Schwartz v. Latch, Inc.

CourtDistrict Court, D. Delaware
DecidedAugust 11, 2025
Docket1:23-cv-00027
StatusUnknown

This text of Schwartz v. Latch, Inc. (Schwartz v. Latch, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schwartz v. Latch, Inc., (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

SCOTT SCHWARTZ, individually and on § behalf of all others similarly situated, § § Plaintiff, § § Civil Action No. 23-27-WCB v. § § LATCH, INC, et al., § § Defendants. § §

MEMORANDUM OPINION AND ORDER

Plaintiff Scott Schwartz brought this securities class action against defendant Latch, Inc., (“Latch”) and several of Latch’s officers and directors. Latch went public via a merger with a special purpose acquisition company in June 2021. Dkt. No. 1 at ¶ 1. On January 11, 2023, Mr. Schwartz filed his complaint in this district, alleging that Latch’s pre-merger registration statement contained false and misleading statements that are actionable under sections 11 and 15 of the Securities Act, 15 U.S.C. §§ 77k, 77o. Id. at ¶¶ 9, 12. On April 24, 2023, I approved Mr. Schwartz’s motion to be appointed lead plaintiff and have his counsel approved as lead counsel. Dkt. No. 13. On June 11, 2025, the parties filed a stipulation and agreement of settlement, which set forth the terms of the settlement agreement to which they had agreed. Dkt. No. 43. Mr. Schwartz also moved for preliminary approval of that settlement. Dkt. No. 44. On August 8, 2025, I held a hearing regarding the preliminary approval of the settlement. I. Proposed Settlement Terms The stipulation and agreement of settlement defines the class as: “all stockholders of Legacy Latch who purchased or otherwise acquired Latch common stock pursuant to Latch’s registration statement filed in connection with its June 4, 2021 merger and were allegedly damaged thereby, excluding (i) Defendants; (ii) the officers and directors of Latch; (iii) members of the officers’ and directors’ immediate families and their legal representatives, heirs, successors, or assigns; (iv) any entity in which Defendants have or had a controlling interest; and (v) Settlement

Class Members who validly and timely request exclusion in accordance with the requirements set by the Court in the Preliminary Approval Order and the notice given pursuant thereto.” Dkt. No. 43 at 13. Under the proposed terms, the defendants will pay in cash $1,950,000 into a settlement fund. The settlement fund will be distributed on a pro rata basis based on the relative size of each class member’s claim. Dkt. No. 43, Exh. 2 at ¶ 63. The expected recovery is between $9 and $10 per share of stock minus the sales price if the stock was sold. Dkt. No. 43, Exh. 4. The settlement determines $10 to be the de minimis amount for distribution, so if any class member’s distribution amount is less than $10, those funds will not be distributed but instead will be reallocated on a pro- rata basis to the class members who are receiving a distribution amount of more than $10. Dkt.

No. 43, Exh. 2 at ¶ 63. If there is a remaining balance that cannot be cost-effectively distributed, those funds will be donated to a not-for-profit organization that will be approved by the court. Id. at ¶ 64. Lead counsel expects to seek 33 and 1/3% of the funds as their attorneys’ fees and will seek to have expenses reimbursed in an amount not to exceed $40,000. Id. at ¶ 5. Mr. Schwartz expects to seek a lead plaintiff award of no more than $10,000. Id. II. Discussion “The exact process a district court should follow when presented with a ‘settlement class’ is not prescribed by Rule 23(e),” but the Third Circuit has approved of a two-hearing process. In re Nat. Football League Players Concussion Inj. Litig., 775 F.3d 570, 581–84 (3d Cir. 2014). In the first hearing, or “preliminary fairness review,” “[t]he judge should make a preliminary determination that the proposed class satisfies the criteria set out in Rule 23(a) and at least one of the subsections of Rule 23(b). . . . The judge must make a preliminary determination on the

fairness, reasonableness, and adequacy of the settlement terms and must direct the preparation of notice of the certification, proposed settlement, and date of the final fairness hearing.” Id. (citation omitted). After the class members have been notified of the proposed settlement, the court will hold the final fairness hearing, at which class members may object. See Fed. R. Civ. P. 23(e)(1)(B). The court can then approve the settlement if the court concludes the settlement is “fair, reasonable, and adequate.” Id. a. Rule 23(a) Rule 23(a) sets forth four requirements that a class must meet to be certified. The first requirement is that the class is “so numerous that joinder of all members is impracticable.” Fed. R. Civ. P. 23(a)(1). Counsel for Mr. Schwartz has represented that there are millions of stock

shares at issue in this case, which are held by hundreds of individuals. Although counsel did not have a specific number of shareholders who would qualify as class members, counsel represented that the number would be well in excess of 40 individuals. “No minimum number of plaintiffs is required to maintain a suit as a class action, but generally if the named plaintiff demonstrates that the potential number of plaintiffs exceeds 40, the first prong of Rule 23(a) has been met.” Stewart v. Abraham, 275 F.3d 220, 226–27 (3d Cir. 2001). The second requirement of Rule 23(a) is that “there are questions of law or fact common to the class.” Here, there are multiple commons questions of law and fact. One example is the question whether Latch’s pre-merger registration statement contained false and misleading statements, as Mr. Schwartz has alleged. “The commonality requirement will be satisfied if the named plaintiffs share at least one question of fact or law with the grievances of the prospective class.” Stewart, 275 F.3d at 227 (alteration in the original; citation omitted). The third requirement of Rule 23(a) is that “the claims or defenses of the representative

parties are typical of the claims or defenses of the class.” “The typicality inquiry centers on whether the interests of the named plaintiffs align with the interests of the absent members.” Stewart, 275 F.3d at 227. Counsel for Mr. Schwartz has represented that he is an affected shareholder who is not materially positioned differently from other potential claim members. Furthermore, “[p]redominance is a test readily met in certain cases alleging consumer or securities fraud or violations of the antitrust laws.” Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 625 (1997). The fourth requirement of Rule 23(a) is that “the representative parties will fairly and adequately protect the interests of the class.” For that determination, courts typically consider whether counsel is qualified and whether there are any conflicts of interests between the named

parties and the class they seek to represent. In re Prudential Ins. Co. Am. Sales Prac. Litig. Agent Actions, 148 F.3d 283, 312 (3d Cir. 1998). I have previously concluded that the lead counsel selected by Mr. Schwartz is well qualified to represent the class in this action. See Dkt. No. 13 at 2. And counsel for Mr. Schwartz has explained that there are no conflicts between Mr. Schwartz and potential class members, as each purchased or acquired the stock at issue based on the same alleged misrepresentations. Based on the foregoing analysis, I preliminarily determine that the requirements of Rule 23(a) have been met. b.

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