Court filing
NOTICE by Software & Information Industry Association re 156 MOTION… — Brooks v. Thomson Reuters Corporation (Dkt. 162)
No. 3:21-cv-01418-EMC · Doc. 162 · Docket on CourtListener
Full text
Case 3:21-cv-01418-EMC Document 162 Filed 02/13/23 Page 1 of 3
1 Laura Sullivan (Cal. Bar No. 220529)
LAW OFFICE OF LAURA SULLIVAN
2 423 South Estate Drive
3 Orange, CA 92869
Telephone: 714-744-15220
4 Email: laurasullivan@laurasullivanlaw.com
5 Jennifer Sarvadi (D.C. Bar. No. 490475)
(pro hac vice application pending)
6 HUDSON COOK, LLP
1909 K Street NW, 4th Floor
7 Washington, DC 20006
Telephone: 202-715-2002
8 Email: jsarvadi@hudco.com
9 Attorneys for Proposed Amici,
10 The Software & Information Industry Association and
The Coalition for Sensible Public Record Access
11
12 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
13
SAN FRANCISCO DIVISION
14
CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC
15 individually and on behalf of all others
similarly situated, NOTICE OF MOTION FOR LEAVE TO
16 FILE PROPOSED AMICI CURIAE BRIEF
Plaintiffs, OF THE SOFTWARE & INFORMATION
17 INDUSTRY ASSOCIATION AND THE
v. COALITION FOR SENSIBLE PUBLIC
18
THOMSON REUTERS CORPORATION, RECORDS ACCESS IN SUPPORT OF
19 DEFENDANT
Defendant.
20 Judge: Hon. Edward M. Chen
Date: April 20, 2023
21 Time: 1:30 pm
Room: Courtroom 5, 17th Floor
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TO THE PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that on April 20, 2023 at 1:30 p.m., or as soon thereafter as the
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matter may be heard in Courtroom 5 of the United States District Court, Northern District of
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California, San Francisco Division, The Software & Information Industry Association (“SIIA”)
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NOTICE OF MOTION FOR LEAVE TO FILE PROPOSED AMICI CURIAE BRIEF OF THE SOFTWARE &
INFORMATION INDUSTRY ASSOCIATION AND THE COALITION FOR SENSIBLE PUBLIC RECORDS
ACCESS IN SUPPORT OF DEFENDANT
CASE NO. 3: 21-cv-01418-EMC
Case 3:21-cv-01418-EMC Document 162 Filed 02/13/23 Page 2 of 3
1 and Coalition for Sensible Public Records Access (“CSPRA”) will move this Court for leave to
2 file their proposed Amici Curiae Brief in support of Defendant Thomson Reuters Corporation’s
3 Opposition to Plaintiffs’ Motion for Class Certification. Proposed Amici’s motion is based on this
4 notice, the Motion for Leave to File Amici Curiae Brief in Support of Defendant and Proposed
5 Amici Curiae Brief filed on February 2, 2023 [ECF No. 156], and all documents on file in this
6 matter. Defendant consents to the filing of proposed Amici’s brief. Plaintiffs indicate they will
7 oppose. ECF No. 160.
8 Please note also that although Amici are prepared to argue this matter on the date noticed,
9 they have no objection should the Court choose to decide this matter on the papers.
10 STATEMENT OF INTEREST
11 1. The SIIA is a trade association for those in the business of information that represents
12 approximately 600 member companies, among them publishers of software and information
13 products, including databases, enterprise and consumer software, and other products that combine
14 information with digital technology.
15 2. SIIA member companies serve nearly every segment of society, including business,
16 education, government, healthcare, and consumers. SIIA is dedicated to creating a healthy
17 environment for the creation, dissemination, and productive use of information.
18 3. SIIA has an interest in this matter and qualifications to assist this Court as it considers
19 Plaintiffs’ motion because the availability of accurate public records is central to SIIA’s mission
20 and many of its members rely on access to public records. Moreover, Plaintiffs’ challenge to the
21 Defendant’s business model has implications for other SIIA members and their businesses.
22 4. CSPRA is a non‐profit organization dedicated to promoting the principle of open public
23 record access to ensure individuals, the press, advocates, and businesses the continued freedom to
24 collect and use the information made available in the public record for personal, governmental,
25 commercial, and societal benefit.
5.Members of CSPRA are among the many entities that comprise a vital link in the flow
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of information for these purposes and provide services that are widely used by constituents in
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NOTICE OF MOTION FOR LEAVE TO FILE PROPOSED AMICI CURIAE BRIEF OF THE SOFTWARE &
INFORMATION INDUSTRY ASSOCIATION AND THE COALITION FOR SENSIBLE PUBLIC RECORDS
ACCESS IN SUPPORT OF DEFENDANT
CASE NO. 3: 21-cv-01418-EMC
Case 3:21-cv-01418-EMC Document 162 Filed 02/13/23 Page 3 of 3
1 every state. Collectively, CSPRA members alone employ over 75,000 persons across the U.S.
2 The economic and societal activity that relies on entities such as CSPRA members is valued in
3 the trillions of dollars and employs millions of people.
4 6. CSPRA has an interest in this matter and qualifications to assist this Court as it
5 considers Plaintiffs’ motion because the availability of complete and accurate public records is
6 central to CSPRA’s belief that the economy and society depend on value-added information and
7 services that include public record data for many important aspects of our daily lives, and to
8 CSPRA’s work to protect those sensible uses of public records.
9 7. SIIA and CSPRA wish to be heard on this issue because consumers, law enforcement,
10 and a wide range of businesses rely on data that flows in and through Defendant’s CLEAR
11 product, and other similar products, to function and fulfill their every-day obligations. The brief
12 submitted by SIIA and CSPRA will assist this Court in its understanding of the CLEAR product
13 and the ways in which open access to public records benefits virtually every facet of society.
14 8. SIIA and CSPRA have read the parties’ briefs, and their proposed Amici brief is
15 necessary to fully and adequately address the issue of class certification.
16 Accordingly, SIIA and CSPRA request that they be granted permission to file their
17 proposed Amici brief. ECF No. 156.
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Dated: February 13, 2023 Respectfully submitted,
19
/s/ Laura Sullivan
20 _________________________________
21
Laura Sullivan
22
Attorney for Proposed Amici Curiae
23 The Software & Information Industry Association
and The Coalition for Sensible Public Records
24 Access
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NOTICE OF MOTION FOR LEAVE TO FILE PROPOSED AMICI CURIAE BRIEF OF THE SOFTWARE &
INFORMATION INDUSTRY ASSOCIATION AND THE COALITION FOR SENSIBLE PUBLIC RECORDS
ACCESS IN SUPPORT OF DEFENDANT
CASE NO. 3: 21-cv-01418-EMC
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