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MOTION to Exclude Testimony of Professor Joseph Turow (Dkt. 124-07)… — Brooks v. Thomson Reuters Corporation (Dkt. 198)
Summary
Document 198, filed 04/11/23 in Case 3:21-cv-01418-EMC (Brooks v. Thomson Reuters Corporation, N.D. Cal.), is Defendant Thomson Reuters' Motion to Exclude Testimony of Joseph Turow, filed by Perkins Coie LLP with an April 20, 2023 hearing date before Hon. Edward M. Chen. The notice asks for an order excluding Turow's testimony, including the report filed as Doc. 124-07. The table of contents shows three arguments. The first is that his opinion that all Californians suffered uniform harm to their ethical and social rights is ipse dixit philosophizing. The second is that, if he is offered as a consumer preferences expert, he fails to show that the surveys he cites are reliable or support his conclusion. The third is that any opinion that consumers' legal rights were violated is an inadmissible legal conclusion.
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Cite this document
“MOTION to Exclude Testimony of Professor Joseph Turow (Dkt. 124-07)… — Brooks v. Thomson Reuters Corporation (Dkt. 198).”
Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 198. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2023-04-20-gov-uscourts-cand-374304-198-0-gov-uscourts-cand-374304-198-0/
, SHA-256 ad1badf24c5414774543b8b9e78b92c608b4a6c11800c4d31efb07935a9d098d.Full text
Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 1 of 13
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
4 EEarl@perkinscoie.com Telephone: 650.838.4300
Anna M. Thompson, pro hac vice Facsimile: 650.838.4350
5 AnnaThompson@perkinscoie.com
Tyler S. Roberts, pro hac vice Hayden M. Schottlaender, pro hac vice
6 TRoberts@perkinscoie.com HSchottlaender@perkinscoie.com
PERKINS COIE LLP PERKINS COIE LLP
7
1201 Third Avenue, Suite 4900 500 N. Akard Street, Suite 3300
8 Seattle, WA 98101-3099 Dallas, TX 75201-3347
Telephone: 206.359.8000 Telephone: 214.965.7700
9 Facsimile: 206.359.9000 Facsimile: 214.965.7799
10 Attorneys for Defendant
11 Thomson Reuters Corporation
12
13 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
14 SAN FRANCISCO DIVISION
15 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC
individually and on behalf of all others
16 similarly situated, DEFENDANT THOMSON REUTERS’
MOTION TO EXCLUDE TESTIMONY
17
Plaintiffs, OF JOSEPH TUROW
18
v.
19 Date: April 20, 2023
THOMSON REUTERS CORPORATION, Time: 9:00 a.m.
20 Place: Courtroom 5, 17th Floor
Defendant. Judge: Hon. Edward M. Chen
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1 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that on April 20, 2023 at 9:00 a.m., or as soon thereafter as this
3 Motion may be heard in this Court, Defendant Thomson Reuters Corporation (“TR”), by and
4 through its counsel of record, will and hereby does move the Court for an order excluding the
5 testimony of Joseph Turow, including the report filed as Doc. 124-07. This Motion is based on
6 this Notice, the following Memorandum of Points and Authorities, the pleadings and papers on
7 file in this action, any arguments and evidence to be presented at hearing, and any other matters
8 that may properly come before the Court.
