Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 1 of 11
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`Joseph W. Cotchett (State Bar No. 36324)
`Adam J. Zapala (State Bar No. 245748)
`Elizabeth T. Castillo (280502)
`COTCHETT PITRE & McCARTHY LLP
`840 Malcolm Road, Suite 200
`Burlingame, CA 94010
`Telephone: (650) 697-6000
`Facsimile: (650) 697-0577
`jcotchett@cpmlegal.com
`azapala@cpmlegal.com
`ecastillo@cpmlegal.com
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`Lead Class Counsel for Indirect Purchaser Plaintiffs
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`UNITED STATES DISTRICT COURT
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`FOR THE NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`IN RE CAPACITORS ANTITRUST
`LITIGATION
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`THIS DOCUMENT RELATES TO:
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`ALL INDIRECT PURCHASER
`PLAINTIFF ACTIONS
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`Case No. 3:14-cv-03264-JD
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`MDL No. 3:17-md-02801-JD
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`INDIRECT PURCHASER PLAINTIFFS’
`SUPPLEMENTAL REPORT AND
`MATERIALS TO THE SPECIAL MASTER
`(MONICA IP) IN SUPPORT OF THEIR
`MOTION FOR REIMBURSEMENT OF
`EXPENSES
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in Support
`of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 2 of 11
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`TABLE OF CONTENTS
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`Page
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`SUMMARY OF REASONABLY INCURRED OVERALL COSTS ................................. 1
`A. Summary of Reasonably Incurred Litigation Fund Expenses ..................................... 1
`B.
`Summary of Reasonably Incurred Individual Firm Expenses ..................................... 6
`IPPS’ OVERAL COSTS HAVE BEEN REASONABLY INCURRED .............................. 6
`CONCLUSION ..................................................................................................................... 7
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`I.
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`II.
`III.
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 3 of 11
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`In re Fleet/Norstar Sec. Litig.,
`935 F. Supp. 99 (D.R.I. 1996)........................................................................................................ 7
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`Nat’l Rural Telecomms. Coop. v. DIRECTV, Inc.,
`221 F.R.D. 523 (C.D. Cal. 2004) ................................................................................................... 6
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`Weseley v. Spear, Leeds & Kellogg,
`711 F. Supp. 713 (E.D.N.Y. 1989) ................................................................................................ 7
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 4 of 11
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`Pursuant to this Court’s directions regarding the appointment of Special Master Monica Ip at
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`the July 25, 2019 Status Conference, and pursuant to this Court’s Order appointing the Special Master
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`(ECF No. 2439), the Indirect Purchaser Plaintiffs’ (“IPPs”) respectfully submit this Memorandum,
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`along with the supporting materials attached as Exhibits to the Declaration of Adam J. Zapala (“Zapala
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`Declaration” or “Zapala Decl.”), for purposes of IPPs’ request for reimbursement of litigation
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`expenses in the amount of $4,710,298.22. These pleadings, and the supporting materials, have also
`been served on the Special Master.
`SUMMARY OF REASONABLY INCURRED OVERALL COSTS
`I.
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`Summarized below and in the Zapala Declaration with its accompanying exhibits, IPPs have
`attempted to explain their reasonably incurred overall costs in this litigation. There are two ways in
`which costs are incurred in this litigation under the direction of IPP Lead Counsel. First, for common
`costs such as expert fees, document review hosting, deposition vendors, and similar common
`expenses, IPP Lead Counsel established a common Litigation Fund out of which these common costs
`are paid. The total costs incurred through the Litigation Fund for the entire case, and for discrete
`temporal portions of the case, are outlined below (“Litigation Fund Expenses”). Second, there are
`also individual firm expenses that IPP Lead Counsel reported as part of the motion for approval of
`attorneys’ fees and reimbursement of litigation expenses. These individual firm expenses are incurred
`outside of Litigation Fund expenses and commonly include travel expenses for depositions, costs
`incurred in connection with vendor services related to the Class Representatives’ production of
`documents, copying costs, legal research costs and the like (“Individual Firm Expenses”).
