Illinois Biometric Claims

If you have done any of the following while in Illinois, we may be able to represent you in a claim against these companies for violating the Illinois Biometric Information Privacy Act (BIPA). If you are interested in us representing you against these companies, please click on all of the following that apply to you.
Thank you for choosing our firm. Please find below a Lawyer-Client Agreement (“Agreement”) setting out the terms under which Siri & Glimstad LLP and Peiffer Wolf Carr Kane & Conway, LLP (the “Attorneys”) will represent you (“You”):

1. Scope of Representation. You hereby engage Attorneys to bring claims against Snapchat and/or claims against its related entities (“Defendants”) regarding the potential illegal capture of face, eye, and/or voice biometrics (the “Litigation”). This representation will not be for any other matter, unless we agreed to that representation in writing, nor will it require Attorneys to file any appeal.

2. Attorneys’ Fees. Your representation will be handled strictly on a contingent fee basis. We will seek payment of our fees and costs from the Defendants (Snapchat) or out of any amount recovered. If there is no recovery, you will not owe Attorneys anything.

The most likely scenario is that Defendants would pay Your damages (often in the range of $500 to $1,000) and the Defendants would pay our Attorneys fees and costs. If Defendants do not pay our fees and costs, then we would be entitled to receive forty percent (40%) (or a lesser percentage if required by law) plus costs from any funds obtained from Defendants.

3. Duties of Attorneys. Attorneys shall take all steps in connection with the Litigation which, in the opinion of Attorneys, are required to protect or advance Your interests. Attorneys shall take reasonable steps to keep you informed of the progress of the Litigation.

4. Cooperation. You agree to cooperate with Attorneys regarding the Litigation and respond to reasonable requests from Attorneys related to the Litigation. Your failure to cooperate may require Attorneys to withdraw from the Litigation.

5. Miscellaneous:

(a) Additional Attorneys. Attorneys may associate or affiliate additional attorneys to assist in the Litigation, which additional attorneys shall be included in the reference to “Attorneys” in this Agreement.

(b) Termination. Attorneys may withdraw from this Agreement and/or the Litigation to the extent permitted by law. If you choose to discharge the Attorneys, the Attorneys will be entitled to fees as provided in Section 2 above on a quantum meruit basis and you will be responsible for all costs.

(c) Attorneys' Lien. Attorneys shall have a lien on any amount recovered in the Litigation for their attorneys’ fees and costs.

(d) Joint Representation. Attorneys may represent more than one client who is seeking recovery from Defendants, and you agree to such multiple representations. When attorneys represent multiple clients in the same litigation matter, potential or actual conflicts of interest may arise. For example, one client may want to settle the case and another client may not agree to settle. Nevertheless, we are not currently aware of or presently foresee any such specific conflict.

(e) No Guarantee. Attorneys cannot and do not make any guarantee of success regarding the Litigation. No statement made prior to the execution of this document shall be deemed or construed as a promise or guarantee of success.

(f) Arbitration & Governing Law. Any dispute arising under or relating to the terms of this Agreement or Attorneys’ representation hereunder shall be submitted to binding arbitration in New York. This agreement shall be governed by New York law, without regard to the conflict of law provisions thereof.

(g) Storage and Use of Electronic Data: You are aware of and consent to the retention, maintenance, and storage of client information and records relating to this matter in the following forms and locations: Paper (in office and/or storage files); electronic (e.g., computer, handheld devices for email, fax, and via the Internet using cloud storage); or other like mediums. We will endeavor to take all reasonable steps to preserve and maintain the confidentiality of all your information and records, however, you recognize and agree that such information and records may be subject to unauthorized access outside our control, and agree to hold us harmless from any breaches of confidentiality of your information and records that we do not directly cause.

(h) Client Rights: The Appellate Divisions of the State of New York have enacted a Statement of Client’s Rights and Statement of Client’s Responsibilities which are available at www.nysba.org. If you have any questions about the content of either of these documents, please let us know.

(i) Complete Agreement. This is the complete agreement between you and the Attorneys regarding the matters addressed herein.

(j) Consent. By signing below, you affirm you have read and consent to the terms of this Agreement. Attorneys shall have no obligation to begin the representation until both you and Attorneys have signed this Agreement.

