CLARKSON LAW FIRM, P
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 1 of 341234567CLARKSON LAW FIRM, P.C.Ryan J. Clarkson (SBN 257074)rclarkson@clarksonlawfirm.comShireen M. Clarkson (SBN 237882)sclarkson@clarksonlawfirm.comBahar Sodaify (SBN 289730)bsodaify@clarksonlawfirm.com9255 Sunset Blvd., Ste. 804Los Angeles, CA 90069Tel: (213) 788-4050Fax: (213) 788-4070Attorneys for Plaintiff Thomas IglesiasUNITED STATES DISTRICT COURT8FOR THE NORTHERN DISTRICT OF CALIFORNIA910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 9006911121314151617181920THOMAS IGLESIAS, individually and onbehalf of all others similarly situated,Plaintiff,vs.FERRARA CANDY CO., and DOES 1through 10, inclusive,Defendants.)))))))))))))))))))))Case No. 3:17-cv-00849-VC[CLASS ACTION]MOTION FOR PRELIMINARYAPPROVAL OF CLASS ACTIONSETTLEMENTHon. Judge Vince ChabbriaComplaint filed:February 21, 2017Hearing Date:Hearing Time:Hearing Location:June 21, 201810:00 AMCourtroom 42122232425262728MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 2 of 341TABLE OF CONTENTSClarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 900692Page(s)3I.INTRODUCTION .14II.FACTUAL AND PROCEDURAL BACKGROUND.35A.Litigation History. .36B.Discovery .37C.Class Certification, Amendment, and Settlement Negotiation .38D.The Proposed Settlement .491. Monetary Relief. .4102. Injunctive Relief.5113. Administrative Expenses, Attorneys’ Fees and Costs, and Incentive Awards .5124. Notice .613III.PRELIMINARY APPROVAL IS WARRANTED .714A.Relative Value of Plaintiff’s Claims .815B.Risk, Expense, Complexity, and Likely Duration of Continuing Litigation .916C.The Amount Offered in Settlement.1117D.The Extent of Discovery Conducted and the Information Obtained .1218E.Experience and Views of Counsel .1319IV.20THE COURT SHOULD PROVISIONALLY CERTIFY THE SETTLEMENT CLASS .14A.21The Nationwide Settlement Class Should Be Conditionally Certified .141. Nationwide Class Members Are Victims of the Same Misconduct asPlaintiff .14222. A Fifty-State Consumer Protection Class Can Be Certified .15233. The Plaintiff’s Unjust Enrichment Claims Can Be Pursued on a NationwideBasis .182425B.Nationwide Settlement Classes Are Still Permitted After Hyundai .2026V.THE PROPOSED NOTICE IS ADEQUATE .2227VI.DATES FOR THE FINAL APPROVAL PROCESS .2328VII. CONCLUSION .25iMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 3 of 341TABLE OF AUTHORITIES2345678910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069111213141516171819Page(s)CASESAccord Porter v. Hu,116 Haw. 42 (Ct. App. 2007).20Allen v. Bedolla,787 F.3d 1218 (9th Cir. 2015) .12Am. Towers Owners Ass'n, Inc. v. CCI Mech., Inc.,930 P.2d 1182 (Utah 1996) .20Amchem Prods. v. Windsor,521 U.S. 591 (1997) .14, 21Andren v. Alere, Inc.,2017 WL 6509550 (S.D. Cal. Dec. 20, 2017).16, 19Bearden v. Honeywell Int’l, Inc.,2010 WL 3239285 (M.D. Tenn. Aug. 16, 2010) .16Briseno v. ConAgra Foods, Inc.,844 F.3d 1121 (9th Cir. 2017) .9ConAgra Brands, Inc. v. Briseno,138 S. Ct. 313 (2017) .9Cotter v. Lyft, Inc.,193 F. Supp. 3d 1030 (N.D. Cal. 2016) .2, 7, 8Curtis-Bauer v. Morgan Stanley & Co.,2008 U.S. Dist. LEXIS 85028 (N.D. Cal. Oct. 22, 2008) .9202122232425262728Daugherty v. Sony Elecs., Inc.,2006 WL 197090 (Tenn. Ct. App. Jan. 26, 2006) .20Eddings v. DS Services of America, Inc.,2016 WL 3390477 (N.D. Cal. May 20, 2016) .2Eisen v. Carlisle and Jacquelin,417 U.S. 156 (1974) .22Fejzulai v. Sam’s West, Inc.,205 F. Supp. 3d 723 (D.S.C. 2015) .16Fulford v. Logitech, Inc.,2010 