In Resnick v. Netflix, Inc., No. 12-15705 (9th Cir. Feb. 27, 2015), plaintiffs alleged WalMart and Netflix had divided the DVD rental market.  Plaintiffs settled their antitrust lawsuit for a fund of $27.25 million, consisting of: $6.8 million in attorneys’ fees; $1.7 million in expenses to class counsel; administration and notice costs of $4.5 million; and the remaining $14.1 million was made available to 1.2 million class members as gift cards or in cash.  The district court approved the settlement, and the Ninth Circuit affirmed the finding that the settlement was fair, reasonable, and adequate.  The Ninth Circuit found the incentive awards to class representatives did not create a conflict; the district court did not err in using a claim fund mechanism; and the notice was sufficient even though it failed to estimate how much each class member would recover.  Further, the reverter, which permitted defendants to recover funds if the settlement was rejected or to recover monies in excess of the amounts needed, did not undermine the settlement, and the district court adequately explained its reasons for approving the settlement.  Finally, the court’s approval of attorneys fees of 25% of the settlement was appropriate.  Had the settlement been a “coupon settlement,” CAFA would require fees to be paid based on redeemed benefits or the lodestar method.  The court agreed that the gift cards were not coupons, and thus not covered by the CAFA provision, because they could be used on a large number of items from a large retailer, and claimants had the option of receiving cash rather than a gift card.