Brandon M. Wise
By:Brandon M. Wise (Jun 15, 2021 10:56 CDT)
Brandon Wise 1778 Caprice Court
O’Fallon, IL 62269
(314) 669-3600

Laura M. Carroll, Attorney
Siri | Glimstad
111 West Jackson Boulevard
Suite 1700 - 218
Chicago, IL 60604
Phone: 312-757-7510
www.sirillp.com

JOINT LITIGATION MANAGEMENT CO-COUNSEL AGREEMENT

Pursuant to this JOINT LITIGATION MANAGEMENT CO-COUNSEL AGREEMENT (“Agreement”), the law firms of Siri & Glimstad LLP (“S&G”), and Peiffer Wolf Carr Kane & Conway, LLP (“PWCKC” and collectively, the “Firms”) agree to associate to jointly manage and pursue all claims by any Illinois resident for violations of the Illinois’ Biometric Information Privacy Act against SnapChat and related entities (the “Action”). In return for valid consideration, the Firms agree as follows:

1. Coordination of Litigation Efforts. Following the execution of this Agreement the Firms will maintain a leadership role with regard to litigation for the Action and major decisions regarding case management and strategy will be made by consensus of the Firms. The Firms agree to work cooperatively and to keep each other apprised of all developments in the Litigation, including communications with opposing counsel regarding the Litigation, and to reach consensus prior to making any material decision in the Litigation, including providing an opportunity to review, edit and comment upon any papers prior to their filing or service in the Litigation.

2. Costs and Expenses. Each Firm shall absorb its internal “in-house” costs including but not limited to the following: telephone and facsimile costs, in- house copying, salaries for their respective attorneys and staff, and travel and lodging. The Firms shall each pay 50% of all other out-of-pocket litigation expenses the Firms agree to expend, such as depositions and court costs, using third-party services or specialists (such as court reporters, expert consultants and witnesses, and graphics services), and other expenses associated with the producing and running of the case, including advertising. Eligible Expenses means any out-of-pocket costs incurred by any Firm in support of the Action since inception. Eligible Expenses shall be payable out of any recovery in the Action. Any attorneys’ fees recovered, whether designated as, attributed to, or described as, attorneys’ fees, costs, out-of-pocket expenses, or something else, shall be used first to repay to the Firms the amounts of any Eligible Expenses they have advanced in pursuing the Action.

Fee and Expense Records. Each Firm agrees to keep detailed, contemporaneous records of all billable time expended, including attorney, paralegal, and law and document clerk work, and all necessary costs, disbursements and expenses incurred in this case.

3. Recovery of Fees and Expenses. In the event that fees are obtained in either the Action or otherwise related to the Action, prior to any division of the fee amount among the Firms, the Firms shall first be reimbursed out of the fee amount for any Eligible Expenses for which they have not otherwise been reimbursed. Thereafter, the net amount and/or any other total fee award (after the subtraction of Eligible Expenses) shall thereafter be divided among the Firms as follows: 50% of the net fee amount shall be reserved to S&G; and 50% of the net fee amount shall be reserved to PWCKC. The Firms shall presume that the division above represents an equitable, just, and accurate reflection of the Firms’ contributions to the resolution of the Action and reflects the Firms’ respective contributions to obtaining the lump sum fee amount.

4. Additional Parties; Modification. Additional parties may participate in this Agreement only with the unanimous approval of the Firms at the time the additional party is proposed to be added. Changes in the division of fees or payment of Common Expenses may be made only with the unanimous approval of the Firms. Any modification or supplementation of this Agreement must be in writing and signed by each Firm. The Agreement may be signed in counterparts and shall not be effective as to a client until agreed to in writing by the client in the Litigation. This agreement shall be governed by New York law, without regard to the conflict of law provisions thereof.

IT IS SO AGREED:

SIRI & GLIMSTAD LLP

Dated: June 15, 2021

By: Aaron Siri
Aaron Siri
200 Park Avenue, 17th Floor New York, NY 10166
(212) 532-1091

PEIFFER WOLF CARR KANE & CONWAY, LLP

Dated: June 20, 2021

Brandon M. Wise
By:Brandon M. Wise (Jun 15, 2021 10:56 CDT)
Brandon Wise 1778 Caprice Court
O’Fallon, IL 62269
(314) 669-3600
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