Court filing

Exhibit 60 to the Mura Declaration - Public Version of ECF No.… — Brooks v. Thomson Reuters Corporation (Dkt. 148.13)

Summary

Exhibit 60 (Redacted), Document 148-13, filed 12/14/22 in Case 3:21-cv-01418-EMC, seven pages. It is Defendant Thomson Reuters Corporation's First Supplemental Answers and Objections to Plaintiffs' First Set of Interrogatories to Defendant in Cat Brooks and Rasheed Shabazz v. Thomson Reuters Corporation, Case No. 3:21-cv-01418-EMC, United States District Court, Northern District of California, San Francisco Division. The propounding party is Plaintiffs Cat Brooks and Rasheed Shabazz and the responding party is Defendant, Set No. One. It states that the supplemental answers incorporate the original answers and are based on information currently available as discovery is not complete, and the text reaches Interrogatory No. 16.

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“Exhibit 60 to the Mura Declaration - Public Version of ECF No.… — Brooks v. Thomson Reuters Corporation (Dkt. 148.13).” Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 148-13. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2022-12-14-gov-uscourts-cand-374304-148-13-doc-148-13/, SHA-256 933ba4335ba451bc2c0e11d5e58ce51659ff598641d24f3f65ccf40673a80fbc.

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Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 1 of 7




           EXHIBIT 60
                      (Redacted)
     Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 2 of 7




 1   Susan D. Fahringer, Bar No. 21567                      Gabriella Gallego, Bar No. 324226
     SFahringer@perkinscoie.com                             GGallego@perkinscoie.com
 2   Nicola C. Menaldo, pro hac vice                        PERKINS COIE LLP
     NMenaldo@perkinscoie.com                               3150 Porter Drive
 3   Erin K. Earl, pro hac vice                             Palo Alto, CA 94304-1212
     EEarl@perkinscoie.com                                  Telephone: 650.838.4300
 4   Anna M. Thompson, pro hac vice                         Facsimile: 650.838.4350
     AnnaThompson@perkinscoie.com
 5   PERKINS COIE LLP
     1201 Third Avenue, Suite 4900
 6   Seattle, WA 98101-3099
     Telephone: 206.359.8000
 7   Facsimile: 206.359.9000

 8   Attorneys for Defendant
     Thomson Reuters Corporation
 9

10                           UNITED STATES DISTRICT COURT
11                         NORTHERN DISTRICT OF CALIFORNIA
12                                 SAN FRANCISCO DIVISION
13

14   CAT BROOKS and RASHEED                           Case No. 3:21-cv-01418-EMC
     SHABAZZ, individually and on behalf
15   of all others similarly situated,                DEFENDANT THOMSON REUTERS
                                                      CORPORATION’S FIRST
16                       Plaintiffs,                  SUPPLEMENTAL ANSWERS AND
                                                      OBJECTIONS TO PLAINTIFFS’ FIRST
17         v.                                         SET OF INTERROGATORIES TO
                                                      DEFENDANT
18   THOMSON REUTERS
     CORPORATION,
19
                         Defendant.
20

21

22   PROPOUNDING PARTY:                Plaintiffs Cat Brooks and Rasheed Shabazz

23   RESPONDING PARTY:                 Defendant Thomson Reuters Corporation

24   SET NO:                           One

25

26

27

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     Case No. 3:21-cv-01418-EMC                           THOMSON REUTERS’ FIRST SUPPLEMENTAL
                                                         ANSWERS AND OBJECTIONS TO FIRST SET OF
                                                                              INTERROGATORIES
     Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 3 of 7




 1          Thomson Reuters Corporation (“Thomson Reuters”), by its counsel, pursuant to Rule 33
 2   of the Federal Rules of Civil Procedure hereby provides the following First Supplemental
 3   Answers and Objections to Plaintiffs’ First Set of Interrogatories to Defendant (“Interrogatories”).
 4   These Supplemental Answers and Objections necessarily incorporate and add to Thomson
 5   Reuters’ original Answers and Objections to Plaintiffs’ First Set of Interrogatories. Thomson
 6   Reuters’ combined answers and objections (“Answers”) are based on information currently
 7   available to Thomson Reuters as discovery is not complete and Thomson Reuters’ investigation is
 8   ongoing. Thomson Reuters reserves the right to further supplement or amend these Answers
 9   should additional information become available through the discovery process or otherwise.
10                                   ANSWERS AND OBJECTIONS
11   INTERROGATORY NO. 16:
12          For each fiscal quarter between Q1 2015 and the present, state the gross and net revenues
13   You have generated from CLEAR, delineated by each of the ways that You collect revenue from
14   CLEAR (for example, revenue attributable to per-search charges, revenue attributable to
15   subscription plans, revenue attributable to custom pricing packages, revenue attributable to
16   standard package arrangements including CLEAR, or any other means by which CLEAR
17   generates revenue).
18   ANSWER TO INTERROGATORY NO. 16:
19          Thomson Reuters understands this Interrogatory to seek revenue and operating income
20   (EBITDA or earnings before interest, taxes, depreciation, and amortization) for CLEAR
21   since 2015. Thomson Reuters further understands that Plaintiffs seek that revenue data broken
22   down based on CLEAR pricing models.
23          Subject to that interpretation and without waiving the objections set forth below, in
24   answer to this Interrogatory, pursuant to Federal Rule of Civil Procedure 33(d), Thomson Reuters
25   refers Plaintiffs to TR-BROOKS017074, which provides financial data for CLEAR on an annual
26   basis. To the extent that this Interrogatory seeks this information broken down by fiscal quarter,
27   Thomson Reuters objects to this Interrogatory as seeking information that is not relevant to any
28
      Case No. 3:21-cv-01418-EMC                  -1-        THOMSON REUTERS’ FIRST SUPPLEMENTAL
                                                            ANSWERS AND OBJECTIONS TO FIRST SET OF
                                                                                 INTERROGATORIES
     Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 4 of 7




