Stark v. Patreon, Inc.
- Joseph Spero
- 3:22-cv-03131
- U.S. District Court · Northern District of California
- 3
Counsel of record per CourtListener. Firm names are approximate.
In Stark v. Patreon, Judge Spero denied Lexclaim’s request to reconsider rulings about settlement opt-out forms.
Lexclaim, the 927 individual class members whose claims it purportedly obtained by assignment, and the parties to the class-action settlement.
What happened
Stark v. Patreon, Inc. concerns Lexclaim’s request to revisit part of an earlier order approving a class-action settlement and ruling on opt-out forms.
Lexclaim asked the court to remove its conclusion that Lexclaim’s own opt-out form was an invalid group opt-out. The court had also found that 927 class members’ purported assignments of their claims to Lexclaim were invalid. Lexclaim argued that the group-opt-out conclusion was unnecessary, unsupported, and inconsistent with the finding that the assignments were invalid.
Judge Spero denied the motion. He ruled that Lexclaim had not shown the required failure to consider important facts or legal arguments, and that the two findings were alternative holdings rather than conflicting ones. He also ruled that Lexclaim repeated an argument it had already made, contrary to the local rule governing reconsideration requests.
The detailed version
- Stark v. Patreon, Inc. · No. 3:22-cv-03131
- Joseph Spero
- July 8, 2025
Background
On June 5, 2025, the court approved the class-action settlement and ruled on the validity of opt-out forms submitted by Lexclaim. The court found that 927 opt-out forms from individual class members who purportedly assigned their claims to Lexclaim, along with an opt-out form submitted in Lexclaim’s own name, were invalid “group opt-outs” prohibited by the settlement agreement.
Lexclaim filed a motion seeking permission to file a motion for partial reconsideration or, alternatively, partial reconsideration. It asked the court to remove the conclusion that Lexclaim’s own opt-out request was invalid because it was a prohibited group opt-out. Lexclaim argued that conclusion was unnecessary to the relief ordered, unsupported by the court’s reasoning, and inconsistent with the court’s finding that the underlying assignments of the 927 class members’ claims were invalid. Lexclaim also repeated its argument that its form could not be a group opt-out because Lexclaim was a single entity.
Court’s Analysis
The court rejected Lexclaim’s argument under Civil Local Rule 7-9(b)(3), which permits reconsideration when the court has manifestly failed to consider material facts or dispositive legal arguments previously presented. The court stated that even if the group-opt-out conclusion were unnecessary to the relief ordered, that would not establish the required failure. It also held that the findings about the invalid assignments and the prohibited group opt-out were alternative holdings, not conflicting holdings.
The court separately found that Lexclaim violated Civil Local Rule 7-9(c), which prohibits a motion for leave to file a reconsideration motion from repeating arguments previously made about the order at issue. The court concluded that Lexclaim had already made the argument that its single-entity status prevented its form from being a group opt-out. The court stated that reconsideration could not be used to ask it to rethink a conclusion it had already considered.
Disposition
The court denied Lexclaim’s motion for leave to file a motion for partial reconsideration or, in the alternative, for partial reconsideration. The opinion does not change the June 5 findings described above.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.