Dunstan et al v. comScore, Inc.

Filing 108

RESPONSE by comScore, Inc. to MOTION by Plaintiffs Jeff Dunstan, Mike Harris to compel comScore to Respond to Written Discovery 104 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Bowland, Robyn)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of similarly
CASE NO. 1:11-cv-5807
situated individuals
Judge Holderman
Plaintiff,
Magistrate Judge Kim
v.
COMSCORE, INC., a Delaware corporation
Defendant.

COMSCORE'S RESPONSE TO PLAINTIFFS' MOTION TO COMPEL COMSCORE,
INC. TO RESPOND TO PLAINTIFFS' WRITTEN DISCOVERY
Defendant comScore, Inc. ("comScore") respectfully submits this brief in response to
Plaintiffs Mike Harris' and Jeff Dunstan's ("Plaintiffs") Motion to Compel comScore, Inc. to
Respond to Plaintiffs' Written Discovery. (Dkt. No. 104) Plaintiffs' motion should be denied
because comScore has fully responded to Plaintiffs' relevant written discovery, Plaintiffs seek
documents and information not within the custody or control of comScore, and comScore
produced documents as they are maintained in the usual course of business in accordance with
Fed. R. Civ. P. 34.
I.

INTRODUCTION
Plaintiffs ask this Court to order comScore to produce irrelevant information and

documents, information and documents that it does not possess, and a “cheat sheet” to guide its
review of documents produced by comScore in response to Plaintiffs’ own document requests.
In so doing, Plaintiffs mischaracterize comScore’s production and ignore their own proposed
class definitions. They also seek to get “blood from a stone” by requesting information that

comScore has already informed Plaintiffs it does not have. The Court should reject Plaintiffs’
arguments and deny their motion to compel.
II.

LEGAL STANDARDS
In accordance with Rule 26(b)(1), "[p]arties may obtain discovery regarding any

nonprivileged matter that is relevant to any party's claim or defense . . . ." Fed. R. Civ. P.
26(b)(1). Notably, however, the Court must limit discovery where "the burden or expense of the
proposed discovery outweighs its likely benefit, considering the needs of the case, the amount in
controversy, the parties' resources, the importance of the issues at stake in the action, and the
importance of the discovery in resolving the issues." Fed. R. Civ. P. 26(b)(2)(C)(iii). Moreover,
parties are not entitled to discovery that is nothing more than a fishing expedition. Strait v.
Mehlenbacher, 526 F.Supp. 581, 584 (W.D.N.Y. 1981) (stating that using the discovery rules as
"fishing expedition" to attempt to find a basis for a claim is plainly in violation of the Federal
Rules).
In its Memorandum Opinion and Order issued March 2, 2012, the Court bifurcated class
certification discovery and merits discovery, ordering the parties to conduct class certification
discovery first. (Dkt. No. 88) Thus, the only relevant issues to be resolved at this stage of the
litigation are those listed in Rule 23—whether:
(1) the class is so numerous that joinder of all members is impracticable; (2) there
are questions of law or fact common to the class; (3) the claims or defenses of the
representative parties are typical of the claims or defenses of the class; and (4) the
representative parties will fairly and adequately protect the interests of the class.
Fed. R. Civ. P. 23(a).
Rule 34 governs the production and inspection of documents and things. In accordance
with Rule 34, a producing party must "produce documents as they are kept in the usual course of

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business or must organize and label them to correspond to the categories in the request. . . ."
Fed. R. Civ. P. 34(b)(2)(E)(i).
If the producing party produces documents in the order in which they are kept in
the usual course of business, the Rule imposes no duty to organize and label the
documents, provide an index of the documents produced, or correlate the
documents to the particular request to which they are responsive.
MGP Ingredients, Inc. v. Mars, Inc., Case No. 06-2318, 2007 WL 3010343 at *3 (D. Kan. Oct.
15, 2007) (documents produced in the same order and grouping in which they were collected
were produced in the usual course of business); see also Morgan v. City of New York, Case No.
00Civ.9172, 2002 WL 1808233 at *4 (S.D.N.Y. Aug. 6, 2002) (production of documents
grouped in the readily identifiable categories in which they were kept in the usual course of
business fulfilled the requirements of Rule 34). Finally, a responding party is only required to
produce documents within its possession, custody, or control. Fed. R. Civ. P. 34(a)(1); see also
Am. Maplan Corp. v. Heilmayr, 203 F.R.D. 499, 501-502 (D. Kan. 2001) (a party has actual
possession, custody, or control under Rule 34 if it has actual possession, custody or control or the
legal right to obtain the documents on demand).
III.

