Facebook's $650 million settlement, approved in February 2021 to resolve claims that its Tag Suggestions facial-recognition feature violated Illinois' Biometric Information Privacy Act (BIPA), remains the largest confirmed BIPA settlement on record, according to Robbins Geller Rudman and Dowd LLP, lead counsel in the case. It is more than 7 times bigger than the next-largest confirmed settlement, and the 10 largest confirmed BIPA settlements combined now total roughly $949 million. Four of those ten were finalized in 2025 alone.
Which BIPA settlement is the largest?
Facebook's $650 million settlement, approved by a federal judge in February 2021, is the largest confirmed settlement reached under BIPA. The case centered on Tag Suggestions, a feature that used facial-recognition software to scan and identify people in photos uploaded to the platform without the written consent the statute requires. Robbins Geller Rudman and Dowd LLP, counsel for the roughly 1.6 million class members, described it as the largest cash settlement ever paid out over a privacy violation at the time it received final approval.
Figure 1: The three largest confirmed BIPA settlements by amount. Source: Robbins Geller Rudman and Dowd LLP (2021), FeganScott via BusinessWire and natlawreview.com (2022), ICLG and Constangy LLP (2025).
No other confirmed BIPA settlement has come close since. That gap is the clearest sign that a handful of large consumer-platform cases, not the more numerous employer fingerprint-timeclock lawsuits, drive most of the dollar total in BIPA litigation.
How do the 10 largest BIPA settlements rank against each other?
Below Facebook, the ranking drops off fast. TikTok and parent company ByteDance settled for $92 million in a case that received final court approval on August 22, 2022, resolving claims under both BIPA and the federal Video Privacy Protection Act. Clearview AI's settlement, structured as a 23% equity stake in the company rather than a cash payment, was valued at $51.75 million when a federal judge granted final approval on March 20, 2025, based on Clearview's own January 2024 valuation.
Figure 2: The 10 largest confirmed BIPA settlements, ranked by amount. Sources: see the numbered list at the end of this post.
Motorola Solutions and its Vigilant Solutions subsidiary follow at $47.5 million, approved in September 2025 over the FaceSearch facial-recognition database. Six Flags ($36 million, 2021) and Snapchat ($35 million, 2022) round out the top six, both stemming from consumer-facing biometric scanning rather than workplace timeclocks.
How much have the largest BIPA settlements paid out combined?
The 10 largest confirmed BIPA settlements add up to roughly $949 million, based on PrivacyTerms.io's compilation of court filings and law firm press releases covering settlements finalized between 2021 and 2025. That total climbed unevenly: three settlements closed in 2021, two more in 2022, then a full calendar year, 2023, passed without a new settlement cracking the top 10 before four more were finalized in 2025 alone.
Figure 3: Cumulative total of the 10 largest confirmed BIPA settlements by year finalized. Sources: see the numbered list at the end of this post.
That 2025 cluster, Clearview AI, Motorola Solutions, Speedway, and Google Workspace for Education, adds up to $120.1 million on its own, more new top-10 settlement money finalized in a single year than 2022, 2023, and 2024 combined. Biometric litigation exposure keeps growing alongside adoption of the technology itself: the biometrics market is projected to reach $59.7 billion in 2026, which means more companies are collecting the exact data category BIPA regulates.
How is the $949 million split across companies?
A single case still dominates the total. Facebook's $650 million equals 68% of the combined $949 million paid out across the 10 largest confirmed BIPA settlements, and the top 3 settlements together, Facebook, TikTok, and Clearview AI, account for 84% of every dollar.
Figure 4: Share of the combined $949 million total by company. Sources: see the numbered list at the end of this post.
The remaining 6 settlements on the list, Motorola Solutions, Six Flags, Snapchat, Speedway, White Castle, and Google Workspace for Education, together total $108 million, just 11% of the combined figure despite making up 60% of the cases counted. Anyone collecting fingerprints, face scans, or voiceprints from Illinois residents carries that same exposure regardless of company size, and a privacy policy generator built to name biometric data as its own disclosed category is a faster fix than waiting for a regulator or plaintiffs' firm to flag a missing consent notice.
Does a bigger settlement always mean a bigger per-person payout?
Not even close. Total settlement size mostly reflects how many people are in the class, not how much each person collects. Speedway's $12.1 million fingerprint-timeclock settlement, finalized in October 2025, covered roughly 7,700 current and former Illinois employees and worked out to an estimated $970 per class member, according to the settlement administrator.
Figure 5: Estimated payout per class member for four confirmed BIPA settlements. Sources: see the numbered list at the end of this post.
Facebook's settlement, spread across roughly 1.6 million class members, works out to about $406 per person, well below Speedway's per-person figure despite being 54 times larger in total dollars. Six Flags and Shutterfly, both covering class sizes above 900,000 people, fall to an estimated $33 and $7 per member. Smaller, employer-side cases with a few thousand class members routinely outpay the record-setting consumer platform cases on a per-person basis, which matters more to an affected worker than the headline settlement total does. That same pattern shows up across the broader litigation trend: even as BIPA lawsuit filings fell 65% in 2025, the settlements still working through the courts keep producing meaningful individual payouts.