`Summary of Reasonably Incurred Litigation Fund Expenses
`A.
`After the Court appointed Cotchett, Pitre & McCarthy, LLP (“CPM”) Interim Lead Counsel
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`for the IPP Class, CPM created a Litigation Fund to pay the common expenses for prosecuting this
`case. CPM also enlisted the support of others law firms (“Supporting Counsel”) to assist in
`prosecuting the IPP case. CPM and Supporting Counsel have contributed substantial money to the
`Litigation Fund to pay for common expenses. As outlined in the Zapala Declaration, the vast majority
`of litigation expenses in this case have been paid from the Litigation Fund, as opposed to in the form
`of individual firm expenses. Zapala Decl. ¶ 5. Measures have been taken whenever possible to keep
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 5 of 11
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`costs at a minimum. Id. ¶¶ 3, 8(k) (court reporting services), 9(a)-(b) (document hosting), 11 (d)-(g)
`(experts), 12 (hearing transcripts), 14 (translations), 19 (deposition travel).
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`IPPs’ motion seeks reimbursement of $4,710,298.22 in total unreimbursed litigation expenses
`to August 10, 2018. The following table summarizes the amounts sought for reimbursement by IPPs
`through their Motion:
`Description
`Unpaid Litigation Fund Expenses
`(November 1, 2014–September 30, 2016)
`Unpaid Litigation Fund Expenses
`(October 1, 2016–August 10, 2018)
`Unpaid Individual Firm Expenses (Less Assessments)1
`(October 1, 2016–March 31, 2018)
`Total Requested Amount of Reimbursement
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`$3,518,095.70
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`$438,977.80
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`$4,710,298.22
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`Costs Incurred
`$753,224.72
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`1 “Assessments” are simply payments or contributions by individual firms to the common Litigation
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`Fund. As noted in the Declaration of Adam J. Zapala, some individual firms included assessments in
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`their backup materials. Those assessment checks can be ignored in terms of accounting for overall
`costs because they are already accounted for through the Litigation Fund Expenses accounting. See
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`Zapala Decl. ¶ 20.
`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Zapala Decl. ¶ 3.
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`In connection with approval of the first round of settlements, IPPs reported incurred Litigation
`Fund expenses in the amount of $3,311,678.72 for the time period November 1, 2014 through
`September 30, 2016. ECF No. 1649-7. Consistent with their notice to the Class, however, IPPs only
`sought reimbursement of expenses in the amount of $2,558,454.00, leaving a balance of $753,224.72
`in unpaid litigation expenses. See ECF No. 1649. On October 30, 2017, the Court awarded IPPs’
`request for reimbursement of expenses in the amount of $2,558,454.00. See ECF No. 1938. IPPs
`now seek reimbursement of the remaining costs incurred from November 1, 2014 - September 30,
`2016 in the amount of $753,224.72. Zapala Decl. ¶ 3.
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`The table below summarizes the expenses incurred by the Litigation Fund from the inception
`of the case broken out by reporting periods:
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 6 of 11
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`Description
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`Litigation Fund Costs
`Nov. 1, 2014 - Sept.
`30, 2016
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`$117,575.71
`$218,379.79
`$17,634.31
`$2,567,455.21
`$593.10
`$14,350.00
`$368,837.77
`$188.40
`$6,664.43
`$3,311,678.72
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`Litigation Fund Costs
`Oct. 1, 2016 - August
`10, 2018
`$340,984.43
`$715,414.80
`$0.00
`$2,328,045.44
`$645.05
`$30,408.00
`$95,013.04
`$108.29
`$7,476.65
`$3,518,095.70
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`Overall
`Litigation
`Fund Costs
`Incurred
`$458,560.14
`$933,794.59
`$17,634.31
`$4,895,500.65
`$1,238.15
`$44,758.00
`$463,850.81
`$296.69
`$14,141.08
`$6,829,774.42
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`Depositions
`Document Depository
`Document Production
`Experts / Consultants
`Hearing Transcripts
`Mediation
`Translations
`Miscellaneous - Bank Fees
`Service of Process
` TOTAL
`Zapala Decl. ¶ 6.
