We look forward to working with you to pursue your claims against Arlo Technologies, Inc. (“Arlo”) for its violations of the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq., relating to Arlo’s monitoring, collecting, capturing, and storing your facial biometric data, including facial geometry, through the person detection feature of its home security cameras. This is an agreement (the “Agreement”) between you and Milberg Coleman Bryson Phillips Grossman LLC (“MCBPG”). I, along with MCBPG attorneys who are licensed to practice law in Illinois and other states, will be primarily responsible for your case. Although I am only licensed to practice law in Tennessee, our team at MCBPG includes attorneys licensed in Illinois and other states who will be working with me and others on your case.
You understand and authorize MCBPG to proceed with filing your claims as an individual arbitration. Arbitration is a simplified means of pursuing legal claims, where the claim is decided by an arbitrator rather than a judge or jury. However, this agreement also authorizes MCBPG to settle your claim as a part of a class action if Arlo chooses to do so. MCBPG intends to secure the maximum recovery for your or your minor child’s claims. However, you authorize MCBPG to resolve your claims with Arlo for, at a minimum, a one-hundred-dollar ($100.00) value. Of course, we will try to obtain a larger settlement amount.
Our firm will handle this matter with a contingent fee of the greater of either forty percent (40%), as allowed by state law, of any recovery obtained in this matter or a total attorneys’ fees awarded by the arbitrator or court. We reserve the right to associate any co-counsel, but our fee will be split among our firm and any firm(s) we associate.
We will advance all costs incurred by our firm during this litigation (e.g., filings fees, travel, etc.). We will be reimbursed for these costs if, and only if, we ultimately obtain a recovery. Advanced costs are deducted after the calculation of the contingent fee.
You authorize MCBPG to withdraw from our representation if we determine for sufficient reasons that the case should not continue. Regardless, we will maintain the file on this matter for at least six years. If requested, these will be returned to you after the conclusion of the representation.
Finally, we do not make any promises or guarantees regarding the outcome or conclusion of your claims. If you have any questions about the foregoing, please advise. We would appreciate your returning a signed copy of this engagement letter to us for our files.