Todd Benjamin International, Ltd. v. TCA Fund Management Group Corp., 1:20-cv-21808

Plaintiffs invested in TCA Global Credit Master Fund L.P. and related funds, claiming losses due to misconduct involving Grant Thornton entities and others.
The Receiver for the TCA funds, as appointed in a related SEC action, participated in the settlement on behalf of affected investors.
Plaintiffs sought class certification, asserting the numerosity and typicality of claims justified class treatment under Rule 23(b)(3).
The proposed settlement involved Grant Thornton Cayman Islands and Ireland, and was mediated under the supervision of a retired judge in 2024.
The class included all qualifying investors in specific TCA funds who had not opted out; there were no timely opt-outs.
Plaintiffs requested final settlement approval and an award for attorneys’ fees and costs, both contested in the context of class action settlements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Class Certification	Class meets Rule 23 criteria for settlement	Criteria met only for settlement	Certified for settlement class
Settlement Fairness	Fair, reasonable, negotiated at arm’s length	Fair and reasonable	Approved as fair, reasonable
Notice to Class Members	Adequate and compliant with due process	Not contested	Satisfied due process
Attorneys’ Fees & Costs	Requested fees and costs are reasonable	Fee percentage appropriate	Fees and costs awarded as requested

Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (1997) (manageability not a concern for settlement classes)
Bennett v. Behring Corp., 737 F.2d 982 (11th Cir. 1984) (factors for class action settlement approval)
Camden I Condo. Ass’n v. Dunkle, 946 F.2d 768 (11th Cir. 1991) (percentage-of-the-fund method for attorneys’ fees)
In re Checking Acct. Overdraft Litig., 830 F. Supp. 2d 1330 (S.D. Fla. 2011) (attorneys’ fees methodology for common fund cases)