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1 TABLE OF CONTENTS
2 Page
3 I. STATEMENT OF ISSUE .................................................................................................... 1
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II. INTRODUCTION ............................................................................................................... 1
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III. PROF. TUROW’S OPINION & TESTIMONY .................................................................. 1
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IV. LEGAL STANDARD .......................................................................................................... 3
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V. ARGUMENT ....................................................................................................................... 4
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A. Prof. Turow’s opinion that all Californians have suffered uniform
9 harm to their ethical and social rights is nothing more than ipse dixit
philosophizing. ......................................................................................................... 4
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B. If Prof. Turow is being offered as an expert in consumer
11 preferences, he fails to articulate how consumer preference affects
his opinion, nor how the consumer surveys he cites are reliable or
12 supportive of his conclusion. ................................................................................... 5
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C. If Prof. Turow is instead offering a conclusion about whether
14 consumers’ legal rights have been violated, such opinion ought to
be excluded as a legal conclusion. ........................................................................... 7
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VI. CONCLUSION .................................................................................................................... 8
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1 TABLE OF AUTHORITIES
2 Page(s)
3 CASES
4 Andrews v. County of Orange,
5 2021 WL 6496831 (C.D. Cal. July 27, 2021) ........................................................................... 7
6 Brown v. Google, LLC,
2022 WL 17961497 (N.D. Cal. Dec. 12, 2022) ........................................................................ 4
7
Cahen v. Toyota Motor Corp.,
8 147 F. Supp. 3d 955 (N.D. Cal 2015) ....................................................................................... 8
9 Claar v. Burlington N. R.R. Co.,
29 F.3d 499 (9th Cir. 1994)....................................................................................................... 4
10
11 Daubert v. Merrell Dow Pharms., Inc.,
43 F.3d 1311 (9th Cir. 1995)................................................................................................. 1, 4
12
Domingo ex rel. Domingo v. T.K.,
13 289 F.3d 600 (9th Cir. 2002)............................................................................................. 1, 4, 5
14 Ellis v. Costco Wholesale Corp.,
657 F.3d 970 (9th Cir. 2011)..................................................................................................... 3
15
16 F.T.C. v. Com. Planet, Inc.,
642 F. App’x 680 (9th Cir. 2016) ............................................................................................. 5
17
Godinez v. Huerta,
18 2018 WL 2018048 (S.D. Cal. May 1, 2018) ............................................................................. 7
19 Gong v. Jones,
2008 WL 4183937 (N.D. Cal. Sept. 9, 2008) ........................................................................... 7
20
In re iPhone Application Litig.,
21
2011 WL 4403963, at *5 (N.D. Cal. Sept. 20, 2011)), aff'd, 717 F. App'x 720
22 (9th Cir. 2017) ........................................................................................................................... 8
23 Lust ex rel. Lust v. Merrell Dow Pharms., Inc.,
89 F.3d 594 (9th Cir. 1996)....................................................................................................... 3
24
TransUnion LLC v. Ramirez,
25 141 S. Ct. 2190 (2021) .............................................................................................................. 8
26 United States v. Tamman,
27 782 F.3d 543 (9th Cir. 2015)..................................................................................................... 7
28
Case No. 3:21-cv-01418-EMC ii DEFENDANT THOMSON REUTERS’ MOTION TO
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1 OTHER AUTHORITIES
2 Federal Rule of Evidence 702 ..................................................................................................... 1, 3
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Case No. 3:21-cv-01418-EMC iii DEFENDANT THOMSON REUTERS’ MOTION TO
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Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 6 of 13
1 I. STATEMENT OF ISSUE
2 Whether the testimony and report of Joseph Turow should be excluded under Federal Rule
3 of Evidence 702.
4 II. INTRODUCTION
5 Professor Turow’s opinion1 that CLEAR generates an abstract privacy harm should be
6 excluded because it is based on nothing more than his personal belief (or, in his words, his
7 “sense”). His report is not supported by any objective or verifiable evidence or methodology.
8 Where “[p]ersonal opinion, not science, is testifying . . . [that] testimony is inadmissible as a
9 matter of law under Rule 702.” Daubert v. Merrell Dow Pharms., Inc., 43 F.3d 1311, 1319 (9th
10 Cir. 1995) (cleaned up).
11 To the extent Prof. Turow attempts to support his editorial scholarship by reference to
12 “consumer perceptions,” he has never articulated how those perceptions affect his opinion at all
13 (i.e., whether a consumer’s own preferences with respect to privacy tradeoffs affect the
14 uniformity of his perceived “harm”). But, even if that explanation comes in response to this
15 Motion, it would not matter. Each of the surveys that Prof. Turow cites in his report is either
16 irrelevant to this case, or directly supports TR’s position that there is a significant lack of
17 commonality among putative class members regarding their preferences for CLEAR and its many
18 socially-beneficial uses. As a result, Prof. Turow cannot “set forth the steps used to reach the
19 conclusion that the research is applicable” and his report ought to be excluded. Domingo ex rel.
