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)

EXHIBIT J

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of similarly
situated individuals,
Plaintiffs,
v.
COMSCORE, INC., a Delaware corporation,
Defendant.

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DEFENDANT COMSCORE, INC.'S FOURTH SUPPLEMENTAL RESPONSES
TO PLAINTIFF HARRIS' FIRST SET OF INTERROGATORIES

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure and the
Memorandum and Opinion Order granting bifurcation of discovery entered March 2, 2012
("Bifurcation Order"), Defendant comScore, Inc, ("comScore"), by its undersigned attorneys,
hereby submits the following supplemental objections and responses to Plaintiff Mike Harris'
("Harris") First Set of Interrogatories ("Interrogatories"), Nos. 2, 11, and 17. Pursuant to Federal
Rule of Civil Procedure 26(e), comScore reserves the right to supplement its responses to these
interrogatories if it learns of additional information.

04692.62386/4941422.1

unwritten policies regarding the manner in which comScore obtains consent from users. In
addition to the policies already outlined in comScore's previous Interrogatory Responses,
comScore requires prospective and current third party bundlers to comply with the requirements
outlined in the "comScore Software Distribution Program Software Bundle Guidelines. See
CS0016693, CS0016810.
See also comScore's Responses and Supplemental Responses to Interrogatory Nos. 12
and 13.
INTERROGATORY NO. 17:
IDENTIFY and DESCRIBE each type of information that YOUR MACINTOSH
SOFTWARE monitors, collects, retains, or transmits about MAC PANELISTS.
SUPPLEMENTAL RESPONSE TO INTERROGATORY NO. 17
To the best of comScore's knowledge, the data collected by the beta version of the
comScore Mac software was only shared with a AccuData, a third party matching vendor, on a
limited basis. To the best of comScore's knowledge, no data collected by the beta version of the
comScore Mac software was ever sold to a third party.

DATED: September 14, 2012

By /s/ Robyn Bowland
Andrew Schapiro
Email: [e-mail]
Stephen Swedlow
Email: [e-mail]
Robyn Bowland
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
500 West Madison Street, Suite 2450

04692.62386/4941422.1

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.

04692.62386/4941422.1