AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC. et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 60

MOTION for Summary Judgment Filed by AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC., AMERICAN PSYCHOLOGICAL ASSOCIATION, INC., NATIONAL COUNCIL ON MEASUREMENT IN EDUCATION, INC. (Attachments: #1 Statement of Facts Points of Authority, #2 Statement of Facts Statement of Undisputed Facts, #3 Declaration Declaration of Jonathan Hudis, #4 Exhibit Ex. A, #5 Exhibit Ex. B, #6 Exhibit Ex. C, #7 Exhibit Ex. D, #8 Exhibit Ex. E, #9 Exhibit Ex. F, #10 Exhibit Ex. G, #11 Exhibit Ex. H, #12 Exhibit Ex. I, #13 Exhibit Ex. J, #14 Exhibit Ex. K, #15 Exhibit Ex. L, #16 Exhibit Ex. M, #17 Exhibit Ex. N, #18 Exhibit Ex. O, #19 Exhibit Ex. P, #20 Exhibit Ex. Q, #21 Exhibit Ex. R, #22 Exhibit Ex. S, #23 Exhibit Ex. T, #24 Exhibit Ex. U, #25 Exhibit Ex. V-1, #26 Exhibit Ex. V-2, #27 Exhibit Ex. W, #28 Exhibit Ex. X, #29 Exhibit Ex. Y, #30 Exhibit Ex. Z, #31 Exhibit Ex. AA, #32 Exhibit Ex. BB, #33 Exhibit Ex. CC, #34 Exhibit Ex. DD, #35 Exhibit Ex. EE, #36 Exhibit Ex. FF-1, #37 Exhibit Ex. FF-2, #38 Exhibit Ex. FF-3, #39 Exhibit Ex. FF-4, #40 Exhibit Ex. FF-5, #41 Exhibit Ex. FF-6, #42 Exhibit Ex. GG, #43 Exhibit Ex. HH, #44 Exhibit Ex. II, #45 Exhibit Ex. JJ, #46 Exhibit Ex. KK, #47 Exhibit Ex. LL, #48 Exhibit Ex. MM, #49 Declaration Declaration of Marianne Ernesto, #50 Exhibit Ex. NN, #51 Exhibit Ex. OO, #52 Exhibit Ex. PP, #53 Exhibit Ex. QQ, #54 Exhibit Ex. RR, #55 Exhibit Ex. SS, #56 Exhibit Ex. TT, #57 Exhibit Ex. UU, #58 Exhibit Ex. VV, #59 Exhibit Ex. WW, #60 Exhibit Ex. XX, #61 Exhibit Ex. YY, #62 Exhibit Ex. ZZ, #63 Exhibit Ex. AAA, #64 Exhibit Ex. BBB, #65 Exhibit Ex. CCC, #66 Exhibit Ex. DDD, #67 Exhibit Ex. EEE, #68 Exhibit Ex. FFF, #69 Exhibit Ex. GGG, #70 Exhibit Ex. HHH, #71 Exhibit Ex. III, #72 Exhibit Ex. JJJ, #73 Declaration Declaration of Lauress Wise, #74 Exhibit Ex. KKK, #75 Exhibit Ex. LLL, #76 Declaration Declaration of Wayne Camara, #77 Exhibit Ex. MMM, #78 Declaration Declaration of Felice Levine, #79 Exhibit Ex. NNN, #80 Exhibit Ex. OOO (Public Version), #81 Exhibit Ex. PPP, #82 Exhibit Ex. QQQ, #83 Exhibit Ex. RRR, #84 Exhibit Ex. SSS, #85 Exhibit Ex. TTT-1, #86 Exhibit Ex. TTT-2, #87 Exhibit Ex. UUU, #88 Declaration Declaration of Kurt Geisinger, #89 Declaration Declaration of Dianne Schneider, #90 Text of Proposed Order Proposed Order, #91 Certificate of Service Certificate of Service)(Hudis, Jonathan). Added MOTION for Permanent Injunction on 12/22/2015 (td).

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN EDUCATIONAL RESEARCH
ASSOCIATION, INC., AMERICAN
PSYCHOLOGICAL ASSOCIATION, INC.,
and NATIONAL COUNCIL ON
MEASUREMENT IN EDUCATION, INC.,
Plaintiffs,
v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant.

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Civil Action No. 1:14-cv-00857-TSC-DAR
CERTIFICATE OF SERVICE

I hereby certify that on December 21, 2015 the accompanying:
1. PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A
PERMANENT INJUNCTION;
2. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A
PERMANENT INJUNCTION;
3. PLAINTIFFS’ STATEMENT OF MATERIAL FACTS IN SUPPORT OF THEIR
MOTION FOR SUMMARY JUDGMENT;
4. DECLARATION OF JONATHAN HUDIS IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibits);
5. DECLARATION OF MARIANNE ERNESTO IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibits);
6. DECLARATION OF LAURESS L. WISE IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibits);
7. DECLARATION OF WAYNE CAMARA IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibits);

8. DECLARATION OF FELICE J. LEVINE IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibits);
9. DECLARATION OF KURT F. GEISINGER IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION (with exhibit);
10. DECLARATION OF DIANNE L. SCHNEIDER IN SUPPORT OF PLAINTIFFS’
MOTION FOR SUMMARY JUDGMENT AND ENTRY OF A PERMANENT
INJUNCTION;
11. A [PROPOSED] ORDER AND ENTRY OF A PERMANENT INJUNCTION; and
12. This CERTIFICATE OF SERVICE
were filed with the Court using the CM/ECF system that sent notice of the filing of these
documents to all counsel of record, and was also served via e-mail to:
Andrew P. Bridges
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
[e-mail]
Matthew B. Becker
FENWICK & WEST LLP
801 California Street
Mountain View, CA 94041
Telephone: [phone]
[e-mail]
David Halperin
1530 P Street NW
Washington, DC 20005
[e-mail]
Mitchell L. Stoltz
Corynne McSherry
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
[e-mail]
[e-mail]
Counsel for Defendant
PUBLIC.RESOURCE.ORG, INC.

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Respectfully submitted,
QUARLES & BRADY LLP

Dated: December 21, 2015

By:

/s/ Jonathan Hudis
Jonathan Hudis (DC Bar # 418872)
1700 K Street NW, Suite 825
Washington, DC 20006-3825
Tel. [phone]
Fax [phone]
E-Mail [e-mail]
Kathleen Cooney-Porter (DC Bar # 434526)
OBLON, McCLELLAND, MAIER &
NEUSTADT, LLP
1940 Duke Street
Alexandria, VA 22314
Tel. [phone]
Fax [phone]
E-Mail [e-mail]

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