Damages & valuation

Gutmann v. Apple Inc. (and Rodger v. Google, CAT)

England & Wales Court of Appeal; CAT · UK · 2025 · Decided

Citation/Docket: [2025] EWCA Civ 459; [2025] CAT 45

Parties & Funders

Posture: Funder payment priority in collective proceedings
Funder(s) involved: (Class-action funders)

Background

Whether funders and lawyers can be paid from damages before class members, and how tribunals assess funder returns.

Holding & Outcome

Yes, the CAT may order funder/lawyer payment ahead of the class; Rodger v. Google added that paying the funder first can even serve the class's interests. Merricks settlement scrutiny showed the CAT will also police the size of returns.

Practical Lesson

UK funder economics are now openly supervised: priority is available, but returns must be justified with evidence.

Matters like this one often turn on expert testimony, on valuation, industry custom and practice, legal ethics, or damages. The Institute partners with world-class expert witness referral companies for this purpose.

Compiled from public sources (court filings, published opinions, and secondary reporting) as part of the Institute's Phase 1 Dispute Library research. This is educational material, not legal advice; case citations should be independently verified before relied upon.

← Back to the Dispute Library