I take this opportunity to say I told you so.  "We clarify today that when an attorney fee is awarded out of a common fund preserved or recovered by means of litigation (see Serrano III, supra, at p. 35), the award is not per se unreasonable merely because it is calculated as a percentage of the common fund."  Laffitte, et al. v. Robert Half International, Inc., et al., at p. 2 (August 11, 2016).  See the rest if you have the time, but this should put an end to the spreading nonsense that lodestar is the method for calculating fees in common fund class action settlements.