e. The Third Circuit has recognized that fee percentage-of- recovery fee awards commonly range from 19 percent to 45 percent of the settlement fund. GM Truck Prods., 55 F.3d at 822. Using the rough $10430 million settlement For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0064712

the parties' agreement." Fed. R. Civ. P. 23(h). A "thorough judicial r59] review of fee applications is required in all class action settlements." GM Truck Prods., 55 F.3d at 819. "Determining an appropriate award is not an exact science," and the "facts of each individual case drive the amount of any award.

: Complexity and duration of litigation The first Girsh factor considers the complexity and likely [*26] duration of litigation without settlement. GM Truck Prods., 55 F.3d at 785. This factor favors approving a settlement when resolution of the claims by trial would require "additional discovery, extensive pr