Section 1712 of CAFA provides that if a proposed settlement provides for recovery of coupons, the portion of attorneys’ fees attributable to the award of coupons should be based on the coupons actually redeemed.  CAFA, however, does not define “coupon.”  In Davis v. Cole Haan, Inc., No. 11-01826 (N.D. Cal. Oct. 21, 2013), the parties settled a case by providing $20 cash off vouchers to certain customers and a 30% merchandise voucher to other customers.  The court concluded that the settlement’s noncash benefit triggered Section 1712.  Because of the restrictions on the redemption of the settlement benefit – the vouchers were valid for six months, could not be combined with other offers, and could only be used in Cole Haan stores ­­– the court concluded the 30% merchandise voucher, and perhaps the cash off voucher, were coupons.  As a result, the court denied the request for fees, without prejudice to seek fees after the value of redeemed coupons was determined.  The court also declined without prejudice the request for incentive awards.  The court directed plaintiffs to submit descriptions of the work that would entitle them to an incentive award.