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`Paragraphs 8 through 16 of the Zapala Declaration, along with the exhibits associated with
`those paragraphs, provide a detailed breakdown and explanation of each of the categories of expenses
`in the table above. These paragraphs further identify each vendor IPPs contracted with and explain
`the services provided by each. Exhibit 1 to the Zapala Declaration provides a summary chart of all
`money paid to all vendors from the Litigation Fund from inception of the case up until August 10,
`2018. Additionally, the Zapala declaration attaches invoices that reflect all of the expenses incurred
`by the Litigation Fund from the inception of the case. See Zapala Decl., Exs. 2-34. A brief overview
`of the work performed and expenses incurred in each of the categories follows. The Zapala
`Declaration contains an even more detailed description of each of these categories:
`• Depositions: The expenses incurred in this category included those costs associated with
`deposition transcripts, court reporting services, videography services, and interpreters. There have
`been more than 130 depositions in this case, nearly all lasting two days with nearly all witnesses
`testifying in Japanese and requiring an interpreter. Zapala Decl. ¶ 8. The Litigation Fund expenses
`for depositions incurred in connection with the Round 2 Settlements (period of Oct. 1, 2016 - August
`10, 2018) was $340,984.43.
`• Document Depository: This category of expenses includes those associated with the
`document review, primarily costs associated with hosting, coding, and processing both defendants’
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 7 of 11
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`and plaintiffs’ document productions, as well as non-party data. An extraordinary amount of data
`and documents have been produced in this litigation: more than eleven million documents
`constituting more than 8.5 terabytes have been produced by defendants and non-parties. Zapala Decl.
`¶ 9. The vast majority of expenses in this category have been paid to CasePoint. CasePoint hosts the
`documents produced by defendants, and provides a software platform in which IPPs and DPPs’
`document reviewers may review documents and code them for relevance and deposition preparation.
`CasePoint also engages in ad hoc technical projects at the direction of Interim Lead Counsel which
`assist in proving Plaintiffs’ affirmative case. Before CasePoint was chosen to host the document
`productions in this litigation, a thorough competitive bidding process was held and CasePoint
`provided the most competitive bid from a price and technology standpoint. To further reduce
`expenses, IPPs have shared the ESI review platform and associated costs with the Direct Purchaser
`Plaintiffs (“DPPs”), which is somewhat unique in this type of litigation. Had IPPs not split the review
`platform costs with DPPs, expenses in this category would have been double what they are. In
`addition to sharing these costs with DPPs, the contract with CasePoint was renegotiated when it
`became apparent how large the document productions in the case had become. Id. As a consequence,
`IPPs and DPPs renegotiated the contract to receive a lower hosting fee. The Litigation Fund expenses
`for document depositories incurred in connection with the Round 2 Settlements (period of Oct. 1,
`2016 - August 10, 2018) was $715,414.80.
`• Document Production: This category of expenses includes those incurred with
`producing IPPs’ documents, cost-sharing arrangements with non-parties (primarily distributors
`whose data IPPs sought in connection with class certification proceedings), and reproduction of
`document productions. Zapala Decl. ¶ 10. Although costs for this category of services were incurred
`during the previous round of settlements (reporting period of Nov. 1, 2014 - Sept. 30, 2016), no such
`costs were incurred in this reporting period and therefore IPPs’ request for reimbursement of litigation
`expenses in connection with the Round 2 Settlements does not include costs for document production.
`IPPs nevertheless provide the foregoing information in the interests of completeness.
