Welcome from Classaction.org!

Thank you for your interest. Milberg is pursuing arbitration claims against KAYAK Software Corporation (“Kayak”) for using the TikTok Pixel, which intercepts subscribers' electronic communications, including but not limited to logging device identifiers, geographic information, IP addressing information, and URL tracking. KAYAK Software Corporation shares this data with TikTok without consent. We believe this is a violation of the California Invasion of Privacy Act.

If this happened to you, we believe you may be eligible to receive compensation for your damages. Milberg can pursue these claims on your behalf.

Please answer the following questions to help us determine if you are eligible to make a claim for compensation:







Congratulations!

Looks like you qualify and we’d like to immediately move your claim forward. This will cost you nothing out of pocket. We get paid only if we recover an award or settlement on your behalf. Our fee is 40% of the award we recover for you. If we don’t win, you don’t pay.

To move forward, please provide the following information:

Your data privacy and security is important to us. See below for our Privacy Policy









By continuing through this form, you represent that you do not own, work for, represent, or contemplate representing the company that is the subject of this arbitration. Milberg considers the following retainer agreement attorney work product and privileged. Any employee of a law firm viewing this document and not seeking representation is in violation of the Model Rules of Professional Conduct, including, but not limited to Rule 4.1.

Help us verify your claim

Kayak.com may require you to produce documentation or proof that you used their services. Please keep an eye out for future correspondence from Milberg. Your data privacy is important to us. This information will not be shared for any reason outside of pursuing this claim on your behalf.

If not, Milberg will reach out via email in the coming days.

The next step is essential in order to give us the permission we need to pursue this claim on your behalf.

You will be asked to electronically sign our Contingency Fee Agreement.

  • You pay nothing out of pocket
  • You will not be asked for any credit card information to hire our firm
  • If we win, our fee is paid from a percentage of the money we recover for you
  • If we do not win, you pay nothing


By continuing through this form, you represent that you do not own, work for, represent, or contemplate representing the company that is the subject of this arbitration. Milberg considers the following retainer agreement attorney work product and privileged. Any employee of a law firm viewing this document and not seeking representation is in violation of the Model Rules of Professional Conduct, including, but not limited to Rule 4.1.

Client Name: 
Client Email: 

Re: [CLIENT NAME] v. KAYAK Software Corporation

Dear [CLIENT NAME]

This is an agreement (the “Agreement”) between you and Milberg Coleman Bryson Phillips Grossman LLC (“MCBPG”) for legal representation for your claims against KAYAK Software Corporation (“Kayak”) for its violation of your privacy rights pursuant to the California Invasion of Privacy Act, including California Penal Code § 638.51. 

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 Kayak chooses to do so. 

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 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.
  

                        Sincerely,

                          Justin Day



Agreed to on this _____ day of _________________, 2024.


__________________________________
[CLIENT NAME]                    

   

CERTIFICATION 

I, the undersigned, hereby certify that I visited www.Kayak.com within the last 12 months and reserved a hotel, flight, or rental car via the website. I further certify that, if needed, I could produce evidence (for example, an email) of reserving a hotel, flight, or rental car via Kayak.com within the last 12 months.                     


__________________________________
[CLIENT SIGNATURE]
* Please note that the company against which you are retaining Milberg to pursue individual arbitration claims on your behalf requires a notice letter personally signed by you to begin the dispute resolution process.  So that Milberg can start this process, by signing the retainer agreement, it is your intent to provide Milberg with your electronic signature and your consent to include your electronic signature in the notice letter to be sent on your behalf to the company identified in the retainer agreement as the party against whom Milberg has agreed to represent you in connection with an individual arbitration.  This is the sole limited purpose for which you are giving Milberg legal authority to utilize your electronic signature.

Thank you for letting us review your potential claim.

After review of the information provided, our firm has decided to respectfully decline representation.

Although we are not representing you in this matter, we appreciate the opportunity to review your case, and we wish you the best possible outcome. Please feel free to contact us again should the need arise.

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