20 Domingo v. T.K., 289 F.3d 600, 606 (9th Cir. 2002).
21 Finally, to the extent that Prof. Turow opines on CLEAR’s encroachment on any legal
22 privacy right, that opinion should be excluded as legal opinion beyond the scope of expert
23 testimony.
24 III. PROF. TUROW’S OPINION & TESTIMONY
25 Prof. Turow offers the opinion that “Thomson Reuters’ operation of the CLEAR product
26 affects privacy interests of Californians–the right to control personal information and to be let
27
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28 Report of Prof. Turow, Doc. 124-07 (“Turow Rep.”).
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Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 7 of 13
1 alone–in such a way that all Californians whose information is accessible through CLEAR are
2 harmed.” Turow Rep. at 5. He claims that those rights are violated “at the point at which
3 Thomson Reuters aggregates or collects . . . people’s data,” Declaration of Hayden Schottlaender,
4 Ex. 4, Deposition of Joseph Turow (“Turow Dep.”), at 167:19-168:4, and “regardless of who sees
5 that information.” Id. at 327:1-6. He has no opinion about whether those harms may differ among
6 Californians. Id. at 188:5-12.
7 By “right to control,” Prof. Turow means “the right to decide whether a company should
8 even have [certain] information.” Id. at 196:1-3. Prof. Turow concedes that “many Americans …
9 have already . . . lost the ability to control their information.” Id. at 70:22-71:5. Notwithstanding,
10 Prof. Turow claims that the right involves “ensuring individuals are not blindsided by the
11 unknown and unwanted collection and use of information about themselves.” Turow Rep. at 15.
12 Prof. Turow opines that TR violates that right because “the general public does not know about
13 CLEAR.” Id. at 15-16. And he bases that conclusion solely on: (1) the fact that he was
14 “personally . . . unaware of CLEAR;” and (2) a deposition of a TR employee, where that
15 employee “came close” to saying that “he doesn’t know that any marketing materials are . . .
16 presented to the public about . . . Thomson Reuters.” Turow Dep. at 334:8-335:8.
17 Prof. Turow describes the right “to be let alone” as “a corollary of the right to control
18 one’s information. So they come together.” Id. at 99:15-17. He also defines it as “the right to not
19 be worried that companies could use data to create trouble for that person or to create
20 discriminatory activities for that person.” Id. at 212:5-12. He believes that that right extends to a
21 “right not to be chosen by particular agencies for investigation because of certain information that
22 got out that might not even be accurate and that CLEAR makes no pretension to accuracy.” Id. at
23 212:22-213:10. But, when asked whether he was suggesting that criminals have a right to not be
24 investigated, Prof. Turow reversed course and explained that the right to be let alone applies
25 “within a marketing context.” Id. at 215:2-6, 215:16-19. Prof. Turow concedes that CLEAR
26 “cannot be used for” marketing or advertising, id. at 295:10-13, and CLEAR is in fact not used
27 for marketing purposes. Doc. 152, ¶ 11.
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1 Prof. Turow describes both the right to “control” and the right to “be let alone” as “ethical
2 and social” rights. Turow Dep., at 174:18-175:2; 212:2-4. And he states that he is “offering
3 opinion in this case regarding consumer perceptions.” Id. at 119:3-10. But Prof. Turow did not
4 conduct any survey in connection with this case because “it is so clear what CLEAR is doing that
5 the harm of – the privacy harms that it is creating among Californians is – is not at issue here in
6 my mind.” Id. at 72:4-19. Instead, he relied on a handful of pre-existing surveys having nothing to
7 do with CLEAR or any platform even similar to CLEAR. Id. at 71:8-16; see also infra, Part
8 IV.B.
9 Because Prof. Turow conducted no surveys, he has “no idea” whether there might be any
10 Californians who would not object to their information being in CLEAR. Id. at 153:5-8. Instead,
11 Turow formed his opinions based on his own “sense . . . that if you told people what – what is in
12 my report, they would freak out.” Id. at 152:20-153:4. That “sense” was derived from “read[ing]
13 material that was provided to [him] about CLEAR including promotional materials by CLEAR
14 . . . [and] “depositions that described some of CLEAR’s activities.” Id. at 27:8-14.