ARGUMENT
Plaintiffs alternatively complain about being provided too little information and too many

documents. However, as discussed below, Plaintiffs have received the discovery to which they
are entitled. Plaintiffs are not permitted to embark on a fishing expedition, force comScore to
create information and/or documents it does not possess, and lessen their burden in reviewing
documents by improperly expanding the production requirements of Rule 34.
A. The Court Should Not Compel Production of Panelist Complaints Regarding
comScore's Software because They Are Not Relevant to Class Certification
Plaintiffs' discovery requests regarding panelist complaints are irrelevant to the issue of
class certification in light of the classes proposed by the Plaintiffs. Plaintiffs ask comScore to
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"IDENTIFY the total number of complaints YOU received about YOUR PANELIST
SOFTWARE (broken down by year)" and produce "ALL complaints about PANELIST
SOFTWARE." (Ex. A, Plaintiff Mike Harris' First Set of Interrogatories to Defendant
comScore, Inc., Interrogatory No. 8; Ex. B, Plaintiff Mike Harris' First Set of Requests for the
Production of Documents to Defendant comScore, Inc., Request No. 34.) Plaintiffs seek to
certify the following two classes in this action:
"The Surveillance Software Class: All individuals and entities in the United States that
have had comScore's Surveillance Software installed on their computer(s).
The Dunstan Subclass: All individuals and entities in the United States that have
incurred costs in removing the Surveillance Software."
(Dkt. No. 1 at ¶ 74.)
Plaintiffs' proposed classes are not composed of panelists who complained about
comScore's software. Rather, they are directed to all panelists who downloaded comScore's
software on their computers and individuals who, instead of removing comScore's software
through the obvious means of using the uninstall function, incurred costs to remove comScore's
software. Plaintiffs' proposed classes are not dependent on a malfunction of comScore's software
or even a panelist’s unhappiness with comScore's software—Plaintiffs allege that comScore's
functioning software is the culprit. comScore has already provided Plaintiffs with the total
number of machines actively reporting data and the total number of installations of comScore's
software. (Ex. C, Defendant comScore, Inc.'s First Supplemental Responses to Plaintiff Harris'
First Set of Interrogatories, Response to Interrogatory No. 7.) Moreover, there is no accurate
way to determine how many panelists uninstalled comScore's software by a method other than
the provided uninstall feature. (Ex. D, Declaration of Brown at ¶ 3.)

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Plaintiffs contend that the complaints they seek are directly relevant to numerosity,
typicality, and commonality because they "would potentially show: how many consumers were
adversely affected by comScore's software, the common ways in which consumers were affected,
and whether the named representatives' experiences are typical of other putative class members."
(Dkt. No. 104 at 7.) These arguments are unpersuasive. The number of consumers "adversely"
affected by comScore's software is not relevant because Plaintiffs allege the class consists of all
individuals who downloaded comScore's software. The "common ways in which consumers
were affected" is irrelevant for the same reason. Finally, complaints regarding comScore's
software are not likely to show whether the named representatives' experiences were typical of
all individuals who downloaded comScore's software. Presumably those panelists who were
pleased with their experiences with comScore's software would not complain to comScore about
the software. Plaintiffs seek nothing more than to improperly tilt the playing field in their favor
by only considering individuals unhappy with comScore's software in their typicality analysis.
Plaintiffs also assert that panelists' complaints "may identify subclasses among the
consumers affected by comScore's software." (Dkt. No. 104 at 7.) That statement suggests that
what Plaintiffs actually want is to embark on a fishing expedition designed to identify additional
class representatives. Notably, the case Plaintiffs cite for the proposition that such discovery is
acceptable fails to support this proposition. In United Nat'l Records, Inc. v. MCA, Inc., the court
denied the Defendants' motion to vacate an already-granted motion to certify the class based on
the potential for additional discovery to identify additional subclasses. United Nat'l Records,
Inc. v. MCA, Inc., 101 F.R.D. 323, 326 (N.D. Ill. 1984). In other words, identification of
additional subclasses was not required for class certification. So too here.

