Dunstan et al v. comScore, Inc.

Filing 176

DECLARATION of Robyn Bowland regarding memorandum in opposition to motion 175 (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, # 9 Exhibit I, # 10 Errata J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(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 situated individuals

CASE NO. 1:11-cv-5807

Plaintiff,

Chief Judge Holderman

v.

Magistrate Judge Kim

COMSCORE, INC., a Delaware corporation
Defendant.

DECLARATION OF ROBYN BOWLAND
I, Robyn Bowland, hereby declare and state based upon my personal knowledge
as follows:
1.

I am an attorney at the law firm of Quinn Emanuel Urquhart & Sullivan LLP. I

am admitted to practice law in the state of Illinois and represent comScore, Inc. (“comScore”) in
the above-titled action. This declaration is based on my personal knowledge, except where
expressly noted otherwise.
2.

A true and correct copy of a website entitled “comScore Fact Sheet – comScore,

Inc.” available at http:www.comscore.com/About_comScore/comScore_Fact_Sheet, accessed on
February 25, 2013, is attached as Exhibit A to this Declaration.
3.

A true and correct copy of the Expert Witness Report of Colin O’Malley, dated

November 30, 2012, is attached as Exhibit B to this Declaration.
4.

A true and correct copy of excepts of the deposition transcript of Michael Brown,

dated August 15, 2012, is attached as Exhibit C to this Declaration.

99999.77815/5189084.1

5.

A true and correct copy of the Expert Witness Report of Roberto Tamassia, dated

November 30, 2012, is attached as Exhibit D to this Declaration.
6.

A true and correct copy of CS0016873, an Excel spreadsheet produced by

comScore in this case, is attached as Exhibit E to this Declaration.
7.

A true and correct copy of excerpts of the deposition transcript of Colin

O’Malley, dated December 13, 2012, is attached as Exhibit F to this Declaration.
8.

A true and correct copy of excepts of the deposition transcript of Roberto

Tamassia, dated December 14, 2012, is attached as Exhibit G to this Declaration.
9.

A true and correct copy of comScore’s Second Supplemental Responses to

Plaintiff Harris’s First Set of Interrogatories, dated May 24, 2012, is attached as Exhibit H to this
Declaration.
10.

A true and correct copy of excerpts of comScore’s Responses to Plaintiff Harris’s

First Set of Interrogatories, dated March 23, 2012, is attached as Exhibit I to this Declaration.
11.

A true and correct copy of comScore’s Fourth Supplemental Responses to

Plaintiff Harris’s First Set of Interrogatories, dated September 14, 2012, is attached as Exhibit J
to this Declaration.
12.

A true and correct copy of excerpts of the deposition transcript of Don Waldhalm,

dated October 25, 2012, is attached as Exhibit K to this Declaration.
13.

A true and correct copy of excerpts of the deposition transcript of Yvonne Bigbee,

dated September 12, 2012, is attached as Exhibit L to this Declaration.
14.

A true and correct copy of excerpts of the deposition transcript of Randall L.

McCaskill, dated September 14, 2012, is attached as Exhibit M to this Declaration.

2

15.

A true and correct copy of excerpts of the deposition transcript of Michiko A.

Chand, dated September 13, 2012, is attached as Exhibit N to this Declaration.
16.

A true and correct copy of excerpts of Plaintiff Mike Harris’s Responses to

Defendant comScore’s First Set of Interrogatories, dated April 9, 2012, is attached as Exhibit O
to this Declaration.
17.

A true and correct copy of excerpts of the deposition transcript of Michael J.

Harris, dated July 13, 2012, is attached as Exhibit P to this Declaration.
18.

A true and correct copy of Exhibit 6 used during the deposition of Michael J.

Harris on July 13, 2012, is attached as Exhibit Q to this Declaration.
19.

A true and correct copy of the Declaration of Michael Brown, dated February 26,

2013, is attached as Exhibit R to this Declaration.
20.

A true and correct copy of excerpts of Plaintiff Jeff Dunstan’s Responses to

Defendant comScore’s First Set of Interrogatories, dated April 9, 2012, is attached as Exhibit S
to this Declaration.
21.

A true and correct copy of excerpts of Plaintiff Jeff Dunstan’s First Supplemental

Responses to Defendant comScore’s First Set of Interrogatories is attached as Exhibit T to this
Declaration.
22.

A true and correct copy of Harris-Dunstan 0632-0655, an anti-virus log produced

by Plaintiff Jeff Dunstan in this case, is attached as Exhibit U to this Declaration.
23.

A true and correct copy of excerpts of the deposition transcript of Jeffrey

Dunstan, deposed August 8, 2012, is attached as Exhibit V to this Declaration.

3