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

Filing 89

REPLY to opposition to motion re #69 MOTION for Summary Judgment and Opposition to Plaintiffs' Motion for Summary Judgment and Permanent Injunction, #60 MOTION for Summary Judgment Filed MOTION for Permanent Injunction (Plaintiffs' Reply in Further Support of Plaintiffs' Motion for Summary Judgment and Permanent Injunction and Opposition to Defendant's Motion for Summary Judgment) filed by AMERICAN EDUCATIONAL RESEARCH ASSOCIATION, INC., AMERICAN PSYCHOLOGICAL ASSOCIATION, INC., NATIONAL COUNCIL ON MEASUREMENT IN EDUCATION, INC.. (Attachments: #1 Plaintiffs' Statement of Material Facts in Opposition to Defendant's Motion for Summary Judgment, #2 Plaintiffs' Reply to Defendants' Statement of Disputed Facts, #3 Plaintiffs' Response to Defendant's Objections to Plaintiffs' Evidence, #4 Declaration of Nikia L. Gray, #5 Exhibit VVV, #6 Exhibit WWW, #7 Exhibit XXX, #8 Exhibit YYY, #9 Exhibit ZZZ, #10 Exhibit AAAA, #11 Exhibit BBBB, #12 Exhibit CCCC, #13 Exhibit DDDD, #14 Exhibit EEEE, #15 Exhibit FFFF, #16 Exhibit GGGG, #17 Exhibit HHHH, #18 Exhibit IIII, #19 Exhibit JJJJ, #20 Exhibit KKKK, #21 Exhibit LLLL, #22 Exhibit MMMM, #23 Exhibit NNNN, #24 Exhibit OOOO, #25 Exhibit PPPP, #26 Exhibit QQQQ, #27 Exhibit RRRR, #28 Exhibit SSSS, #29 Exhibit TTTT, #30 Exhibit UUUU, #31 Exhibit VVVV, #32 Exhibit WWWW, #33 Exhibit XXXX, #34 Exhibit YYYY, #35 Exhibit ZZZZ, #36 Exhibit AAAAA, #37 Exhibit BBBBB, #38 Exhibit CCCCC, #39 Exhibit DDDDD, #40 Exhibit EEEEE, #41 Exhibit FFFFF, #42 Exhibit GGGGG, #43 Exhibit HHHHH, #44 Exhibit IIIII, #45 Exhibit JJJJJ, #46 Exhibit KKKKK, #47 Exhibit LLLLL, #48 Exhibit MMMMM, #49 Exhibit NNNNN, #50 Exhibit OOOOO, #51 Exhibit PPPPP, #52 Exhibit QQQQQ, #53 Exhibit RRRRR, #54 Exhibit SSSSS, #55 Exhibit TTTTT, #56 Exhibit UUUUU, #57 Exhibit VVVVV, #58 Exhibit WWWWW, #59 Exhibit XXXXX, #60 Exhibit YYYYY, #61 Exhibit ZZZZZ, #62 Exhibit AAAAAA, #63 Declaration of Wayne Camara, #64 Plaintiffs' Objections to Defendant's Evidence, #65 Certificate of Service)(Hudis, Jonathan)

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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. ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 1:14-cv-00857-TSC CERTIFICATE OF SERVICE I hereby certify that on February 18, 2016 the accompanying: 1. PLAINTIFFS’ REPLY IN FURTHER SUPPORT OF PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND PERMANENT INUNCTION AND OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT; 2. DECLARATION OF NIKIA L. GRAY IN FURTHER SUPPORT OF PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND PERMANENT INJUNCTION AND OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND EXHIBITS VVV THROUGH EXHIBITS UUUUU, EXHIBIT WWWWW and EXHIBIT ZZZZZ; 3. REPLY DECLARATION OF WAYNE CAMARA IN FURTHER SUPPORT OF PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT AND PERMANENT INJUNCTION AND OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT ; 4. PLAINTIFFS’ OBJECTIONS TO DEFENDANT’S EVIDENCE IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY JUDGMENT; and 5. This CERTIFICATE OF SERVICE. were filed with the Court using the CM/ECF system. These documents also were served via email to: Andrew P. Bridges Sebastian E. Kaplan FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 abridges@fenwick.com skaplan@fenwick.com Matthew B. Becker FENWICK & WEST LLP 801 California Street Mountain View, CA 94041 Telephone: (650) 335-7930 mbecker@fenwick.com David Halperin 1530 P Street NW Washington, DC 20005 davidhalperindc@gmail.com Mitchell L. Stoltz Corynne McSherry ELECTRONIC FRONTIER FOUNDATION 815 Eddy Street San Francisco, CA 94109 mitch@eff.org corynne@eff.org Counsel for Defendant PUBLIC.RESOURCE.ORG, INC. Respectfully submitted, QUARLES & BRADY LLP Dated: February 18, 2016 By: /s/ Jonathan Hudis Jonathan Hudis (DC Bar # 418872) Nikia L. Gray (pro hac vice) Jonathan P. Labukas (DC Bar # 998662) 1700 K Street NW, Suite 825 Washington, DC 20006-3825 Tel. (202) 372-9600 Fax (202) 372-9599 E-Mail Jonathan.Hudis@quarles.com E-Mail Nikia.Gray@quarles.com E-Mail Jonathan.Labukas@quarles.com Counsel for Plaintiffs American Educational Research Association, Inc., American Psychological Association, Inc., and National Council on Measurement in Education, Inc. -2-

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