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Finally, as discussed by comScore's counsel at the April 17, 2012 hearing before the
Court, comScore does not maintain separate files for panelist complaints. All communications
from panelists would have to be reviewed, and a determination of what constitutes a “complaint”
would require burdensome and sometimes difficult review. (Ex. E, April 17, 2012 Transcript at
6:8-23; Ex. D, Declaration of Brown at ¶ 4.)1 Thus, even if the Court were to find panelists’
complaints to be remotely relevant, the Court should not order production of the complaints
under Fed. R. Civ. P. 26(b)(2)(C)(iii) because the burden to comScore greatly outweighs any
potential relevance to this matter.
B. comScore Has Fully Responded to Interrogatory Nos. 16 and 17
Plaintiffs seek additional information in response to Interrogatory Nos. 16 and 17.
Interrogatory No. 16 requests information regarding the "type of information that YOUR
WINDOWS SOFTWARE monitors, collects, retains, and/or transmits from PC PANELISTS."
(Ex. A, Plaintiff Mike Harris' First Set of Interrogatories to Defendant comScore, Inc.,
Interrogatory No. 16.) Interrogatory No. 17 requests the same information with respect to
"YOUR MACINTOSH SOFTWARE" and "MAC PANELISTS." (Ex. A, Plaintiff Mike Harris'
First Set of Interrogatories to Defendant comScore, Inc., Interrogatory No. 17.) Plaintiffs
acknowledge that comScore attached a business document pursuant to Fed. R. Civ. P. 33(d) in
response to Interrogatory No. 16. (Dkt. No. 104 at 8.) This document, comScore's official list of
the online activity information collected by the comScore software, lists the elements of online
activity information collected and provides a short description of each element. (Ex. D,
Declaration of Brown at ¶ 5.) Thus, examination of this business record and comScore's source
1

Plaintiffs' motion suggests that comScore's counsel has been less than forthright about
its refusal to produce panelists' complaints. However, as can be seen from the April 17, 2012
transcript, comScore's counsel fully explained the situation to the Court. (Ex. E, April 17, 2012
Transcript at 5:15-7:10.)

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code provides all of the information necessary to form a full and complete response to
Interrogatory No. 16.
Plaintiffs complain that comScore failed to respond fully with respect to previous
information collected, citing the "Legacy" fields noted in the attached business document.2
However, as previously explained to Plaintiffs, comScore does not maintain a list of "Legacy"
data fields, nor can comScore easily compile such a list. (Ex. F, April 27, 2012 Email from
Bowland to Balabanian; Ex. D, Declaration of Brown at ¶¶ 7-8.) In order to provide the
information Plaintiffs seek, comScore would have to engage several of its employees in a needlein-a-haystack search through old source code and other related documentation in an attempt to
find the previous descriptions of the "Legacy" fields. (Ex. D, Declaration of Brown at ¶ 8.)
Such an investigation is not guaranteed to result in identification of all Legacy fields, nor is it
likely to be completely accurate. (Ex. D, Declaration of Brown at ¶ 8.) comScore is not required
to create documents and cannot provide Plaintiffs with information it does not have—no matter
how many times Plaintiff requests it.
Additionally, Plaintiffs complain that comScore failed to respond fully to Interrogatory
No. 17 by referring to the business document produced in response to Interrogatory No. 16.
However, as previously relayed to Plaintiffs, comScore does not currently collect information
regarding Mac panelists. (Ex. F, April 27, 2012 Email from Bowland to Balabanian.) The
"beta" Macintosh software previously employed by comScore was designed to collect the
information listed in the business record provided by comScore. (Ex. F, April 27, 2012 Email

2

When comScore, for any reason, decides to no longer collect a certain piece of
information from its panelists but wishes to maintain the placeholder for compatibility purposes,
it zeros out the value of the information and changes the description of the information to
"Legacy field." (Ex. D, Declaration of Brown at ¶ 6.)