15 IV. LEGAL STANDARD
16 “It is the proponent of the expert who has the burden of proving admissibility.” Lust ex
17 rel. Lust v. Merrell Dow Pharms., Inc., 89 F.3d 594, 598 (9th Cir. 1996). Expert testimony should
18 only be admitted if “(a) the expert’s scientific, technical, or other specialized knowledge will help
19 the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is
20 based on sufficient facts or data; (c) the testimony is the product of reliable principles and
21 methods; and (d) the expert has reliably applied the principles and methods to the facts of the
22 case.” Fed. R. Evid. 702. In evaluating a motion to strike expert testimony offered to support a
23 motion for class certification, “the trial court must act as a ‘gatekeeper’ to exclude junk science
24 that does not meet Federal Rule of Evidence 702’s reliability standards by making a preliminary
25 determination that the expert’s testimony is reliable.” Ellis v. Costco Wholesale Corp., 657 F.3d
26 970, 982 (9th Cir. 2011) (citation omitted). “Thus, an expert’s inference or assertion must be
27 derived by the scientific method to be admissible.” Id. (cleaned up).
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1 V. ARGUMENT
2 Prof. Turow’s opinion should be excluded as personal opinion unsupported by verifiable
3 evidence or any science whatsoever. His attempts to connect that personal opinion to consumer
4 perception are equally unexplained and unavailing. Consumer preference does not impact his
5 opinion about uniform privacy harms whatsoever and does not even support that opinion. Finally,
6 to the extent Prof. Turow’s opinion touches on any legal privacy right, it should be excluded as
7 legal opinion beyond the permissible scope of expert testimony.
8 A. Prof. Turow’s opinion that all Californians have suffered uniform harm to
their ethical and social rights is nothing more than ipse dixit philosophizing.
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10 As described above, Prof. Turow opines that everyone has “ethical and social rights” to
11 control their information and to be let alone. And he “conclude[s], based on a review and
12 understanding of privacy scholarship, and . . . case materials, that Thomson Reuters’ operation of
13 CLEAR interferes” with those rights. Turow Rep. at 5. But Prof. Turow lacks “objective,
14 verifiable evidence that [his] testimony is based on ‘scientifically valid principles.’” Daubert, 43
15 F.3d at 1317-18. Instead, he relied only on his “sense . . . that if you told people” about the
16 platform, “they would freak out[.]” Turow Dep. at 152:20-153:4. But an expert cannot “merely
17 impute his own opinions to those of a reasonable consumer.” Brown v. Google, LLC, 2022 WL
18 17961497, at *11 (N.D. Cal. Dec. 12, 2022) (excluding consumer expectation opinion where
19 expert opinions were “based on nothing more than his personal interpretation . . . and the idea that
20 such interpretations are reasonable.”). “Nothing in either Daubert or the Federal Rules of
21 Evidence requires a district court to admit opinion evidence that is connected to existing data only
22 by the ipse dixit of the expert.” Domingo, 289 F.3d at 607 (citation omitted). Thus, because Prof.
23 Turow’s sole opinion in this case espouses nothing more than “subjective beliefs or unsupported
24 speculation,” it is properly excluded under Daubert. Claar v. Burlington N. R.R. Co., 29 F.3d
25 499, 502 (9th Cir. 1994).
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1 B. If Prof. Turow is being offered as an expert in consumer preferences, he fails
to articulate how consumer preference affects his opinion, nor how the
2 consumer surveys he cites are reliable or supportive of his conclusion.
3 Despite claiming that he is “offering opinion in this case regarding consumer
4 perceptions,” (Turow Dep. at 119:3-10), Prof. Turow never explains how consumer preference
5 affects his legal opinion at all. To the contrary, he suggests that whether Californians “would
6 object to their information being in CLEAR” is not a point that would “affect [his] conclusion.”