U.S. Dist. LEXIS 29042 (N.D. Cal. Mar. 5, 2010) .10iiMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 4 of 3412345678910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069111213141516171819202122232425262728Ham v. Hain Celestial Grp., Inc.,70 F. Supp. 3d 1188 (N.D. Cal. 2014) .20Hanlon v. Chrysler Corp.,150 F.3d 1011 (9th Cir. 1998) .8, 14Hunt v. VEP Healthcare Inc.,2017 WL 3608297 (N.D. Cal., Aug. 22, 2017) .2In re Abbott Labs. Norvir Anti-Tr. Litig.,2007 WL 1689899 (N.D. Cal. June 11, 2007) .18In re Apple Computer Sec. Litig.,1991 U.S. Dist. LEXIS 15608 (N.D. Cal. Sept. 6, 1991) .10In re Anthem, Inc. Data Breach Litig.,162 F. Supp. 3d 953 (N.D. Cal. 2016) .20In re Cast Iron Soil Pipe & Fittings Antitrust Litig.,2015 WL 5166014 (E.D. Tenn. June 24, 2015) .15In re Checking Account Overdraft Litig.,307 F.R.D. 630 (S.D. Fla. 2015) .18In re Google Referrer Header Privacy Litig.,2014 WL 1266091 (N.D. Cal. Mar. 26, 2014) .23In re Hydroxycut Marketing & Sales Practices Litig.,299 F.R.D. 648 (S.D. Cal. 2014) .15In re Horizon Organic Milk Plus DHA Omega-3 Mktg. & Sales Practice Litig.,955 F. Supp. 2d 1311 (S.D. Fla. 2013) .20In re Hyundai & Kia Fuel Econ. Litig.,881 F.3d 679 (9th Cir. 2018) .14, 20, 21In re Mego Fin. Corp. Sec. Litig.,213 F.3d 454 (9th Cir. 2000) .12In re Mercedes–Benz Tele Aid Contract Litig.,257 F.R.D. 46 (D.N.J. 2009) .18In re Netflix Privacy Litig.,2013 WL 1120801 (N.D. Cal. Mar. 18, 2013) .7, 10In re Netflix Privacy Litig.,2012 WL 2598819 (N.D. Cal. July 5, 2012) .23In re Omnivision Techns., Inc.,559 F. Supp. 2d 1036 (N.D. Cal. 2008) .13iiiMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 5 of 3412345678910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069111213141516171819202122232425262728In re Optical Disk Drive Antitrust Litig.,2012 WL 1366718 (N.D. Cal. Apr. 19, 2012) .16In re Pac. Enters. Sec. Litig.,47 F.3d 373 (9th Cir. 1995) .13In re Tableware Antitrust Litig.,484 F. Supp. 2d 1078 (N.D. Cal. 2007) .7In re Tobacco II Cases,207 P.3d 20 (Cal. 2009) .17Kwikset v. Superior Court,51 Cal. 4th 310 (2011) .20Lane v. Facebook, Inc.,696 F.3d 811 (9th Cir. 2012) .12Linney v. Cellular Alaska Partnership,151 F.3d 1234 (9th Cir. 1998) .11Lisk v. Lumber One Wood Preserving, LLC,792 F.3d 1331 (11th Cir. 2015) .15Luskin’s, Inc. v. Consumer Prot. Div.,353 Md. 335 (1999) .17Metcap Sec. LLC v. Pearl Senior Care, Inc.,2009 WL 513756 (Del. Ch. Feb. 27, 2009) .20Miller v. Ghirardelli Chocolate Co.,2015 WL 758094 (N.D. Cal. Feb. 20, 2015) .6Mounce v. CHSPSC, LLC,2017 WL 4392048 (W.D. Ark. Sept. 29, 2017) .15Nat’l Rural Telecomms. Coop. v. DIRECTV, Inc.,221 F.R.D. 523 (C.D. Cal. 2004) . passimOfficers for Justice v. Civil Serv. Comm’n,688 F.2d 615 (9th Cir. 1982) .11One Step Up, Ltd. v. Webster Bus. Credit Corp.,87 A.D.3d 1 (N.Y. App. Div. 2011) .19Patterson v. BP Am. Prod. Co.,240 P.3d 456 (Colo. App. 2010) .17Pennsylvania Emp., Benefit Trust Fund v. Zeneca, Inc.,710 F.Supp.2d 458 (D. Del. 2010) .18ivMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 6 of 3412345678910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 900691112131415161718Peterson v. Cellco P’ship,164 Cal. App. 4th 1583 (2008) .19Phillips Petroleum Co. v. Shutts,472 U.S. 797 (1985) .22Pitts v. Am. Sec. Ins. Co.,144 N.C. App. 1, 14 (2001) .17Powers v. Lycoming Engines,245 F.R.D. 226, 231 (E.D. Pa. 2007) .19Reed v. Dynamic Pet Prods.,2016 WL 3996715 (S.D. Cal. July 21, 2016) .16Rodriguez v. W. Publ’g Corp.,563 