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from Bowland to Balabanian.)3 The Mac software was not commercially implemented, and
there is no separate list of data collected by Mac software. (Ex. D, Declaration of Brown at ¶ 5.)
Once again, comScore has provided Plaintiffs all of the information it has regarding this
Interrogatory. It cannot provide more; the Court should deny Plaintiffs' motion to compel.
C. comScore Has Also Fully Responded to Interrogatory No. 13
Plaintiffs also complain that comScore has not fully responded to Interrogatory No. 13 on
the basis of comScore's supposed failure to provide screenshots of all of the dialog boxes used by
all of comScore's third party partners at any point in time. However, Interrogatory No. 13 does
not request this information. Interrogatory No. 13 asks comScore to "IDENTIFY and
DESCRIBE the different ways in which YOU obtain consent from YOUR PANELISTS to
install the PANELIST SOFTWARE." (Ex. A, Plaintiff Mike Harris' First Set of Interrogatories
to Defendant comScore, Inc., Interrogatory No. 13.) In comScore's supplemental response to
this Interrogatory, comScore provided nearly two pages of written response describing how
comScore obtains consent from prospective panelists, as well as screenshots comScore collected
from each of its active third party U.S. partners on or around October 2011 as examples of the
dialog boxes shown to prospective panelists. (Ex. C, Defendant comScore, Inc.'s First
Supplemental Responses to Plaintiff Harris' First Set of Interrogatories, Response to
Interrogatory No. 13.) Each and every one of these screenshots were included as part of Exhibit

3

Upon further investigation while preparing this motion, comScore determined that the
only the information listed under the following headers in the business record were collected by
the beta Macintosh software, although the software was designed to eventually collect all of the
information in the business record: (1) DB Source 8 (ci=1): Basic Content Information; (2) DB
Source 6 (ci=3): Application Usage Data; (3) DB Source 4 (ci=4): AOL Proprietary & IM Event
Logging ContentID; (4) DB Source 5 (ci=6): Secure ContentID; (5) DB Sources 3 & 7 (ci=7):
Non-Secure Web Traffic; (6) DB Source 13 (ci=8): Snippet Data; and (7) DB Source 15 (ci=10):
Biometrics Data. comScore will supplement its response to Interrogatory No. 17 to clarify this
issue no later than May 24, 2012.

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A to comScore's Supplemental Interrogatory Responses. (Ex. D, Declaration of Brown at ¶ 10.)
comScore has provided all of the information it has—Plaintiffs are not entitled to more.4
In addition, the Court should reject Plaintiffs' improper attempt to expand Interrogatory
No. 13 beyond the specific request. Plaintiffs make the bold claim that comScore "must disclose
those third-party partners whose dialog boxes were not produced." (Dkt. No. 104 at 11.)
However, Plaintiffs did not request this information as part of Interrogatory No. 13. If Plaintiffs
desire the names of third-party partners whose dialog boxes were not produced, they should
serve an additional Interrogatory directed to this information rather than attempt to circumvent
the limits on the number of Interrogatories allocated to Plaintiffs in this action.5
D. Plaintiffs Mischaracterize comScore's Production and Misstate the Law in an
Improper Attempt to Have comScore Review the Documents Requested by
Plaintiffs for Plaintiffs
Plaintiffs' motion is replete with incorrect statements regarding comScore's production.
First, comScore produced a combination of .tif files and native files. (Ex. G, Declaration of
Bowland at ¶ 4.) Native files were produced only when producing .tif files was unfeasible due to
the length of the native files. (Ex. G, Declaration of Bowland at ¶ 4.) comScore did not, as
Plaintiffs claim, reproduce any documents produced as .tifs as native files. (Ex. G, Declaration
of Bowland at ¶ 5.) Rather, the .tif files labeled "unsupported file type" that Plaintiffs complain
about are placeholder documents for the native files. (Ex. G, Declaration of Bowland at ¶ 5.)
Contrary to Plaintiffs' claims, the .tif files were produced in an electronically searchable format
and with metadata. (Ex. G, Declaration of Bowland at ¶ 6.) Specifically, comScore produced
4

Plaintiffs do not complain that comScore's written response is deficient, only that
comScore failed to provide documents it does not possess in response to Interrogatory No. 13.
5

Plaintiffs claim that comScore represented it has all of the documents maintained by its
third party partners is unsupported and untrue. Although comScore maintains all of the
information relevant to class certification in one form or another, it obviously does not maintain
the exact same information as all of its third party vendors.

