State of Washington, et al v. Donald J. Trump, et al

Filing 118

Filed (ECF) joinder letter in lieu of amicus brief pursuant to Circuit Advisory Committee Note to Rule 29-1. Filed by TECHNOLOGY AND OTHER START-UPS AMICI, joining in brief(s) [19]. Date of service: 02/02/2017. [10306139] [17-35105] (Calafiore Healy, Valeria) [Entered: 02/07/2017 03:01 PM]

UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
No: 17-35105

STATE OF WASHINGTON, et al.

D.C. No. 2:17-cv-00141-JLR
Western District of Washington

Plaintiffs-Appellees,
v.
DONALD J. TRUMP, President of the
United States, et al, Defendant-Appellants

TECHNOLOGY START-UPS AMICI JOINDER
IN PROPOSED AMICI CURIAE BRIEF
FILED BY THE TECHNOLOGY COMPANIES
The technology and other start-up entities listed below (the “Start-Ups
Amici”) respectfully join as supplemental Amici in the Amici Curiae Brief filed by
the Technology Companies and Other Businesses at Docket 19-1 in support of
Appellees:
• Alta Plana Corporation
• Amitree Inc.
• Bright Idea Energy Solutions Inc.
• Cognitive Computing Consortium
• iCouldBe.Org Inc.
1

• Indico Inc.
• JP Linguistics Inc.
• Lending Robot Inc.
• Loop AI Labs Inc.
• The Kitchens Inc., DBA Forkable
• The Social Edge Inc.
• TwoToTango Inc.
• Unitive Inc.
• Vital AI LLC
Start-up companies contribute substantially to this country’s economic
prosperity and growth potential and for reasons similar to those already set forth by
the Technology Companies in their Amici Brief, start-ups are especially affected by
the immigration order at issue. Many start-up companies are founded by, and rely
heavily on the hard work of immigrants. Orders of the type at issue here cause
immediate harm to technology companies, their employees and their families, and
the competitiveness of the United States in the global market for innovation. In
many instances, the technological innovation driven by U.S. start-ups contributes
not only to the national prosperity but also to the national security. Implementation
of the immigration order at issue thus has the potential to harm the country’s
security as well as its prosperity. Accordingly, the Start-Ups Amici join the
2

Technology Companies Amici in their Brief filed in support of Appellees in the
above captioned proceeding and respectfully urge this Court to uphold Judge
Robart’s ruling.
Pursuant to 26.1(a) and 29(a)(4)(A), the Start-Ups Amici respectfully
provide their corporate disclosure statement in the attached Exhibit 1.

Respectfully submitted,
February 7, 2017

By:

/s/ Valeria Calafiore Healy
Valeria Calafiore Healy, Esq.
HEALY LLC
154 Grand Street
New York, New York 10013
Telephone: [phone]
Facsimile: [phone]
On behalf of the Start-Ups Amici
Curiae.

3

EXHIBIT 1
CORPORATE DISCLOSURE OF TECHNOLOGY AND OTHER STARTUPS AMICI
1.

Alta Plana Corporation has no parent corporation and no
publicly held corporation owns 10% or more of its stock.

2.

Amitree Inc. has no parent corporation and no publicly held
corporation owns 10% or more of its stock.
Bright Idea Energy Solutions Inc. has no parent corporation and
no publicly held corporation owns 10% or more of its stock.
Cognitive Computing Consortium has no parent corporation
and no publicly held corporation owns 10% or more of its
stock.
iCouldBe.Org, Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
Indico Inc. has no parent corporation and no publicly held
corporation owns 10% or more of its stock.
JP Linguistics Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
Lending Robot Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
Loop AI Labs Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
The Kitchens Inc, DBA Forkable, has no parent corporation
and no publicly held corporation owns 10% or more of its
stock.
The Social Edge Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
TwoToTango Inc. has no parent corporation and no publicly
held corporation owns 10% or more of its stock.
Unitive Inc. has no parent corporation and no publicly held
corporation owns 10% or more of its stock.

3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.

Vital AI LLC has no parent corporation and no publicly held
corporation owns 10% or more of its stock.

CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing with the Clerk of the
Court for the United States Court of Appeals for the Ninth Circuit by using the
appellate CM/ECF system on February 7, 2017. Participants in the case who are
registered CM/ECF users will be served by the appellate CM/ECF system.

January 7, 2017

By: /s/ Valeria Calafiore Healy____
Valeria Calafiore Healy, Esq.
HEALY LLC
On behalf of Start-Ups
Amici.