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)

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EXHIBIT W Robyn Bowland From: Sent: To: Cc: Subject: Attachments: Ben Thomassen [] Friday, September 21, 2012 4:30 PM Andy Schapiro; Robyn Bowland; Amanda Williamson; Stephen Swedlow; Paul Stack; Mark Wallin Rafey Balabanian; Jay Edelson; Ari Scharg; Chandler Givens Dunstan v. comScore (11-cv-05807) Harris-Dunstan 0632-0655.pdf Counsel: As I'm sure you've concluded by now, we decided not to amend the pleadings in this case. As we've made clear, however, Mr. Dunstan will not be seeking to certify the ICFA claim on behalf of the subclass. Since we've decided not to amend, and even though we believe you're not entitled to them and Mr. Dunstan continues to have significant privacy concerns, in the interest of moving this case forward on behalf of the class, he's decided to provide the entirety of his anti-virus logs to comScore in an effort to move this case forward on behalf of the class. We hope this avoids any further expenditure of resources on this issue, which thus far has been a complete waste. Please be advised that the produced documents (attached here) are marked "CONFIDENTIAL-ATTORNEYS' Eyes Only" pursuant to the Protective Order entered in this case. (Dkt. No. 72.) Please treat them accordingly. Thanks, Ben -Ben Thomassen | Edelson McGuire LLC 350 North LaSalle Street, Suite 1300 Chicago, Illinois 60654 1.312.572.7208 (direct) | 1.312.264.0351 (fax) | Please consider the environment before printing this e-mail CONFIDENTIALITY AND LIABILITY FOR MISUSE. The information contained in this communication is the property of Edelson McGuire, LLC. It is confidential, may be attorney work product, attorney-client privileged or otherwise exempt from disclosure under applicable law, and is intended only for the use of the addressee(s). Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited. If you have received this communication in error, please notify Edelson McGuire, LLC immediately by return e-mail and destroy this communication and all copies thereof, including all attachments. Pursuant to requirements related to practice before the U.S. Internal Revenue Service, any tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for purposes of (i) avoiding penalties imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing or recommending to another person any tax-related matter. 1

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