F.3d 948 (9th Cir. 2009) .9, 13Rosenburg v. I.B.M.,2007 WL 128232 (N.D. Cal. 2007) .22Schroeder v. Buchholz,622 N.W.2d 202 (N.D. 2001) .20Schumacher v. Tyson Fresh Meats, Inc.,221 F.R.D. 605, 612 (D.S.D. 2004) .18Shady Grove Orthopedic Assocs., P.A. v. Allstate Ins. Co.,559 U.S. 393 (2010) .15Simpao v. Gov’t of Guam,369 Fed. Appx. 837, 838 (9th Cir. 2010) .23192021222324Trustmark Ins. Co. v. Bank One, Arizona, NA,202 Ariz. 535 (Ct. App. 2002) .20Vizcaino v. Microsoft Corp.,290 F.3d 1043 (9th Cir. 2002) .6Wittman v. CB1 Inc.,2016 WL 3093427 (D. Mont. June 1, 2016) .1525262728vMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 7 of 34123OTHER AUTHORITIES7A Wright & Miller, FEDERAL PRACTICE & PROCEDURE § 1786 (3d ed. 2008) .2221 C.F.R. §100.100 .14456Cal. Civ. Code §1770 .167Colo. Rev. Stat. § 6-1-105.168Fed.R.Civ.P.12 .39Fed.R.Civ.P.15 .31011Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069Ark. Bus. & Com. Code § 4-88-107 .161213Fed.R.Civ.P.23 . passimFed.R.Civ.P.30 .3, 13Federal Judicial Center, Manual for Complex Litigation §21.62 (4th ed. 2004) .914Manual for Complex Litig., Third, §30.41 (1995) .715MS Code § 75-24-5 .1616NEWBERG ON CLASS ACTIONS §11.25 (1992).717OR Rev. Stat. § 646.608 .16181920Tenn. Com. Code § 47-18-104.16Tex. Bus & Com. Code § 17.46 .162122232425262728viMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 8 of 341NOTICE OF MOTION AND MOTION2PLEASE TAKE NOTICE that on Thursday, June 21, 2018 at 10:00 am, or as soon3thereafter as the matter may be heard, in Courtroom 4, 17th Floor, before the Honorable Judge4Vince Chhabria, Plaintiff Thomas Iglesias (“Plaintiff”), on behalf of himself, the general public,5and all others similarly situated, by and through his counsel Ryan J. Clarkson, Shireen M.6Clarkson, and Bahar Sodaify of Clarkson Law Firm, P.C., shall and hereby does move the Court,7pursuant to Federal Rules of Civil Procedure 23(e), for an order as follows:8910Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 9006911(1) Preliminarily approving the settlement of this class action as set forth in the class actionsettlement agreement dated May 10, 2018, attached as Exhibit 1 to the Declaration of Ryan J.Clarkson filed herewith;(2) Preliminarily approving, for settlement purposes only, a settlement class defined as12“All persons who between February 21, 2013 and the date of Preliminary Approval, purchased, in13the United States, one or more candy products manufactured by Defendant and packaged for sale14or resale to consumers in an opaque cardboard box (including bag-in-a-box products), including15Jujyfruits , Jujubes , Now and Later , Lemonhead , Applehead , Cherryhead , Grapehead ,16RedHots , Trolli , Chuckles , Black Forest , Jawbuster , Jawbreaker , Brach’s , Boston17Baked Beans , Super Bubble , Rainblo , Atomic Fireball , and all flavors and varieties of18those candies.” Excluded Persons are: (1) the Honorable Vince Chhabria (2) Mediator Martin19Quinn; (3) the Honorable William Cahill; (4) any member of their immediate family; (5) any20government entity, (6) Defendant; (7) any entity in which Defendant has a controlling interest; (8)21any of Defendant’s subsidiaries, parents, affiliates, and officers, directors, employees, legal22representatives, heirs, successors, or assigns; (9) counsel for the Parties; and (10) any persons who23timely opt-out of the Settlement Class;2425262728(3) Preliminarily approving Plaintiff Thomas Iglesias as the Class Representative, andappointing