 1   party’s claim or defense such that this request is unduly burdensome and not proportional to the

 2   needs of the case. To the extent this Interrogatory seeks revenue broken down based on each and

 3   every “means” by which CLEAR generates revenue, Thomson Reuters objects to this

 4   Interrogatory as seeking information that is not relevant to any party’s claim or defense such that

 5   this request is unduly burdensome and not proportional to the needs of the case.

 6          Should Plaintiffs continue to seek additional financial data, Thomson Reuters invites

 7   Plaintiffs to meet and confer on that subject.

 8   FIRST SUPPLEMENTAL ANSWER TO INTERROGATORY NO. 16:

 9          Thomson Reuters maintains its previously asserted answers and objections to Plaintiff’s

10   First Set of Interrogatories and to Interrogatory No. 16.

11          Thomson Reuters adds to those answers and objections that it does not charge a fee for the

12   dissemination of information about people; rather, it charges for use of its research platform,

13   CLEAR. Some customers pay a flat subscription fee for use of CLEAR without any limit to the

14   number of search queries they may perform. Other customers pay a flat subscription fee in return

15   for the ability to conduct up to a maximum number of search queries. Thomson Reuters refers to

16   the revenue attributed to these customers’ subscription fees as “recurring” revenue. Other

17   customers (including customers that exceed their maximum number of queries) pay for each

18   search query they conduct within CLEAR. Thomson Reuters refers to the revenue attributed to

19   such fees as “transactional” revenue. Some customers pay for some features on a “recurring”

20   basis and other features on a “transactional” basis.

21   ///

22   ///

23   ///

24   ///

25   ///

26   ///

27   ///

28
      Case No. 3:21-cv-01418-EMC                      -2-    THOMSON REUTERS’ FIRST SUPPLEMENTAL
                                                            ANSWERS AND OBJECTIONS TO FIRST SET OF
                                                                                 INTERROGATORIES
Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 5 of 7
Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 6 of 7
     Case 3:21-cv-01418-EMC Document 148-13 Filed 12/14/22 Page 7 of 7




 1                                         PROOF OF SERVICE
 2            I, Anna Mouw Thompson, declare:
 3            I am a citizen of the United States and employed in Seattle, Washington. I am over the age
 4   of eighteen years and not a party to the within-entitled action. My business address is 1201 Third
 5   Avenue, Ste. 4900, Seattle, WA 98110. On May 24, 2022, I served a copy of the within
 6   document(s):
 7            DEFENDANT THOMSON REUTERS CORPORATION’S FIRST
              SUPPLEMENTAL ANSWERS AND OBJECTIONS TO PLAINTIFFS’
 8            FIRST SET OF INTERROGATORIES TO DEFENDANT
 9                   by transmitting via my e-mail address (AnnaThompson@perkinscoie.com) the
10
                    document listed above to the persons at the e-mail addresses set forth below.

11    Andre M. Mura
      David Stein
12    Mark Troutman
      Jeffrey B. Kosbie
13    Ezekiel S. Wald
      GIBBS LAW GROUP LLP
14    505 14th Street, Suite 1110
      Oakland, CA 94612
15    amm@classlawgroup.com
      ds@classlawgroup.com
16    mht@classlawgroup.com
      jbk@classlawgroup.com
17    zsw@classlawgroup.com
      service@classlawgroup.com
18

19
              I declare under penalty of perjury under the laws of the United States of America that the
20
     above is true and correct.
21
              Executed on May 24, 2022, at Bainbridge Island, WA.
22

23

24                                                               Anna Mouw Thompson

25

26

27

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      Case No. 3:21-cv-01418-EMC                   -1-                                PROOF OF SERVICE
     156972347.2

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