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the following metadata for each file (if available): Custodian, Recordtype, SourceApp, BegDoc,
EndDoc, Attachment Folder Name, Filename, Docext, DateCreated (MMDDYYYY),
DateLastMod (MMDDYYY). (Ex. G, Declaration of Bowland at ¶ 7.) Such information
provides the custodian of the document, the source application from which the document was
collected, the date the document was created, and the attachment folder name, among other
things. To be charitable, it appears that Plaintiffs do not understand the technical details
surrounding comScore's production. Although this may explain their misguided insistence that
comScore did not produce documents as maintained in the usual course of business, it does not
explain why Plaintiffs failed to raise these issues with comScore during any of the parties' meet
and confers or in response to comScore's offer to help Plaintiffs with technical difficulties
contained in the letter producing the documents in question. (Ex. H, April 13, 2012 Letter from
Bowland to Scharg.)
Turning to the issue at hand, Plaintiffs contend that comScore failed to produce
documents in accordance with Rule 34. That is incorrect: comScore produced documents as they
are maintained in the usual course of comScore's business. The majority of comScore's
production (and therefore, the majority of documents Plaintiffs complain about) is comprised of
documents pulled from the JIRA database comScore uses to manage software development and
trouble-shooting. (Ex. G, Declaration of Bowland at ¶ 8.) Because the tickets are stored in
database form, the user at comScore views data pulled from the database in an organized and
readable form. However, without the JIRA software, the data stored in the database would be
unorganized and difficult to understand.6 (Ex. G, Declaration of Bowland at ¶ 9.) Thus, in order

6

In order to view the JIRA tickets and attachments produced in the form Plaintiffs
request, Plaintiffs’ counsel must have the same JIRA and database software configured in the
same way as comScore’s software. (Ex. G, Declaration of Bowland at ¶ 9.) This would require
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to produce documents from the JIRA database in a reasonably useable format, comScore
provided each ticket as a comScore user would view the ticket on his or her computer as well as
the corresponding attachments to the ticket. Notably, comScore did not reorder the tickets or
attachments or otherwise deliberately mix critical documents with others in the hope of
obscuring the significance of the critical documents, activities which Fed. R. Civ. P. 34 was
designed to prevent. See Renda Marine, Inc. v. United States, 58 Fed. Cl. 57, 63 (Fed. Cl. 2003)
(citing the 1980 Advisory Committee Note to Rule 34(b)).7 Each attachment is associated with a
folder named for the ticket to which the attachment corresponds. (Ex. G, Declaration of
Bowland at ¶ 10.) Documents produced in the order they are kept are deemed produced in the
usual course of business under Rule 34, and the rule imposes no obligation on the producing
party to organize and label the documents. In re GI-Holdings Inc., 218 F.R.D. 428, 439 (D.N.J.
2003). The receiving party’s need for organization due to the sheer volume of documents
produced does not require the producing party to index or label documents produced as kept in
the usual course of business. GI-Holdings Inc., 218 F.R.D. at 440; Renda, 58 Fed. Cl. at 64.
Because comScore produced all of its documents grouped and ordered in the way the documents
are maintained and were collected, they were produced as kept in the usual course under Rule 34,
and comScore is not obligated to identify the Document Requests to which each document is
responsive.
licenses to both commercially-available pieces of software as well as significant Information
Technology assistance. comScore sees no need to burden the parties with such difficulties when
the same information is available in a complete and easily producible and reviewable format
such as the one provided Plaintiffs.
7

Plaintiffs seemingly complain that comScore has produced too many documents
responsive to Plaintiffs’ requests. However, each of the documents produced are relevant to one
of Plaintiffs’ extremely broad requests. Plaintiffs requested the documents; it cannot now
complain that it received too many in response to its requests and force comScore to provide an
index based on the volume of documents alone. See GI-Holdings Inc., 218 F.R.D. at 440;
Renda, 58 Fed. Cl. at 64.

