Declaration of Kevin Appold — Brooks Thomsonreuters (Dkt. 244.2)

Summary

The Declaration of Kevin Appold, filed 09/05/24 as Document 244-2 in Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, No. 3:21-cv-01418-EMC, in the Northern District of California, San Francisco Division. It supports Thomson Reuters' statement responding to the plaintiffs' administrative motion on whether another party's materials should be sealed. Appold says he is Vice President, Product, US Public Records at West Publishing Corporation, which owns and operates the CLEAR platform, and has worked for Thomson Reuters more than 27 years. He states that detailed CLEAR capability information, non-public financial information, and the plaintiffs' experts' estimates of CLEAR finances attributable to California would harm Thomson Reuters if made public. The declaration was executed on August 29th, 2024.

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Case 3:21-cv-01418-EMC Document 244-2

Susan D. Fahringer, Bar No. 21567
SFahringer@perkinscoie.com
Nicola C. Menaldo, pro hac vice
NMenaldo@perkinscoie.com

Erin K. Earl, pro hac vice
EEarl@perkinscoie.com

Anna M. Thompson, pro hac vice
AnnaThompson@perkinscoie.com
PERKINS COIE LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Telephone: 206.359.8000
Facsimile: 206.359.9000

Attorneys for Defendant
Thomson Reuters Corporation

Filed 09/05/24 Pagelof4

Gabriella Gallego, Bar No. 324226
GGallego@perkinscoie.com
PERKINS COIE LLP

3150 Porter Drive

Palo Alto, CA 94304-1212
Telephone: 650.838.4300
Facsimile: 650.838.4350

Hayden M. Schottlaender,

pro hac vice
HSchottlaender@perkinscoie.com
PERKINS COIE LLP

500 N. Akard Street, Suite 3300
Dallas, TX 75201-3347
Telephone: 214.965.7700
Facsimile: 214.965.7799

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

CAT BROOKS and RASHEED
SHABAZZ, individually and on behalf of
all others similarly situated,
Plaintiffs,
V.

THOMSON REUTERS CORPORATION,

Defendant.

Case No. 3:21-cv-01418-EMC

Case No. 3:21-cv-01418-EMC

DECLARATION OF KEVIN APPOLD IN
SUPPORT OF THOMSON REUTERS’
STATEMENT IN RESPONSE TO
PLAINTIFF’S ADMINISTRATIVE
MOTION TO CONSIDER WHETHER
ANOTHER PARTY’S MATERIALS
SHOULD BE SEALED

-|- KEVIN APPOLD SEALING DECLARATION

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Case 3:21-cv-01418-EMC Document 244-2 Filed 09/05/24 Page 2of4

I, Kevin Appold, declare as follows:

L. I am Vice President, Product, US Public Records at West Publishing Corporation,
the wholly owned subsidiary of Thomson Reuters Corporation that owns and operates the
CLEAR platform. For purposes of this declaration, I will refer to West and Thomson Reuters
Corporation collectively as “Thomson Reuters.” I have been employed by Thomson Reuters for
more than 27 years. I manage a team responsible for continued development and operation of the
CLEAR platform, and I have led the Product Management team responsible for the integration
and ongoing design of CLEAR since Thomson Reuters acquired CLEAR in 2008. I submit this
declaration in support of Thomson Reuters’ Administrative Motion to File Under Seal
Confidential Information. I make this declaration based upon personal knowledge and if called
upon to do so I could and would testify competently to the facts set forth herein.

2. Detailed information related to CLEAR’s capabilities, especially when
particularized to specific content available through CLEAR, is not available to the general public,
including CLEAR competitors, and is instead ordinarily only available to credentialed and
authorized CLEAR customer(s) who certified a permissible use to access the record or report.
Public disclosure of this information would harm Thomson Reuters because CLEAR competitors
could leverage the detailed information for their own competitive purposes. And the information
could be taken out of context to give a misleading or inaccurate picture of CLEAR and related
business practices.

3. The public disclosure of financial information related to the CLEAR platform
(e.g., revenue, profits, and costs) that is not already public (e.g, in annual reports) would harm
Thomson Reuters because CLEAR competitors could leverage the detailed information for their
own competitive purposes. And the information could be taken out of context to give a
misleading or inaccurate picture of CLEAR and related business practices.

4. Public disclosure of the estimates provided by Plaintiffs’ experts in this case
regarding CLEAR finances and/or the portion of revenue, profits, costs, etc. that are purportedly
attributable to California would harm Thomson Reuters. Some of these estimates may reveal

confidential information about CLEAR finances. And the estimates are inaccurate, or at least

Case No. 3:21-cv-01418-EMC -2- KEVIN APPOLD SEALING DECLARATION

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Case 3:21-cv-01418-EMC Document 244-2 Filed 09/05/24 Page 3of4

grossly misleading, and could therefore result in a misleading or inaccurate picture of CLEAR

and related business practices.

[signature on following page]

Case No. 3:21-cv-01418-EMC s. KEVIN APPOLD SEALING DECLARATION

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Case 3:21-cv-01418-EMC Document 244-2 Filed 09/05/24 Page 4of4

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 29th, 2024, in Ee gan, MN.

Ken loyal

Kevirl Appold /

Case No. 3:21-cv-01418-EMC _4- KEVIN APPOLD SEALING DECLARATION

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