Clarkson Law Firm, P.C. as Class Counsel for the Settlement Class;(4) Directing the dissemination of notice in the form and manner set forth in the settlementagreement; and(5) Setting a date for the final approval hearing.viiMOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 9 of 341A copy of the proposed order granting preliminary approval is filed herewith.2This motion is made on the grounds that preliminary approval of the proposed class action3settlement is proper, given that each requirement of Rule 23(e) has been met.4This Motion is based on Federal Rule of Civil Procedure 23, this Notice of Motion, the5supporting Memorandum of Points and Authorities, the Declaration of Ryan J. Declaration, the6Declaration of Mark Schey, exhibits, the pleadings and papers on file herein, and any other written7and oral arguments that may be presented to the Court.8910Pursuant to Local Rule 7-4(a)(3), the statement of issue to be decided by the Court is asfollows: Whether the Court should preliminarily approve the proposed class action settlementpursuant to Fed. R. Civ. P. 23(e).Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA N FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 10 of 3412MEMORANDUM OF POINTS AND AUTHORITIESI.Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 900693INTRODUCTIONThe parties have reached a nationwide settlement of the putative class action filed by4Plaintiff Thomas Iglesias (“Plaintiff” or “Mr. Iglesias”) against Defendant Ferrara Candy Co.5(“Defendant” or “Ferrara”). Ferrara manufactures confectionary products, including opaque6“theater boxes” of candy sold at retail outlets and movie theaters throughout the United States.17On February 21, 2017, Plaintiff filed a complaint in this Court alleging that the Products’8oversized opaque packaging deceives consumers into believing they are receiving more candy9than they actually receive due to the presence of nonfunctional empty space, or “slack-fill.” In the10second amended complaint (“SAC”), Plaintiff alleges claims for unjust enrichment and violations11of state and federal packaging laws and consumer protection statutes (Dkt. 71). It is appropriate to12certify a nationwide class because Defendant’s challenged packaging is uniform for all purchasers,13and the elements of the legal claims are nearly identical in all states. The minor differences among14state laws are immaterial to certification particularly because the laws of all 50 states are15substantively identical to California.16Due to this litigation, Defendant has agreed to modify its fill level quality control17procedures and target fill levels to at least 75% for theater box Products, and at least 50% for bag-18in-a-box Products.19Defendant will also pay 2.5 million into a common fund. Each class member who makes20a claim may obtain a cash refund of 50 cents per box purchased. A class member may submit21claims for an unlimited number of purchases. Up to 15 claims, for a total of 7.50, will be paid22without Proof of Purchase. Plaintiff may apply for a reasonable incentive award from the common23fund not to exceed 5,000, and his counsel may apply for an award from the common fund to24reimburse their costs, and to pay their attorneys’ fees not to exceed 30% of the fund.252627281The “Products” or “Covered Products” or “Settlement Class Products” means all candy productsmanufactured by Defendant and packaged for sale or resale to consumers in an opaque cardboardbox (including