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Plaintiffs broadly claim that the conversion of electronic files into .tif files, the format
most documents are currently produced in, “essentially creates new documents.” (Dkt. No. 104
at 13.) But the case Plaintiffs cite for this claim base the “new documents” reasoning on several
factors not applicable here, namely that the .tif files did not contain the same information as the
original documents and did not include metadata necessary to determine what files were
attachments, where files started and stopped, and when the documents were created, among
others. Hagenbuch v. 3B6 Sistemi Elettronici Industriali S.R.L., Case No. 04 C 3109, 2006 WL
665005 at *2 (N.D. Ill. March 8, 2006) (“The parties do not dispute that the TIFF documents
differ in design and content from the materials Plaintiff designated, are not identical to the
documents shown to Plaintiff, and contain less information (especially about the documents
themselves) than the originals.”). In contrast, comScore has produced .tif documents with
metadata and has not altered the documents other than to add Bates labels to each image and
redact privileged information. (Ex. G, Declaration of Bowland at ¶ 14.) Notably, the
Hagenbuch court suggested that protection of privileged or confidential information is a
legitimate reason for producing .tifs rather than native files. Hagenbuch, 2006 WL 665005 at *2
(noting that “[the producing party] does not suggest that the changes were made to protect
confidential or privileged information. . .”). In contrast, production of documents as .tif files was
required to allow comScore to redact privileged information. (Ex. G, Declaration of Bowland at
¶ 12.)
All of the other cases cited by Plaintiffs deal with documents produced out of storage
rather than documents produced in the usual course of business, failure to follow a court order
requiring an index, or failure to allow inspection of documents as required by Rule 34. See
Hagemeyer N. Am., Inc. v. Gateway Data Sci. Corp., 222 F.R.D. 594, 598 (E.D. Wis. 2004)

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(holding documents clearly labeled and organized in storage, and produced as such, were
produced as kept in the usual course of business); In re Sulfuric Acid Antitrust Litig., 231 F.R.D.
351, 358 (N.D. Ill. 2005) (documents stored for seven years in Toronto); Alford v. Aaron Rents,
Inc., Case No. 08-cv-683, 2010 WL 2720798 at *3 (S.D. Ill. July 8, 2010) (requiring producing
party to state whether documents were produced from a storage facility, which would require an
index under Rule 34, or were produced from active files, in which case they were produced as
kept in the usual course of business and did not require an index); City of Wichita v. Aero
Holdings, Inc., Case No. 98-1360, 2000 WL 1480499 at *1 n.2 (D. Kan. May 23, 2000) (failure
to provide an index where the court directed the parties to provide an index before production
occurred); Stiller v. Arnold, 167 F.R.D. 68, 70-71 (N.D. Ind. 1996) (refusing to allow inspection
of documents before requesting party copied the documents). comScore did not produce any
documents maintained in a storage facility; indeed, all of the documents produced by comScore
were collected from comScore’s company servers. (Ex. D, Declaration of Brown at ¶ 11; Ex. G,
Declaration of Bowland at ¶ 3.) Moreover, the parties were not ordered to produce an index with
their documents.
comScore produced documents in the groupings and order in which they were collected
from comScore’s active company servers. Documents produced as .tif files in comScore’s
production are electronically searchable and contain all relevant metadata. Additionally, some
documents produced as .tif files include redactions for privilege that could not be performed on a
native database file. Thus, comScore produced its documents as kept in the usual course of
business, and the production of .tif files does not change this fact. The Court should not grant
Plaintiffs’ motion seeking to reduce their document review burden by forcing comScore to
review its documents for Plaintiffs.

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IV.

CONCLUSION
For the foregoing reasons, comScore respectfully requests that the Court deny Plaintiffs'

Motion to Compel comScore, Inc. to Respond to Plaintiff's Written Discovery.

DATED: May 18, 2012

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

_/s/ Andrew H. Schapiro____
Andrew H. Schapiro
[e-mail]
Stephen Swedlow
[e-mail]
Amanda Williamson
[e-mail]
Robyn Bowland
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
Telephone: [phone]
Facsimile: [phone]
Paul F. Stack
[e-mail]
Mark William Wallin
[e-mail]
Stack & O'Connor Chartered
140 South Dearborn Street
Suite 411
Chicago, IL 60603
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant comScore, Inc.

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CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of COMSCORE'S
RESPONSE TO PLAINTIFFS' MOTION TO COMPEL COMSCORE, INC. TO
RESPOND TO PLAINTIFFS' WRITTEN DISCOVERY has been caused to be served on
May 18, 2012 to all counsel of record via the Court's ECF filing system.
_/s/ Robyn Bowland____
Robyn Bowland

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