`• Experts/Consultants: This category represents the costs that IPPs have incurred from
`experts and consultants during the course of the litigation. This category of costs is by far the largest
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 8 of 11
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`category of IPPs’ costs, accounting for approximately 66.2% of overall Litigation Fund costs for the
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`reporting period, and approximately 71.7% of Litigation Fund costs for the entire case. The experts
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`and consultants include IPPs’ testifying expert and his back-up shop (who make up the substantial
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`portion of this line item), a firm engaged to perform a forensic accounting to evaluate ability-to-pay
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`issues, a capacitors industry expert, and e-discovery consultants. Zapala Decl. ¶ 11. The Litigation
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`Fund expenses for experts incurred in connection with the Round 2 Settlements (period of Oct. 1,
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`2016 - August 10, 2018) was $2,328,045.44, in addition to the $753,224.72 in unreimbursed expenses
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`from the period of Nov. 1, 2014 - Sept. 30, 2016.2
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`• Hearing Transcripts: This category of expenses is for those incurred by IPPs for the
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`transcripts of proceedings before this Court. Zapala Decl. ¶ 12.
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`• Mediation: IPPs engaged the services of mediators to oversee certain settlement
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`negotiations and this category of expense represents charges incurred from the mediators. Zapala
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`Decl. ¶ 13. The Litigation Fund expenses for mediation services incurred in connection with the
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`Round 2 Settlements (period of Oct. 1, 2016 - August 10, 2018) was $30,408.00.
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`• Translations: This category reflects costs incurred for obtaining certified translations of
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`documents produced by defendants. Nearly all the documents produced by defendants in this
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`litigation were produced in the Japanese language. To minimize translation expenses, IPPs shared a
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`document review team with DPPs. These document reviewers—all of whom are fluent in Japanese—
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`identified the most relevant documents for potential translation. Only those documents that were
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`identified as highly relevant by the document reviewers, and then identified by attorneys taking
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`depositions as potential deposition exhibits, were sent out for certified translations. To further
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`minimize translation costs, IPPs shared costs with DPPs. Zapala Decl. ¶ 14. The Litigation Fund
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`expenses for document translation services incurred in connection with the Round 2 Settlements
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`(period of Oct. 1, 2016 - August 10, 2018) was $95,013.04.
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`• Miscellaneous – Bank Fees: IPPs incurred certain charges related to maintaining and
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`using an account related to the Litigation Fund. Zapala Decl. ¶ 15.
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`2 It is important to note that these figures are the total amounts incurred to the experts
`through the Litigation Fund. As outlined infra, Cotchett, Pire & McCarthy, LLP also made a
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`$300,000 payment to the experts outside of the Litigation Fund Expenses.
`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 9 of 11
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`• Service of Process: This category reflects IPPs use of a courier service to serve non-party
`subpoenas and deliver courtesy copies to the Court. Zapala Decl. ¶ 16.
`Summary of Reasonably Incurred Individual Firm Expenses
`B.
`A significant portion of the individual firm expenses for the reporting period for which
`reimbursement is sought is a $300,000 line item for “Experts/Consultants” that Cotchett, Pitre &
`McCarthy, LLP (“CPM”) incurred. As IPP Lead Counsel, CPM paid a total of $300,000 directly to
`its experts when the Litigation Fund was nearly expended. Zapala Decl. ¶¶ 18-20.
`The majority of the balance of the individual firm expenses (only $138,977.82) reflect costs
`for travel associated with depositions, vendor services for production of documents from the
`individual Class Representatives, copying costs, and legal research fees and the like. There has been
`a total of 23 international depositions in the case and 65 domestic depositions outside the San
`Francisco area. Zapala Decl. ¶ 19. Where possible, IPPs staffed depositions with counsel who are
`local in order to minimize travel and associated costs. Nonetheless, depositions in this case typically
`last two days because they are translated, which means that any given deposition will require two to
`three nights in a hotel in the deposition’s location—which is typically a major city such as Chicago,
`Washington, D.C., or New York. Id. A summary of IPPs’ reasonably incurred Individual Firm
`Expenses may be found at Exhibit 35 to the Zapala Declaration. A summary and the related backup
`materials and receipts for each Individual Firm’s Expenses may be found at Exhibits 36 through 57
`of the Zapala Declaration. See also Zapala Decl. ¶¶ 18-20.
