McKnight v. Uber Technologies, Inc., 4:14-cv-05615

Plaintiffs brought a nationwide putative class action against Uber asserting breach of implied contract and consumer-protection claims based on representations about a "Safe Rides Fee" and Uber’s safety measures; the class covered app/website riders from Jan 1, 2013 to Jan 31, 2016 (≈22.4 million members).
Parties negotiated a $32.5 million non-reversionary settlement fund, with an average cash share of about $1.07 per class member; default relief for most class members is Uber ride credit, with cash available by claim form or in limited circumstances later.
The court previously granted preliminary approval and conditional class certification, and held a fairness hearing; notice was sent (≈94.3% reach) and few objections/opt-outs were submitted.
Objectors challenged the settlement as coupon-like under CAFA, the adequacy of relief (tiny per-member recovery), and the requested attorneys’ fees; plaintiffs countered that many objectors are serial objectors and defended the fee request.
The court concluded the settlement is sufficiently coupon-like to trigger CAFA scrutiny but found the settlement fair, reasonable, and adequate and granted final approval.
The court granted $500 incentive awards to each named plaintiff and approved $3,200.63 in costs, but denied plaintiffs’ fee request and other cost claims without prejudice, directing a renewed fee submission compliant with CAFA’s coupon-settlement fee principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether notice to the class was adequate	Notice plan (mail, website, ads, phone) reached the class and satisfied Rule 23 requirements	No opposition	Notice was adequate; court previously approved procedures and administrator reached ≈94.3% of class.
Whether the settlement is coupon-like such that CAFA §1712 applies	Settlement offers cash option and passive conversion to cash if credits unused, so not purely coupon	No opposition on applying CAFA; factual emphasis on credits as limited value	Settlement is sufficiently coupon-like to warrant CAFA’s heightened scrutiny.
Final fairness of the settlement under Rule 23 and CAFA	Settlement fairly resolves risks, delays, and complexity despite small per-member payments; injunctive changes and cy pres address residuals	No opposition	Settlement is fair, adequate, and reasonable; final approval granted.
Attorneys’ fees and costs calculation under CAFA	Requested percentage fee (25%) and lodestar multiplier; recoverable costs listed; seek incentive awards	Objectors argued fees disproportionate to class recovery and challenged cost detail and fee method	Court denied fee motion without prejudice and ordered amended fee filing consistent with CAFA rules (coupon redemption valuation + lodestar for non-coupon relief); approved $3,200.63 in costs and $500 incentives each.

Hanlon v. Chrysler Corp., 150 F.3d 1011 (9th Cir. 1998) (standard for assessing fairness of class-action settlements)
Churchill Vill., LLC v. Gen. Elec., 361 F.3d 566 (9th Cir. 2004) (factors for evaluating class settlement fairness)
In re Online DVD-Rental Antitrust Litig., 779 F.3d 934 (9th Cir. 2015) (distinguishing coupon vs. non-coupon settlements and applying CAFA concerns)
In re HP Inkjet Printer Litig., 716 F.3d 1173 (9th Cir. 2013) (CAFA fee rules: redemption-based fees for coupons and lodestar for non-coupon relief)
In re Hyundai & Kia Fuel Econ. Litig., 926 F.3d 539 (9th Cir. 2019) (en banc) (limits on choice-of-law requirements for nationwide settlements)
Rodriguez v. West Publ’g Corp., 563 F.3d 948 (9th Cir. 2009) (standards for incentive awards and class representative adequacy)
Staton v. Boeing Co., 327 F.3d 938 (9th Cir. 2003) (factors for evaluating incentive awards)
Lane v. Facebook, Inc., 696 F.3d 811 (9th Cir. 2012) (cy pres and distributional considerations in class settlements)