In Redman v. RadioShack Corp., 768 F.3d 622 (7th Cir. 2014) (No. 14-1470), the Seventh Circuit reversed the approval of a class action settlement in a FACTA case, which would have involved the issuance of coupons to class members and paid $1 million to counsel.  Of the millions of class members, 83,000 claimed the $10 coupons.  The Seventh Circuit rejected the settlement because, among other things, the district court had viewed the costs of notice and claims administration purely as a benefit to the class, whereas those costs also benefited class counsel and defendants.  The Seventh Circuit also criticized valuing coupons at their nominal value.  Recognizing the benefits to defendants from a coupon settlement, the Seventh Circuit directed courts to scrutinize the benefit of coupons to class members in assessing a settlement’s fairness as the court could not assume that a $10 coupon was worth $10 to every recipient.  Further, agreeing with the Ninth Circuit’s ruling in In re Mercury Interactive Corp. Securities Litigation, 618 F.3d 988, 993-95 (9th Cir. 2010), the court held class counsel must file their attorneys’ fees motion before the deadline for objections to the settlement.  While objectors knew the amount of the fee petition, they were handicapped in objecting to the fee petition because details of hours and expenses were submitted later.