Stark v. Patreon, Inc.

Summary

The Northern District of California denied Lexclaim’s motion for leave to seek partial reconsideration of the court’s June 5, 2025 order approving a class action settlement and invalidating certain opt-out forms. The court held that Lexclaim had not shown a basis for reconsideration under Civil Local Rule 7-9(b)(3) and had repeated arguments in violation of Rule 7-9(c).

Holdings

1. Lexclaim did not establish a manifest failure by the court to consider material facts or dispositive legal arguments, even assuming that the challenged group-opt-out conclusion was unnecessary to the relief ordered.
2. The court's conclusions that the assignments were invalid and that Lexclaim's opt-out form was a prohibited group opt-out were alternative holdings and were not inconsistent.
3. Lexclaim violated Civil Local Rule 7-9(c) by repeating an argument it had previously made—that its opt-out form could not be a group opt-out because Lexclaim was a single entity.

Questions Presented

1. Whether Lexclaim demonstrated a manifest failure by the court to consider material facts or dispositive legal arguments under Civil Local Rule 7-9(b)(3).
2. Whether the court's conclusions that the assignments were invalid and that Lexclaim's opt-out form was a prohibited group opt-out were inconsistent.
3. Whether Lexclaim's motion violated Civil Local Rule 7-9(c) by repeating arguments previously presented.

Disposition

other