Key takeaways:

• Class counsel cannot receive a lodestar-based award that is out-of-proportion to the relief they obtain for the class in a proposed class settlement.
• "Clear sailing" agreements, where class defendants give up their right to object to plaintiffs' fee requests, must be closely scrutinized by district courts reviewing proposed settlements under Rule 23(e).
• In this case, and two others to come involving settlements that provide non-profit contributions rather than direct payments to class members, the Ninth Circuit will help establish the outer bounds of how parties can settle lower-value class actions.