Exhibit 69 — Brooks v. Thomson Reuters Corporation (Dkt. 130.28)

Summary

Exhibit 69 to Document 130-28, filed 11/09/22 in Case No. 3:21-cv-01418-EMC-KAW, is the Declaration of Rasheed Shabazz in support of Plaintiffs' motion for class certification. He says he never gave Thomson Reuters consent to collect, compile or sell access to his information and was never paid. He says his CLEAR profile contained errors, including suggesting that he had filed for divorce and may have outstanding familial support obligations, and that when he started to opt out he stopped after being asked for a photograph of his government-issued ID and a picture of his face. He asks to be appointed a class representative, says he has answered interrogatories and had his deposition taken, and says he knows of no conflict.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Case 3:21-cv-01418-EMC   Document 130-28   Filed 11/09/22   Page 1 of 5




            EXHIBIT 69
         Case 3:21-cv-01418-EMC            Document 130-28     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    Hanne Jensen (SBN 336045)                          Washington, DC 20005
      GIBBS LAW GROUP LLP                                Telephone: (202) 408-4600
 5    1111 Broadway, Suite 2100                          Facsimile: (202) 408-4699
 6    Oakland, California 94607                          ggraber@cohenmilstein.com
      Telephone: (510) 350-9700                          kputtieva@cohenmilstein.com
 7    Facsimile: (510) 350-9701
      ehg@classlawgroup.com
 8
      amm@classlawgroup.com
 9    amz@classlawgroup.com
      mht@classlawgroup.com
10    zsw@classlawgroup.com
11    hj@classlawgroup.com

12   Attorneys for Plaintiffs and the Proposed Class

13
                              UNITED STATES DISTRICT COURT FOR THE
14                              NORTHERN DISTRICT OF CALIFORNIA
                                     SAN FRANCISCO DIVISION
15
16     CAT BROOKS and RASHEED SHABAZZ,                 Case No. 3:21-cv-01418-EMC-KAW
       individually and on behalf of all others
17     similarly situated,
                                                       DECLARATION OF RASHEED SHABAZZ IN
18
                             Plaintiffs,               SUPPORT OF PLAINTIFFS’ MOTION FOR
19                                                     CLASS CERTIFICATION
                    v.
20
21     THOMSON REUTERS CORPORATION,

22                           Defendant.
23
24
25
26
27
28

                         DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF
                           PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                   Case No.: 3:18-cv-01418-EMC-KAW
          Case 3:21-cv-01418-EMC            Document 130-28          Filed 11/09/22      Page 3 of 5




 1          I, Rasheed Shabazz, declare:
 2          1.      I am a Plaintiff in this action. I submit this declaration in support of Plaintiffs’ motion
 3   for class certification. I have personal knowledge of the facts in this declaration and, if called as a
 4   witness, could and would testify to their accuracy.
 5          2.      I am resident of Alameda, California and am a journalist and community organizer. I
 6   recently completed my Masters of City and Regional Planning at UC Berkeley, and I currently serve in
 7   a variety of roles in which I work to inspire, support, and uplift voices in my community through public
 8   history, multimedia, and youth development projects. I care deeply about issues of fairness affecting
 9   my community and have spent considerable time and effort working to support people seeking justice
10   in housing, education, and other aspects of civic life.
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 profile in CLEAR under my current and former name. My profile
15   contained errors, including suggesting that I had filed for divorce and may have outstanding familial
16   support obligations, even though I have never been legally married and had no children at the time.
17   And, as I understand it, because I changed my name to remove the association with people who had
18   enslaved my ancestors, CLEAR marks me as a higher risk individual.
19          6.      Except for the searches I allowed Quest Research & Investigations to run about me so
20   that I could see what was in my CLEAR profile, I have never given anyone consent to search my
21   information in CLEAR, including Thomson Reuters’ customers.
22          7.      When I learned that Thomson Reuters was selling access to my personal information in
23   CLEAR, I started to opt out. But when Thomson Reuters asked me to provide a photograph of my
24   government-issued ID and a separate picture of my face, I decided not to continue the process because I
25   was not comfortable providing Thomson Reuters with even more personal information about me.
26
27
28                       DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF
                           PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                  Case No.: 3:18-cv-01418-EMC-KAW
                                                   1
          Case 3:21-cv-01418-EMC           Document 130-28          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 consent. It
 3   is my understanding that most Californians are not even aware of CLEAR and may not know that
 4   Thomson Reuters is selling access to their information to its customers. I believe that a class action will
 5   save time, money, and effort, and will help to prevent Californians’ personal information from being
 6   shared without their consent.
 7           9.     I have been actively involved in this lawsuit since it started. I have answered
 8   interrogatories, kept in touch with my attorneys to track the case’s progress, and have had my
 9   deposition taken.
10           10.    I understand the responsibilities of a class representative to protect the interests of the
11   class and am prepared to serve in that role. I am not aware of any conflict that would prevent me from
12   fairly and adequately representing the class.
13           11.    If the Court appoints me to serve as a class representative, I will continue to perform my
14   duties to the best of my ability.
15           I declare under penalty of perjury that the foregoing is true and correct. Executed November 7,
16   2022.
17
18                                                         Rasheed Shabazz
19
20
21
22
23
24
25
26
27
28                       DECLARATION OF RASHEED SHABAZZ IN SUPPORT OF
                           PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION
                                  Case No.: 3:18-cv-01418-EMC-KAW
                                                   2
Case 3:21-cv-01418-EMC   Document 130-28   Filed 11/09/22   Page 5 of 5


File and source

File

gov.uscourts.cand.374304.130.28.pdf

Size

1,473,666 bytes

SHA-256

60ccc56a4fea0d6ef935e2591b501eaae7a6bc57f96fbfd54a21042590bd5b5d

Our copy

gov.uscourts.cand.374304.130.28.pdf

Original

PACER (login required)