In Laguna v. Coverall North America, Inc., 753 F.3d 918 (9th Cir. 2014) (No. 12-55479), plaintiffs challenged defendant’s franchise practices. After two years of “significant litigation,” the parties agreed to a settlement in which current franchisees would receive pledges of certain customer accounts upon payment of their franchise fees, and former franchise owners would receive cash and a credit towards the purchase of a new franchise. Class counsel were to receive approximately $1 million in fees. The district court approved the settlement, and the Ninth Circuit affirmed. The court first analyzed the fee request, which it found reasonable. The fees amounted to one-third of the lodestar, which the court cross-checked by reference to a percentage of the fund recovery. As to the fairness of the settlement, the Ninth Circuit deferred to the district court. While the court did not explicitly value the injunctive remedy, it found the settlement terms sufficient. Particularly because the attorneys’ fee was less than the full lodestar, the court found the opportunity for collusion to be minimal. One judge dissented, criticizing the majority for not insisting upon proof of the value of the monetary benefit of the settlement, which was conditional upon class members making payments to the defendant, or the value of the monetary relief for the class.