Exhibit 68 — Brooks v. Thomson Reuters Corporation (Dkt. 130.27)

Summary

Exhibit 68, Document 130-27, filed 11/09/22 in Case 3:21-cv-01418-EMC, five pages. It is a Declaration of Cat Brooks in Support of Plaintiffs Motion for Class Certification in Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, Case No. 3:21-cv-01418-EMC-KAW, United States District Court for the Northern District of California, San Francisco Division. The declarant states that she is a Plaintiff in the action, that she never gave Thomson Reuters consent to collect, compile or sell access to her information and that Thomson Reuters never asked for her consent. She also states that Thomson Reuters has never paid her for its use of her personal information.

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Case 3:21-cv-01418-EMC   Document 130-27   Filed 11/09/22   Page 1 of 5




            EXHIBIT 68
         Case 3:21-cv-01418-EMC            Document 130-27     Filed 11/09/22   Page 2 of 5




 1    Eric H. Gibbs (SBN 178658)                         Geoffrey A. Graber (SBN 211547)
      Andre M. Mura (SBN 298541)                         Karina G. Puttieva (SBN 317702)
 2
      Amy M. Zeman (SBN 273100)                          COHEN MILSTEIN SELLERS & TOLL
 3    Mark H. Troutman (pro hac vice)                    PLLC
      Ezekiel S. Wald (SBN 341490)                       1100 New York Ave. NW, Fifth Floor
 4                                                       Washington, DC 20005
      Hanne Jensen (SBN 336045)
 5    GIBBS LAW GROUP LLP                                Telephone: (202) 408-4600
      1111 Broadway, Suite 2100                          Facsimile: (202) 408-4699
 6    Oakland, California 94607                          ggraber@cohenmilstein.com
 7    Telephone: (510) 350-9700                          kputtieva@cohenmilstein.com
      Facsimile: (510) 350-9701
 8    ehg@classlawgroup.com
 9    amm@classlawgroup.com
      amz@classlawgroup.com
10    mht@classlawgroup.com
11    zsw@classlawgroup.com
      hj@classlawgroup.com
12
13   Attorneys for Plaintiffs and the Proposed Class

14
                             UNITED STATES DISTRICT COURT FOR THE
15                             NORTHERN DISTRICT OF CALIFORNIA
                                   SAN FRANCISCO DIVISION
16
17     CAT BROOKS and RASHEED                          Case No. 3:21-cv-01418-EMC-KAW
       SHABAZZ, individually and on behalf
18     of all others similarly situated,
19                                                     DECLARATION OF CAT BROOKS IN
                             Plaintiffs,               SUPPORT OF PLAINTIFFS’ MOTION FOR
20                                                     CLASS CERTIFICATION
21                  v.

22     THOMSON REUTERS CORPORATION,
23
                             Defendant.
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                           DECLARATION OF CAT BROOKS IN SUPPORT OF
                          PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                  Case No.: 3:18-cv-01418-EMC-KAW
         Case 3:21-cv-01418-EMC          Document 130-27        Filed 11/09/22     Page 3 of 5




 1          I, Cat Brooks, declare:
 2          1.      I am a Plaintiff in this action. I submit this declaration in support of Plaintiffs’
 3   motion for class certification. I have personal knowledge of the facts in this declaration and, if
 4   called as a witness, could and would testify to their accuracy.
 5          2.      I live in Oakland, California and am an activist, organizer, playwright, and
 6   performer. Currently, I am the executive director of Justice Teams Network and the Anti
 7   Police-Terror Project, and I host the radio show Law & Disorder on KPFA. I was raised in an
 8   activist household and have dedicated my life to improving the lives of people in my
 9   community and bringing awareness to injustices we face through politics, writing, art, and
10   other media.
11          3.      I never gave Thomson Reuters consent to collect, compile, or sell access to my
12   information, and Thomson Reuters never asked me for my consent.
13          4.      Thomson Reuters has never paid me for its use of my personal information.
14          5.      I reviewed my CLEAR profile, which inaccurately stated I had never been
15   married, even though I was married at the time. It also inaccurately suggested that I had
16   worked with certain people who were not employed by the organizations I worked with
17   while I was there.
18          6.      I gave my consent to Quest Research & Investigations to run a search of my
19   information in CLEAR so that I could see my CLEAR profile. Except for the search Quest ran
20   on me, I have never given anyone consent to search my information in CLEAR.
21          7.      I wanted to opt out of my personal information being made available for sale
22   through CLEAR. I went to Thomson Reuters’ website to do so, but abandoned the process
23   when Thomson Reuters asked me to provide a photograph of my government-issued ID and
24   a separate picture of my face. I didn’t complete the process because I was not comfortable
25   providing Thomson Reuters with even more personal information about me.
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28                         DECLARATION OF CAT BROOKS IN SUPPORT OF
                          PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                 Case No.: 3:18-cv-01418-EMC-KAW
                                                  1
         Case 3:21-cv-01418-EMC         Document 130-27       Filed 11/09/22     Page 4 of 5




 1          8.     I am asking to be appointed as a class representative so that I can represent all
 2   Californians whose personal information is available to be searched in CLEAR without their
 3   consent. It is my understanding that most Californians are not even aware of CLEAR and
 4   may not know that Thomson Reuters is selling access to their information to its customers. I
 5   believe that a class lawsuit will save time, money, and effort, and will help to prevent
 6   Californians’ personal information from being shared without their consent.
 7          9.     I have been actively involved in this lawsuit since it started. I have answered
 8   interrogatories, communicated with my attorneys to keep apprised of the progress of the case,
 9   and have had my deposition taken.
10          10.    I understand the responsibilities of a class representative to protect the interests
11   of the class and am prepared to serve in that role. I am not aware of any conflict that would
12   prevent me from fairly and adequately representing the class.
13          11.    If the Court appoints me to serve as a class representative, I will continue to
14   perform my duties to the best of my ability.
15          I declare under penalty of perjury that the foregoing is true and correct. Executed on
16   November 7, 2022.
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                                                      Cat Brooks
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28                        DECLARATION OF CAT BROOKS IN SUPPORT OF
                         PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                Case No.: 3:18-cv-01418-EMC-KAW
                                                 2
Case 3:21-cv-01418-EMC   Document 130-27   Filed 11/09/22   Page 5 of 5


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