7 Id. at 151:9-152:6.
8 But even if consumer preferences were somehow relevant to his opinion, Prof. Turow’s
9 testimony should still be excluded. First, he conducted no survey of consumer preferences
10 relating to CLEAR. Supra, Part II. Second, to the extent Prof. Turow relies on extrinsic evidence
11 to support his “sense” of consumer preferences, that extrinsic evidence is unreliable and fails to
12 support his own conclusion. If an expert relies on surveys conducted by others, the expert must
13 “demonstrate that the survey was conducted according to accepted principles.” F.T.C. v. Com.
14 Planet, Inc., 642 F. App’x 680, 682 (9th Cir. 2016) (cleaned up). And “while studies involving
15 similar but not identical situations may be helpful, an expert must set forth the steps used to reach
16 the conclusion that the research is applicable.” Domingo, 289 F.3d at 606. A trial court properly
17 excludes expert testimony where “there is simply too great an analytical gap between the data and
18 the opinion proffered.” Id. (citing Gen. Elec. Co. v. Joiner, 522 U.S. 136, 146 (1997)).
19 Here, there is an analytical chasm between Prof. Turow’s cited evidence and his opinion
20 regarding CLEAR. Prof. Turow’s evidence was expressly identified, collected, and analyzed in
21 significant detail in the Report of Dr. Ran Kivetz, Doc. 151-14, at 38 (“Kivetz Rep.”) (offering a
22 table and summary of Dr. Kivetz’s survey evidence).
23 The problems Dr. Kivetz identifies with the surveys relied upon by Prof. Turow include:
24 Prof. Turow’s 2015 working paper conducted a survey regarding what Americans
25 believe that marketers should be able to learn about them online. Id. at Part D.3.1. Again,
26 Prof. Turow is well aware that CLEAR is not used for marketing or by marketers. Turow
27 Dep. at 295:10-13.
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Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 11 of 13
1 The statistic that Prof. Turow pulls from the National Telecommunications and
2 Information Administration survey actually relates to consumer concerns with online
3 security risks, such as identity theft and credit card fraud. Those have nothing to do with
4 CLEAR (except to the extent CLEAR helps combat identity theft and fraud). Other
5 components of the survey actually contradict Prof. Turow’s opinion, as 77% of
6 participants disagreed that losing control of their personal data was a major concern to
7 them. Kivetz Rep., Part D.3.2.
8 The ValuePenguin survey is wholly unreliable because it lacks any information
9 about the survey questions, and the survey results are so vague that they could be
10 interpreted in a multitude of ways, depending on what is meant by “companies,” “use,”
11 “private information,” “selling,” and “personal information.” More, the actual statistics
12 offered by the ValuePenguin survey contradict Prof. Turow’s opinion; they show that a
13 minority of consumers are concerned with controlling information about them. Id. at Part
14 D.3.3.
15 The boyd and Marwick paper is a result of 58 interviews with teenagers, focusing
16 on social media privacy. That paper opines: “Privacy is a fraught concept, with no clear
17 agreed-upon definition . . . . How people conceptualize privacy and locate it in their life
18 varies wildly, highlighting that a universal notion of privacy remains enigmatic.” boyd,
19 danah and Alice Marwick (2011), “Social Privacy in Networked Publics: Teens’
20 Attitudes, Practices, and Strategies,” A Decade in Internet Time: Symposium on the
21 Dynamics of the Internet and Society, at 2-3. That paper supports TR’s position that
22 “Privacy must be contextualized” because it “varies by individual, by community, by
23 situation, by role, and by interaction. In other words, privacy–and the norms surrounding
24 privacy–cannot be divorced from context.” Id. at 12; see Kivetz Rep., at Part D.3.4.
25 The 2015 Pew Research Center survey asked vague and broad closed-ended
26 questions that could encompass “potentially infinite circumstances [that] likely yielded
27 idiosyncratic and varied interpretations across participants[.]” Kivetz Rep., ¶ 92. The
28 irrelevance of the responses to the instant case is demonstrated by focus group responses
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Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 12 of 13
1 relating to that survey, in which participants clarified that they had in mind “[e]xpansive
2 government data collection efforts” and “hackers” when discussing privacy concepts. Id.
3 at Part D.3.5.
