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In re Bluetooth Headset Products Liability Litigation

654 F.3d 935 (2011)

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In re Bluetooth Headset Products Liability Litigation

United States Court of Appeals for the Ninth Circuit

654 F.3d 935 (2011)

Facts

William Brennan and other class members (the class) (plaintiffs) filed 26 federal class-action lawsuits against Motorola, Inc., Plantronics, Inc., and GN Netcom, Inc. (the companies) (defendants), raising consumer-fraud and unfair-business-practice claims based on the companies’ alleged failures to disclose possible risks of hearing loss associated with the use of Bluetooth headsets at high volumes. The class sought money damages on behalf of millions of Bluetooth headset purchasers. The class requested injunctive relief, damages for economic losses, punitive damages, and attorneys’ fees and costs. The federal district court generally adopted the parties’ proposed settlement and awarded $100,000 in cy pres awards, $12,000 for named class representatives, $800,000 for the class counsel’s attorneys’ fees, and $50,000 for other fees and costs. The settlement did not award the class damages for economic injury. The district court did not disclose how it calculated the attorneys’ fees or why it believed that $800,000 was a reasonable fee amount. Some class members appealed, challenging the court’s approval of the settlement and fees, arguing that the class’s award was unreasonable in disproportionately advancing the class counsel’s interests over the class’s interests.

Rule of Law

Issue

Holding and Reasoning (Hawkins, J.)

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