Court filing
Proposed Order — Brooks v. Thomson Reuters Corporation (Dkt. 174.1)
No. 3:21-cv-01418-EMC · Doc. 174-1 · Docket on CourtListener
Full text
Case 3:21-cv-01418-EMC Document 174-1 Filed 03/16/23 Page 1 of 4
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
3 NMenaldo@perkinscoie.com 3150 Porter Drive
Erin K. Earl, pro hac vice Palo Alto, CA 94304-1212
4 EEarl@perkinscoie.com Telephone: 650.838.4300
Anna M. Thompson, pro hac vice Facsimile: 650.838.4350
5 AnnaThompson@perkinscoie.com
PERKINS COIE LLP Hayden M. Schottlaender, pro hac vice
6 1201 Third Avenue, Suite 4900 HSchottlaender@perkinscoie.com
7 Seattle, WA 98101-3099 PERKINS COIE LLP
Telephone: 206.359.8000 500 N. Akard Street, Suite 3300
8 Facsimile: 206.359.9000 Dallas, TX 75201-3347
Telephone: 214.965.7700
9 Attorneys for Defendant Facsimile: 214.965.7799
Thomson Reuters Corporation
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11 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
12 SAN FRANCISCO DIVISION
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14 CAT BROOKS and RASHEED Case No. 3:21-cv-01418-EMC
SHABAZZ, individually and on behalf of
15 all others similarly situated, [PROPOSED] ORDER GRANTING
ADMINISTRATIVE MOTION TO FILE
16 Plaintiffs, UNDER SEAL CONFIDENTIAL
INFORMATION REGARDING
17 v. THOMSON REUTERS’ OBJECTION TO
NEW REPLY EVIDENCE
18 THOMSON REUTERS CORPORATION,
19 Defendant.
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Case No. 3:21-cv-01418-EMC [PROPOSED] ORDER
Case 3:21-cv-01418-EMC Document 174-1 Filed 03/16/23 Page 2 of 4
1 [PROPOSED] ORDER
2 The Court, having considered Thomson Reuters’ Administrative Motion to File Under
3 Seal Confidential Information (“Sealing Motion”), and all supporting materials thereto, including
4 the Third Sealing Declaration of Kevin Appold, Doc.173-2, (“Third Sealing Declaration); the
5 Stipulated Protective Order entered in this action, Doc. 70; and all pleadings and papers on file
6 hereby finds that good cause and compelling reasons exist to seal:
7 The following portions of Thomson Reuters’ Objection to New Reply Evidence:
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Cite Portion(s) to Seal
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Objection to Reply Page 1, line 6 (after “includes allegations about CLEAR having” and
10 (1:6) before cite to footnote 3)
11 Objection to Reply Page 1, line 9 (after “TR objects to Plaintiffs’ new argument and
12 (1:9) evidence about” and before “under Local”)
13 Objection to Reply Page 1, line 11 (after “further objects that” and before “is irrelevant
(1:11) to Plaintiffs’ case or to class certification and is”)
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Objection to Reply Page 1, line 14 (beginning of line and before “or anything of the
15 (1:14) sort.”)
16 Objection to Reply Page 1, line 18 (after “had “no knowledge one way or the other”
(1:18) whether” and before “was ever indexed in CLEAR.”)
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Objection to Reply Page 1, line 19 (after “And, in fact,” and before “was never made
18 (1:19) available to any CLEAR”)
19 Objection to Reply Page 2, line 7 (after “for at least a limited time, CLEAR had” and
(2:7) before “–which includes potentially”)
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Objection to Reply Page 2, line 7 (after “–which includes potentially” to end of line 7)
21 (2:7)
22 Objection to Reply Page 2, line 8 (after “and” and before “information that cannot be
23 (2:8) accessed through normal internet channels.”)
24 Objection to Reply Page 2, line 11 (after “The phrase” and before “does not appear once
(2:11) in either Plaintiffs’ Complaint or their”)
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Objection to Reply Page 2, lines 23-24 (FN 5: after “TR never discusses” and before “in
26 (2:23-24) its opposition because”)
27 Objection to Reply Page 2, line 24 (FN 5: after “in its opposition because” and before
(2:24) “was never offered through CLEAR and has never”)
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Case No. 3:21-cv-01418-EMC -2- [PROPOSED] ORDER
Case 3:21-cv-01418-EMC Document 174-1 Filed 03/16/23 Page 3 of 4
1
Cite Portion(s) to Seal
2
Objection to Reply Page 2, lines 24.5-25 (after “Nor can Plaintiffs claim that the concept
3 (2:24.5 - 25) of” and before “is new to them and that they could not have
discovered the issue sooner.”)
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Objection to Reply Page 2, line 25.5 (after “to TR’s consideration of” and before
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(2:25.5) “functionality (including those that were presented to Mr.”)
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Objection to Reply Page 3, line 3 (after “references to and arguments about” and before
7 (3:3) “under Local Rule 7-3(d)(1).”)
8 Objection to Reply Page 3, line 7 (after “Because anything regarding” and before “is
(3:7) new”)
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Objection to Reply Page 3, line 9 (after “TR also objects that the new evidence
10 (3:9) regarding” and before “is irrelevant.”)
11 Objection to Reply Page 3, line 19 (beginning of line and before “has no connection to
(3:19) this litigation.”)
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Objection to Reply Page 3, line 21 (after “what types of” and before “may be at issue,
13 (3:21) what”)
14 Objection to Reply Page 3, line 21 (after “may be at issue, what” and before “even is,
(3:21) why TR explored”)
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Objection to Reply Page 4, line 6 (after “customers” and before “See, e.g., Doc. 169-4,
16 (4:6) 258:4-13.”)
17 Objection to Reply Page 4, line 7 (after “CLEAR does not include” and before
18 (4:7) “currently, Doc 169-4, 268:17-23;”)
19 Objection to Reply Page 4, line 9 (after “CLEAR, id. at 262:5-263:8; and he had “no
(4:9) knowledge” whether” and before “was ever made”)
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Objection to Reply Page 4, line 12 (after “never made” and before “available to
21 (4:12) customers.”)
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Case No. 3:21-cv-01418-EMC -3- [PROPOSED] ORDER
Case 3:21-cv-01418-EMC Document 174-1 Filed 03/16/23 Page 4 of 4
1 IT IS SO ORDERED.
2
3 DATED: ____________________ __________________________________
Judge: Hon. Edward M. Chen
4 United States District Judge
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6 Submitted by:
7 PERKINS COIE LLP
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9 By: /s/ Anna Mouw Thompson
Anna Mouw Thompson
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Attorneys for Defendant
11 Thomson Reuters Corporation
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Case No. 3:21-cv-01418-EMC -4- [PROPOSED] ORDER
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