Filing 132

Unopposed MOTION for Leave to File AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANT by Sina Bahram (Pearlman, Jeffrey).

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA AMERICAN SOCIETY FOR TESTING AND MATERIALS d/b/a ASTM INTERNATIONAL; NATIONAL FIRE PROTECTION ASSOCIATION, INC.; and Case No. 1:13-cv-01215-TSC-DAR UNOPPOSED MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANT AMERICAN SOCIETY OF HEATING, REFRIGERATING, AND AIR CONDITIONING ENGINEERS, Action Filed: August 6, 2013 Plaintiffs-Counterdefendants, v. PUBLIC RESOURCE.ORG, INC., Defendant-Counterclaimant. Sina Bahram respectfully moves for leave to file an amicus curiae brief in support of Defendant in the above-captioned matter. Mr. Bahram is a digital accessibility researcher and advocate, chief technology officer and co-founder of the International Association of Visually Impaired Technologists (“IAVIT”). In addition to researching human computer interaction, intelligent user interfaces, and artificial intelligence with the goal of helping users with disabilities, Mr. Bahram advocates on behalf of disabled individuals and organizations representing their interests. Mr. Bahram has authored numerous publications advocating for technical solutions to accessibility challenges, see Sina Bahram, Publications, at, and has been honored by the White House as a “Champion of Change” for his accessibility work. See Matt Shipman, White House Honors Sina Bahram as a “Champion of Change,” CSC News (May 7, 2012), available at; White House, Champions of Change: Sina Bahram, at Additionally, Mr. Bahram serves on several boards of conferences and organizations related to accessibility and, through his consulting service, Prime Access Consulting, works with clients to achieve digital accessibility goals. See Sina Bahram, Consulting, at As a visually-impaired individual himself and in his capacity as an advocate for other disabled persons, Mr. Bahram has a substantial interest in this case, which is likely to have a profound effect on the ability of persons with disabilities to access, understand, and participate in the development of the law. Disabled individuals like Mr. Bahram and those for whom he advocates are acutely affected by changes in public safety or accessibility law—changes that may, as in this case, incorporate standards crafted by standards development organizations (“SDOs”). Defendant’s Statement of Material Facts (“SMF”) ¶¶ 13, 22. The issue has become even more pressing for advocates as the federal government encourages agencies to forego crafting standards themselves and incorporate those developed by SDOs. Id. ¶ 24. When SDOs erect technological barriers to accessing these standards, they prevent millions of disabled individuals from reading the laws that govern them. As an expert on, an advocate for, and a user of accessibility technologies, Mr. Bahram is particularly well-positioned to explain these problems and the potential impact of this case on disabled individuals. As recognized by other amici, this Court has allowed amicus curiae participation when the amicus “has unique information or perspective that can help the court beyond the help that the lawyers for the parties are able to provide.” Jin v. Ministry of State Sec., 557 F. Supp. 2d 131, 137 (D.D.C. 2008) (quoting Ryan v. Commodity Futures Trading Comm’n, 125 F.3d 1062, 1064 (7th Cir. 1997)); Cobell v. Norton, 246 F. Supp. 2d 59, 62 (D.D.C. 2003). Too often, the needs of disabled persons and the impact of laws on disabled persons are profoundly overlooked. In light of Mr. Bahram’s role as an advocate and expert on the technological needs of print and visually disabled persons, his unique perspective will help the Court understand the ways in which this case and its outcome will affect the ability of an important and vulnerable segment of the population to access the law and participate in its development. The Parties have agreed that they will not oppose any amicus filing in support of either side. See Joint Report on Proposed Summary Judgment Briefing Schedule at 14, Docket No. 114 (Oct. 30, 2015). All parties have also separately consented to the filing of the brief proposed by this motion.1 DATED: January 8, 2016 Respectfully Submitted, Jeffrey T. Pearlman CA Bar #254759 D.C. District Bar ID #CA00003 Phillip R. Malone (Admission Pending) Juelsgaard IP And Innovation Clinic Mills Legal Clinic at Stanford Law School 559 Nathan Abbott Way Stanford, CA 94305 Telephone: (650) 497-9443 Fax: (650) 723-4426 1 One or more additional parties may sign on to the brief before it is filed; Plaintiffs and Defendant were informed of this before consent was obtained.

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