Administrator shall prepare final versions of (i) the Class Notice, and (ii) FAQ,

23

incorporating into each of them the Court’s amendments, the Final Approval Hearing date,

24

and the dates and deadlines set forth in Paragraphs III(D) and IV of this Order.

25
26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 8
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

3.

By March 14, 2019, Defendants will file with the Court the Settlement

2

Administrator’s declaration of compliance with this plan of notice, including a statement

3

regarding the number of persons to whom the Class Notice was mailed and/or emailed.

4

4.

By May 23, 2019, the Parties shall file any motion for final approval of

5

class action settlement, and shall note such motion for June 7, 2019. The Parties shall file

6

with such motion the Settlement Administrator’s declaration summarizing and attaching

7

the list of all Settlement Class Members who submitted Requests for Exclusion and any

8

objections received by the Settlement Administrator from Settlement Class Members.

9

Any response to such motion shall be filed by June 3, 2019. Any reply shall be filed by

10
11

8:00 a.m. on June 7, 2019.
5.

The Settlement Administrator shall perform the following functions in

12

accordance with the Settlement Agreement, this Order, and subsequent orders that might

13

be entered by this Court in this case:

14

a.

Establish, on or before February 21, 2019, a Settlement Website

15

that enables Settlement Class Members to: (a) Read the Class Notice, FAQ, Class

16

Counsel’s Fee Application, Settlement Agreement, relevant pleadings related to

17

the Settlement, and relevant orders of the Court; and (b) complete, review, and

18

submit a Request for Exclusion online.

19

b.

Send or cause to be sent, by first-class United States Mail, on or

20

before February 28, 2019, the Class Notice to every Settlement Class Member.

21

CenturyLink will obtain or cause to be obtained address updates utilizing a

22

National Change of Address database (“Updated Addresses”). The Settlement

23

Administrator will use any Updated Addresses thus obtained. The Settlement

24

Administrator will forward Settlement Notices that are returned by the U.S. Postal

25

Service with a forwarding address.

26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 9
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

c.

1

Send or cause to be sent, via electronic mail, on or before

2

February 28, 2019, a copy of the Class Notice to every Settlement Class Member

3

whose email address Defendants can reasonably identify.

4

d.

Process requests for exclusion from the Settlement.

5

e.

Process objections to the Settlement.

6

f.

At least three (3) days before the deadline set forth in Paragraph

7

III(D)(3), provide to Defendants’ Counsel a declaration of compliance with

8

paragraphs III(D)(5)(a)-(c).
g.

9

By May 10, 2019, provide to all counsel a list of all Settlement

10

Class Members who submitted Requests for Exclusion, any objections received by

11

the Settlement Administrator from Settlement Class Members, a list of Settlement

12

Class Members to whom notice was not delivered, and a declaration summarizing

13

the exclusions, objections, and notification failures.

14
15

IV. PROCEDURES FOR FINAL APPROVAL OF THE SETTLEMENT
A.

Final Approval Hearing

16

The Court hereby schedules for June 7, 2019, at 11:00 a.m., a Final Approval Hearing at

17

the United States Courthouse, 700 Stewart Street, Courtroom 15206, Seattle Washington, 98101,

18

to determine whether the Settlement should receive final approval. At that time, the Court will

19

also consider any motion that might be made by Class Counsel for an award of attorneys’ fees

20

and reimbursement of litigation expenses, and any request for a service award to Plaintiff, all in

21

accordance with the terms of the Settlement Agreement.

22
23
24
25
26

B.

Deadline for Members of the Settlement Class to Request Exclusion from
the Settlement

Members of the Settlement Class who wish to be excluded from the Settlement must mail,
email, or submit online their requests for exclusion no later than April 30, 2019. Any exclusion
that is sent via first-class United States Mail must be postmarked by April 30, 2019.

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 10
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

C.

Procedure for Objecting to Matters to Be Heard at the Final Approval
Hearing

2

Any objections to certification of the Settlement Class, the designation of Plaintiff as class

3

representative, the service award requested by Plaintiff, the appointment of Class Counsel, the

4

Settlement, the Settlement Agreement, or the amount of fees and expenses that Class Counsel

5

might request at the Final Approval Hearing, may be made in writing and submitted to the

6

Settlement Administrator by April 30, 2019.

7

Any member of the Settlement Class or his or her counsel may appear at the Final

8

Approval Hearing and present an Objection to the certification of the Settlement Class, the

9

designation of the Class Representative, the appointment of Class Counsel, the Settlement, the

10

Settlement Agreement, or the amount of attorney’s fees, expenses, and/or service awards

11

requested, and/or present any other remarks, without submitting written objections or providing

12

advance notice of an intent to appear or request to be heard at the Final Approval Hearing. The

13

Court will consider all written and oral Objections submitted by any Settlement Class Members.

14

D.

Deadline for Filing Proposed Final Approval Order

15

In conjunction with any motion for final approval of class action settlement, see Paragraph

16

III(D)(4), the parties shall file a proposed Final Approval Order, and shall attach a Word

17

compatible file containing such proposed Final Approval Order to an email sent to

18

[e-mail].

19
20
21
22
23
24
25
26

V. CLASS COUNSEL’S APPLICATION FOR AN AWARD
OF ATTORNEYS’ FEES AND COSTS

On or before March 14, 2019, Class Counsel shall file any motion for attorneys’ fees and
reimbursement of litigation expenses, and shall note such motion for June 7, 2019. Any response
shall be filed by June 3, 2019, and any reply shall be filed by 8:00 a.m. on June 7, 2019.
VI. ABSENCE OF ANY ADMISSION; DENIAL OF ANY WRONGFUL ACT OR
OMISSION AND OF ANY LIABILITY

The Parties entered into the Settlement Agreement solely for the purpose of compromising
and settling disputed claims. Defendants have at all times denied, and continue to deny, any
ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 11
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]

1

wrongful act or omission alleged by Plaintiff in the State and Federal Actions, and any liability of

2

any sort to Plaintiff or any member of the Settlement Class. Nothing contained in the Settlement

3

Agreement, in the documents relating to the Settlement Agreement, or in this Order shall be

4

construed, deemed, or offered as an admission by the Parties, or by any member of the Settlement

5

Class, for any purpose in any judicial or administrative action or proceeding, whether in law or in

6

equity.

7

IT IS SO ORDERED.

8

Dated this 29th day of January, 2019.

A

9
10

Thomas S. Zilly
United States District Judge

11
12
13

Presented by:
14
15

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

19

/s/ Richard E. Spoonemore
Richard E. Spoonemore (WSBA #21833)
701 Fifth Avenue, Suite 2560
Seattle, WA 98104
Tel. [phone]; Fax [phone]
Email: [e-mail]

20

MYERS & COMPANY, PLLC

21

24

/s/ Michael David Myers
Michael David Myers (WSBA #22486)
1530 Eastlake Avenue East
Seattle, WA 98102
Tel. [phone]; Fax [phone]
Email: [e-mail]

25

Attorneys for Plaintiff

16
17
18

22
23

26

ORDER GRANTING PRELIMINARY APPROVAL
OF CLASS ACTION SETTLEMENT - 12
[Case No. 2:18-cv-00413-TSZ]

SIRIANNI YOUTZ
SPOONEMORE HAMBURGER

701 FIFTH AVENUE, SUITE 2560
SEATTLE, WASHINGTON 98104
TEL. [phone] FAX [phone]