`IPPS’ OVERAL COSTS HAVE BEEN REASONABLY INCURRED
`II.
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`IPPs’ respectfully submit that the reimbursement of litigation expenses sought through IPPs’
`Motion have been necessary to the success of the litigation and have been reasonably expended and
`thus should be reimbursed by this Court.
`First, as an initial matter, it bears noting that no class member has objected to IPPs’ request
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`for attorneys’ fees or reimbursement of litigation expenses. Thus, no class member has determined
`that such expenses are excessive in this case given the results achieved. See Nat’l Rural Telecomms.
`Coop. v. DIRECTV, Inc., 221 F.R.D. 523, 529 (C.D. Cal. 2004) (absence of objectors militates in
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 10 of 11
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`favor of approval) (collecting cases); see also In re Fleet/Norstar Sec. Litig., 935 F. Supp. 99, 107
`(D.R.I. 1996).
`Second, considering the complex issues in this case, the number of defendants, the volume of
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`documents and transactional data, IPPs respectfully submit that the expenses incurred by IPPs in this
`complex antitrust action are reasonable. The vast majority of the overall costs have been driven by
`the extensive expert work that has been performed in this litigation. Indeed, as courts have long
`recognized, antitrust class actions cases are notoriously complex, bitterly fought, expensive, and
`heavy on expert work. See Weseley v. Spear, Leeds & Kellogg, 711 F. Supp. 713, 719 (E.D.N.Y.
`1989) (antitrust class actions are “notoriously complex, protracted, and bitterly fought.”) Moreover,
`in IPP Lead Counsel’s experience and judgment, it is not uncommon to have relatively higher
`litigation expenses for the first few rounds of settlements as compared to later rounds. IPPs fully
`expect that future requests for reimbursement of litigation expenses will be lower as a proportion of
`the overall settlement fund because certain one-time costs (e.g., expert costs associated with class
`certification, for example) have already been expended. It bears noting that the reporting period (Oct.
`1, 2016 - August 10, 2018) for which IPPs are seeking their $4,710,298.22 in reimbursement of
`litigation expenses was the heaviest in terms of expert work. For example, IPPs exchanged their
`expert report in support of class certification, exchanged their rebuttal report, prepared their experts
`for deposition, and prepared themselves for depositions of the defendants’ experts. Moreover, this
`reporting period was heaving on discovery work, and in particular, on depositions. For example, the
`vast majority of the depositions of defendants’ witnesses occurred during this reporting period. As a
`consequence, during this period the litigation costs were particularly expensive.
`Finally, IPPs respectfully believe their request for reimbursement of litigation expenses is
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`reasonable by any appropriate comparator or yardstick methodology.
`III. CONCLUSION
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`Based on the foregoing and on the Declaration of Adam J. Zapala and the attached exhibits,
`IPPs respectfully request that the Court through the work of the Special Master award a
`reimbursement of reasonably incurred litigation expenses in the amount of $4,710,298.22.
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`Case 3:14-cv-03264-JD Document 2447 Filed 09/05/19 Page 11 of 11
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`DATED: September 5, 2019
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`Respectfully submitted,
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`/s/ Adam J. Zapala
`Joseph W. Cotchett
`Adam J. Zapala
`Elizabeth T. Castillo
`COTCHETT, PITRE & McCARTHY, LLP
`840 Malcolm Road, Suite 200
`Burlingame, CA 94010
`Telephone: (650) 697-6000
`Facsimile: (650) 697-0577
`
`Interim Lead Class Counsel for Indirect Purchaser
`Plaintiffs
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`Indirect Purchaser Plaintiffs’ Supplemental Report and Materials to the Special Master in
`Support of Motion for Reimbursement of Expenses; Case No. 3:14-cv-03264-JD
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`22
`23
`24
`25
`26
`27
`28
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