How does each of the 10 largest BIPA settlements compare?
| Company | Settlement | Year finalized | Basis |
|---|---|---|---|
| $650,000,000 | 2021 | Tag Suggestions facial recognition | |
| TikTok / ByteDance | $92,000,000 | 2022 | BIPA and VPPA claims combined |
| Clearview AI | $51,750,000 (equity) | 2025 | Photo-scraping facial recognition database |
| Motorola Solutions / Vigilant Solutions | $47,500,000 | 2025 | FaceSearch facial recognition |
| Six Flags | $36,000,000 | 2021 | Fingerprint-based repeat-entry passes |
| Snapchat | $35,000,000 | 2022 | Lenses and filters facial scanning |
| Speedway | $12,100,000 | 2025 | Fingerprint timeclock |
| White Castle | $9,390,000 | 2024 | Fingerprint timeclock |
| Google Workspace for Education | $8,750,000 | 2025 | Chromebook facial data collection |
| Shutterfly | $6,750,000 | 2021 | Face-tagging photo uploads |
Source: PrivacyTerms.io compilation of court filings and law firm press releases; see the numbered sources below for each individual case.
Nine of the 10 settlements land below Facebook's $650 million, and eight land below $100 million, which is the clearest evidence that one case sets the scale for the entire BIPA settlement record rather than the record being built from many comparably sized payouts.
The Bottom Line
$650 million is the correct answer to "what is the largest BIPA settlement," but it says little about what a typical case actually costs a company. The 10 largest confirmed settlements combined total $949 million, 84% of it concentrated in just three cases, while the smaller employer-side fingerprint-timeclock settlements often pay affected workers more per person than the record-setting consumer platform deals do. Any business collecting fingerprints, face scans, or voiceprints from Illinois residents faces exposure on the same statute that produced both ends of this list, and a current, biometric-specific privacy policy disclosure remains the cheapest way to stay off it.
Frequently Asked Questions
What is the largest BIPA settlement ever reached? $650 million, the amount Facebook agreed to pay in February 2021 to resolve claims that its Tag Suggestions facial-recognition feature violated Illinois' Biometric Information Privacy Act, according to Robbins Geller Rudman and Dowd LLP, lead counsel in the case.
How much have the 10 largest BIPA settlements paid out combined? Roughly $949 million, based on PrivacyTerms.io's compilation of the 10 largest confirmed BIPA settlements finalized between 2021 and 2025, ranging from Facebook's $650 million down to Shutterfly's $6.75 million.
Which BIPA settlement paid the most per class member? Speedway's $12.1 million fingerprint-timeclock settlement, finalized in October 2025, worked out to an estimated $970 per class member, more than double Facebook's roughly $406 per member even though Facebook's total settlement was 54 times larger.
How many of the largest BIPA settlements were finalized in 2025? 4 of the 10 largest confirmed BIPA settlements, covering Clearview AI, Motorola Solutions, Speedway, and Google Workspace for Education, received final court approval in 2025, more than any other single year on record.
Where the Numbers Come From
- Robbins Geller Rudman and Dowd LLP. (2021). "Landmark $650 Million Settlement in Facebook Biometric Class Action Approved." Final approval February 26, 2021, covering roughly 1.6 million class members.
- National Law Review. (2022). "TikTok Settlement Receives Final Court Approval." $92 million settlement, final judgment entered August 22, 2022.
- ICLG. (2025). "Clearview AI USD 51.75 Million Class Action Settlement Approved." 23% equity stake, final approval March 20, 2025.
- ClassAction.org. (2025). "$47.5M Motorola Solutions Settlement Resolves Class Action Lawsuit Over Alleged FaceSearch BIPA Violations." Final approval September 15, 2025.
- Lewis Brisbois Bisgaard and Smith LLP. (2021). "Six Flags Agrees to $36 Million BIPA Class Action Settlement." Covering more than 1.1 million fingerprint-scan class members.
- Top Class Actions. (2022). "Snapchat Biometric Privacy $35M Class Action Settlement." Settlement reached August 23, 2022.
- ClassAction.org. (2025). "$12M+ Speedway Settlement Ends Class Action Lawsuit Over Alleged Biometric Privacy Violations." Final approval October 23, 2025, covering roughly 7,700 class members at an estimated $970 each.
- Top Class Actions. (2024). "Judge Gives Final Approval to $9.39M White Castle BIPA Settlement." Final approval August 1, 2024.
- ClassAction.org. (2025). "$8.75M Google Settlement Resolves Class Action Lawsuit Over Alleged Chromebook Privacy Violations." Final approval October 17, 2025, covering roughly 660,000 Illinois students.
- Willkie Compliance Concourse. (2021). "Illinois Court Approves BIPA Class Action Settlement with Shutterfly." Final approval September 9, 2021, covering roughly 955,000 class members.
Note: All figures verified as of October 2026. The $949 million combined total, the percentage breakdowns, and the per-class-member payout figures in this post are PrivacyTerms.io's own calculations, run on the 10 individually sourced settlements listed above. This post will be refreshed at least twice a year as new BIPA settlements receive final court approval.