bag-in-a-box products), including Jujyfruits , Jujubes , Now and Later ,Lemonhead , Applehead , Cherryhead , Grapehead , RedHots , Trolli , Chuckles , BlackForest , Jawbuster , Jawbreaker , Brach’s , Boston Baked Beans , Super Bubble ,Rainblo , Atomic Fireball , and all flavors and varieties of those candies (Dkt. 71).1MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 11 of 341Notice is to be provided to the class via several methods, including (1) print publication,2(2) internet impression advertising, (3) targeted search term advertising, (4) a press release, and3(5) a dedicated settlement website. A well-known third-party claims administrator has designed4the notice plan and has attested that notice will reach at least 70% of the class.56Ryan J. Clarkson (“RJC Decl.”) filed herewith. The proposed class notices can be found at7Exhibits D and E. The proposed claim form is attached as Exhibit C.89Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069A copy of the settlement agreement is attached as Exhibit (“Ex.”) 1 to the Declaration ofThe settlement falls within this Court’s standard for preliminary approval because it is fair,reasonable, and adequate, and will survive the same rigorous level of scrutiny as this Court10applied in Cotter v. Lyft, Inc., 193 F. Supp. 3d 1030, 1036 (N.D. Cal. 2016); Hunt v. VEP11Healthcare, Inc., No. 16-cv04790-VC, 2017 WL 3608297 (N.D. Cal., Aug. 22, 2017); and,12Eddings v. DS Services of America, Inc., No. 15-cv-02576-VC, 2016 WL 3390477 (N.D. Cal.13May 20, 2016). There is a presumption of fairness because the settlement was reached after14substantial discovery, law and motion practice, including a robust class certification motion15supported by four retained experts who conducted full expert reports based on a detailed slack-fill16analysis and 3,788-participant consumer survey, and after arms-length negotiations. See Nat’l17Rural Telecomm. Coop. v. DIRECTV, Inc., 221 F.R.D. 523, 528 (C.D. Cal. 2004).18Numerous other factors also strongly favor the settlement, including the risks of further19litigation and the informed opinion of experienced counsel on all sides who have negotiated and20approved it based upon their views of the strengths and weaknesses of the claims and defenses.21See id. (finding that experienced counsel’s views regarding settlement are entitled to great22weight). The proposed Settlement is a product of extended arms-length negotiations between23experienced attorneys familiar with the legal and factual issues of this case, including two24mediations with experienced neutrals. As a result of these efforts, the parties are fully informed of25the merits of this action and the fairness, adequacy, and reasonableness of the proposed settlement.26As detailed in Plaintiff’s motion for class certification filed on March 5, 2018 (Dkt. 53-54),27the proposed settlement class satisfies Rule 23(a), (b)(2) and (b)(3). Accordingly, Plaintiff’s28motion for preliminary approval should be granted.2MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 12 of 341FACTUAL AND PROCEDURAL BACKGROUND2A.3Plaintiff filed his class action complaint on February 21, 2017, in the U.S. District Court forLitigation History4the Northern District of California, alleging violations of state and federal packaging laws and5consumer protections laws (Dkt. 1). On April 19, 2017, Defendant filed a Rule 12(b)(6) motion to6dismiss Plaintiff’s complaint (Dkt. 14). On May 10, 2017, Plaintiff filed his FAC