4 The 2019 Pew Research Center survey reflected that respondents had wildly
5 differing definitions of privacy, with only 26% of participants mentioning “control over
6 information” as being a component of privacy. In fact, an even higher percentage of that
7 survey’s respondents had no answer for what “digital privacy” meant to them. And,
8 again, the results suggested that respondents would support CLEAR’s existence, insofar
9 as a majority of respondents to that survey indicated that they would be very or
10 somewhat comfortable with their data being used to “help improve [companies’] fraud
11 prevention systems.” And the same survey reflected that more respondents found it
12 “acceptable” than “not acceptable” for the government to collect data about “all
13 Americans to assess potential terrorist threats,” and for DNA testing companies to
14 “shar[e] customers’ genetic data with law enforcement to help solve crimes.” These
15 results support TR; respondents’ “openness to consider situations in which community or
16 societal benefits can outweigh the alleged harm of sharing personal data indicates that it
17 is not appropriate to assume classwide harm in the case of CLEAR . . . .” Id. at Part
18 D.3.6.
19 Because of the analytical gap between Prof. Turow’s cited evidence and his opinion that all
20 Californians suffer an identical privacy harm from CLEAR, the Court should exclude his report.
21 C. If Prof. Turow is instead offering a conclusion about whether consumers’
legal rights have been violated, such opinion ought to be excluded as a legal
22 conclusion.
23 “[A]n expert cannot testify to a matter of law amounting to a legal conclusion.” United
24 States v. Tamman, 782 F.3d 543, 552-53 (9th Cir. 2015) (citations omitted). Testimony about
25 whether a right has been violated is necessarily a legal opinion subject to exclusion. Gong v.
26 Jones, 2008 WL 4183937, at *4 (N.D. Cal. Sept. 9, 2008) (excluding testimony regarding
27 “whether any particular conduct violated any particular law or right”) (citation omitted); Godinez
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Case No. 3:21-cv-01418-EMC 7 DEFENDANT THOMSON REUTERS’ MOTION TO
EXCLUDE TESTIMONY OF PROF. TUROW
Case 3:21-cv-01418-EMC Document 198 Filed 04/11/23 Page 13 of 13
1 v. Huerta, 2018 WL 2018048, at *5 (S.D. Cal. May 1, 2018) (excluding opinion regarding
2 whether defendant “violated [a] clearly established legal right”); Andrews v. County of Orange,
3 2021 WL 6496831, at *1 (C.D. Cal. July 27, 2021) (“Whether or not [defendants] violated
4 [plaintiff’s] legal rights is an ultimate issue of law that is not appropriate subject for expert
5 testimony.”). As such, his testimony that CLEAR violates established privacy rights ought to be
6 excluded as legal opinion.
7 Even if Prof. Turow were entitled to render a legal opinion, his opinion would be
8 inadmissible because the Supreme Court has already rejected it. In TransUnion LLC v. Ramirez,
9 141 S. Ct. 2190 (2021), the Supreme Court held that, “the retention of information lawfully
10 obtained, without further disclosure” did not give rise to concrete harm necessary to confer
11 Article III standing. Id. at 2209 (cleaned up); see also Cahen v. Toyota Motor Corp., 147 F. Supp.
12 3d 955, 971 (N.D. Cal 2015) (“alleged collection and tracking of … personal information” held
13 insufficient to show harm or injury for Article III standing (citing In re iPhone Application Litig.,
14 2011 WL 4403963, at *5 (N.D. Cal. Sept. 20, 2011)), aff’d, 717 F. App’x 720 (9th Cir. 2017). Dr.
15 Turow’s opinion regarding the purported harm that Plaintiffs and putative class members suffered
16 is therefore inadmissible.
17 VI. Conclusion
18 For the foregoing reasons, the Court should strike the report of Prof. Turow.
19
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Dated: April 11, 2023 PERKINS COIE LLP
21
22
By: /s/ Hayden M. Schottlaender
23 Hayden M. Schottlaender
HSchottlaender@perkinscoie.com
24
Attorneys for Defendant Thomson Reuters
25
Corporation
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Case No. 3:21-cv-01418-EMC 8 DEFENDANT THOMSON REUTERS’ MOTION TO
EXCLUDE TESTIMONY OF PROF. TUROW
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