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 W

Robyn Bowland
From:
Sent:
To:
Cc:
Subject:
Attachments:

Ben Thomassen [[e-mail]]
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
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