Tyler Barnett PR, LLC v. Facebook Inc., 4:16-cv-06232

Facebook monetizes mainly through advertising; plaintiffs allege miscalculation of the Average Duration of Video Viewed metric used in ad analytics.
The class consists of Facebook advertisers who paid for video ads from May 4, 2014 to Sept. 23, 2016.
In Aug. 2016 Facebook disclosed the metric was improperly calculated due to a narrower denominator.
Two related actions (Letizia and Quirky) were consolidated; plaintiffs moved for interim class counsel after consolidation.
Court heard the motion, reviewed arguments, and denied the motion to appoint interim class counsel without prejudice for potential future reconsideration.
Plaintiffs argued appointment would prevent delays and leadership disputes; Facebook argued there is no rivalry or need in a single consolidated action.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to appoint interim class counsel under Rule 23(g)(3).	Letizia argues benefits of leadership clarity and efficiency.	Facebook argues no need due to consolidation and cooperation.	Denied without prejudice.
Whether rivalry or future tag-along suits justify appointment.	Plaintiffs contend potential rival firms could disrupt leadership.	No current rivals or likely future suits.	Not warranted; no imminent rivalry.
Whether Nest Labs precedent supports interim appointment.	Nest Labs suggests appointing to maintain status quo.	Nest Labs facts not present; no need to appoint.	Nest Labs factors not satisfied; appointment not necessary.

Corcoran v. CVS Health Corp., 169 F. Supp. 3d 970 (N.D. Cal. 2016) (court recognized interim counsel appointment where appropriate; supports evaluating factors)