Liu v. Home Depot USA Inc

District Court, W.D. Washington·Decided October 2, 2024·No. 2:23-cv-01217·Unknown

Opinion

1 2

3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE

9 10 TRACEY LIU, et al., CASE NO. C23-1217JLR 11 Plaintiffs, ORDER v. 12 HOME DEPOT USA, INC., 13 Defendant. 14

15 I. INTRODUCTION 16 Before the court are (1) Plaintiffs Tracey Liu and Kristie Rudham’s (together, 17 “Plaintiffs”) unopposed motion for final approval of their proposed class action 18 settlement with Defendant Home Depot USA, Inc. (“Defendant”) (Approval Mot. (Dkt. 19 # 35)) and (2) Plaintiffs’ unopposed motion for attorneys’ fees, costs, and incentive 20 awards (Fees Mot. (Dkt. # 32)). The court heard from the parties at a final approval 21 hearing on September 30, 2024, where it determined that the settlement satisfies the 22 requirements set forth in Federal Rule of Civil Procedure 23(e). (See 9/30/24 Min. Entry 1 (Dkt. # 42).) Being fully advised, the court GRANTS the motion for final approval for 2 the reasons set forth on the record during the September 30, 2024 hearing; GRANTS

3 Class Counsel’s requests for costs and incentive awards in their entirety, and GRANTS 4 IN PART Class Counsel’s motion for attorneys’ fees. Below, the court addresses the 5 objections filed by California attorney Michael Geller (Obj. (Dkt. # 34)) and Class 6 Counsel’s request for an award of attorneys’ fees.1 7 II. OBJECTIONS 8 For the reasons stated on the record during the September 30, 2024 hearing, the

9 court finds that the relief offered to the Settlement Class is fair, reasonable, and adequate. 10 As the court noted at the hearing, Mr. Geller raised several objections to the settlement. 11 The court addresses these objections below.2 12 First, Mr. Geller asserts that the settlement is based on “worthless coupons that no 13 one is going to use” and fails to satisfy the requirements of a “coupon settlement” under

14 the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1712. (Obj. at 2-4;3 see Obj. Resp. 15 (Dkt. # 36) at 3-9 (responding to this objection).) CAFA requires courts to apply 16 “heightened scrutiny” when approving “coupon settlements” and to use “specific rules” 17

18 1 The court assumes the reader is familiar with the parties’ settlement agreement (“Agreement”). (See generally Agreement (Dkt. # 26-1).) Capitalized terms in this order are defined in the Agreement. (See id. § I.) 19 2 “An objector to a proposed settlement agreement bears the burden of proving any 20 assertions they raise challenging the reasonableness of a class action settlement.” In re LinkedIn User Privacy Litig., 309 F.R.D. 573, 583 (N.D. Cal. 2015). 21 3 Mr. Geller offers his own calculations of the benefits provided by the settlement. (Obj. at 2.) The court does not address those calculations in this order because they are based on 22 incorrect assumptions about the structure of the settlement. (See id.) 1 to evaluate fee awards in such cases. See McKnight v. Hinojosa, 54 F.4th 1069, 1075 2 (9th Cir. 2022) (citing 28 U.S.C. § 1712). These rules only apply, however, if the

3 settlement is a “coupon settlement.” Id. Because “coupon” is not defined in the statute, 4 see 28 U.S.C. § 1712, courts review three factors to determine whether the relief offered 5 to the class is a “coupon”: “(1) whether class members have ‘to hand over more of their 6 own money before they can take advantage of’ a credit, (2) whether the credit is valid 7 only ‘for select products or services,’ and (3) how much flexibility the credit provides, 8 including whether it expires or is freely transferrable.” McKnight, 54 F.4th at 1075

9 (quoting In re Easysaver Rewards Litig., 906 F.3d 747, 755 (9th Cir. 2018)). 10 The court concludes, based on these factors, that the parties’ settlement is not a 11 “coupon settlement” within the meaning of CAFA. First, Settlement Class Members will 12 not have to “hand over more money” to take advantage of the Credit Benefits because 13 Defendant’s websites offer over 100 products valued at $50 or less, with free shipping on

14 all orders. (See 5/31/24 Franzini Decl. (Dkt. # 33) ¶ 23.) Second, although the Credit 15 Benefits can only be used to purchase products available on Defendant’s websites, they 16 can be used without restrictions, including on already discounted products. (Agreement 17 § III(C)(5).) And third, the Credit Benefits are valid for three years and are freely 18 transferrable. (Id.); see also McKnight, 54 F.4th at 1075-77 (concluding that credits

19 offered as part of a settlement were not “coupons” and thus CAFA did not apply). 20 Because this is not a “coupon settlement,” CAFA’s heightened scrutiny and attorneys’ 21 fees requirements do not apply, and Mr. Geller’s objection is overruled. 22 1 Second, Mr. Geller argues that the settlement should provide cash refunds based 2 on the amount each Settlement Class Member spent on Defendant’s websites during the

3 class period, instead of a flat $50 refund. (Obj. at 3.) Class Counsel respond that a flat 4 refund is appropriate because all of the class members suffered the same harm—they 5 were all misled by Defendant’s misrepresentations of the cost of the products on the 6 websites. (Obj. Resp. at 2 n.1.) The court concludes that Mr. Geller’s objection simply 7 states his preference for an alternative remedy. This is not, in the court’s view, a valid 8 ground for denying final approval of the settlement. See Linney v. Cellular Alaska

9 P’ship, 151 F.3d 1234, 1242 (9th Cir. 1998) (“[T]he very essence of a settlement is 10 compromise, a yielding of absolutes and an abandoning of highest hopes.” (internal 11 quotation marks and citation omitted)). Therefore, the court overrules Mr. Geller’s 12 second objection. 13 Third, Mr. Geller objects that Settlement Class Members should not be required to

14 complete a claim form to receive a Cash Benefit because Defendant knows how much 15 each Settlement Class Member spent on its websites. (Obj. at 3.) According to Mr. 16 Geller, the settlement should instead provide automatic cash payments. (Id.) Class 17 Counsel responds that it is “typical and well-accepted” for settlements to offer class 18 members credits as a default remedy with the option to receive cash by filing a claim.

19 (Obj. Resp. at 1-2 (compiling cases).) They point out that in deceptive price advertising 20 cases like this one, there is nothing wrong with the products themselves; instead, the sole 21 problem is that the defendant represented that its products were worth more than they 22 truly were. (Id.) As a result, according to Class Counsel, there is no reason to assume 1 that Settlement Class Members would be dissatisfied with the Credit Benefits. (Id.) The 2 court agrees that the structure of the parties’ proposed settlement is consistent with many

3 other consumer class action settlements and finds nothing about the settlement that would 4 require the parties to depart from that model. Therefore, the court overrules Mr. Geller’s 5 third objection. 6 Finally, Mr. Geller objects to Class Counsel’s attorneys’ fee request, asserting that 7 fees measured against a percentage of recovery should be based on the $4.95 million 8 Cash Settlement Fund rather than Class Counsel’s inflated $19 million settlement

9 valuation. (Obj. at 4.) He points out that $3.5 million is 71% of the Cash Settlement 10 Fund, and asserts that amount is far too high. (Id.) The court agrees with Mr.

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