pursuant to Rule715(a) to add additional remedies available under the statutes in lieu of an opposition (Dkt. 18).89Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069II.On May 24, 2017, Defendant filed a Rule 12(b)(6) motion to dismiss the FAC, claimingthe Products are not misleading and do not contain nonfunctional slack-fill (Dkt. 28), which10Plaintiff opposed on June 7, 2017 (Dkt. 34), to which Defendant replied on June 14, 2017 (Dkt.1137), and the Court denied on July 25, 2017 (Dkt. 40).12On August 8, 2017, Defendant answered Plaintiff’s FAC (Dkt. 41). After the completion13of substantial discovery described infra, Plaintiff moved for class certification on (Dkt. 53-54) on14March 5, 2018. The parties settled the case before Defendant filed its opposition (Dkt. 58).15B.16On June 27, 2017, Plaintiff served Defendant with requests for admissions, requests for17production of documents, and special interrogatories. RJC Decl. ¶ 5. In connection with these18requests, and Plaintiff’s motion to compel further responses, which the Court granted on19November 15, 2017, Defendant produced over 6,000 documents totaling tens of thousands of20pages of complex information and spreadsheet data. Id. On November 13, 2017, Plaintiff’s21deposition took place in San Francisco, CA. Id. ¶ 6. On December 19-20, 2018, Plaintiff deposed22Defendant’s Rule 30(b)(6) corporate designees in Chicago, Illinois. Id. Plaintiff also subpoenaed23third parties for sales and marketing data to support his claims. Id.Discovery24C.25On October 10, 2017, the Parties attended a mediation in San Francisco, CA with mediatorClass Certification, Amendment, and Settlement Negotiations26Martin Quinn. Id. ¶ 7. The parties were unable to reach an agreement. Id. On February 2, 2018,27the parties held a second mediation with the Honorable William Cahill (Ret.) in San Francisco,28CA. Id. ¶ 8. Although the case did not settle, Judge Cahill remained involved in ongoing3MOTION FOR PRELIMINARY APPROVAL OF CLASS ACTION SETTLEMENT
Clarkson Law Firm, P.C.9255 Sunset Blvd., Suite 804Los Angeles, CA 90069Case 3:17-cv-00849-VC Document 72 Filed 05/10/18 Page 13 of 341mediation discussions in the weeks and months that followed. Id. After Plaintiff filed his motion2for class certification and supporting documents on March 5, 2018, which included supporting3materials from four retained experts who conducted full expert reports based on a detailed slack-4fill analysis and 3,788-participant consumer survey, the case settled. Id. ¶ 9. As part of the5settlement, Defendant stipulated to the filing of Plaintiff’s SAC which added a cause of action for6unjust enrichment and clarified the class definition (Dkt. 71). Id. ¶ 10.7D.8The settlement class consists of all persons who between February 21, 2013 and the date of9Preliminary Approval, purchased, in the United States, one or more candy products manufactured10by Defendant and packaged for sale or resale to consumers in an opaque cardboard box (including11bag-in-a-box products), including Jujyfruits , Jujubes , Now and Later , Lemonhead ,12Applehead , Cherryhead , Grapehead , RedHots , Trolli ,
Clarkson Law Firm, P.C. 9255 Sunset Blvd., Suite 804 Los Angeles, CA 90069 CLARKSON LAW FIRM, P.C. Ryan J. Clarkson (SBN 257074) rclarkson@clarksonlawfirm.com Shireen M. Clarkson (SBN 237882) sclarkson@clarksonlawfirm.com Bahar Sodaify (SBN 289730) bsodaify@clarksonlawfirm.com 9255 Suns
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