In Fraley v. Batman,Nos. 13-16819, 13-16918, 13-16919, 13-16929, 13-16936, 13-17028, 14-15595 (9th Cir. Jan. 6, 2016) (mem.), plaintiffs claimed certain Facebook practices violated their privacy rights. Under the applicable California statute, plaintiffs could claim a $750 penalty per violation. The parties reached a settlement, under which each class member who made a claim would receive $15. The rest of the $20 million settlement was used to pay attorneys’ fees and fund charitable contributions. The Ninth Circuit affirmed the approval of the settlement, finding the district court did not abuse its discretion. The monetary award was reasonable in light of the minimal (if any) harm suffered by the plaintiffs. An award of statutory penalty, the court noted, could implicate due process concerns. One member of the panel dissented, asserting that cy pres should be limited to where it is a required substitute for class distributions.