Dunstan et al v. comScore, Inc.

Filing 255

DECLARATION of Robyn Bowland regarding response in opposition to motion 254 (Attachments: # 1 Exhibit A, # 2 Exhibit B (filed under seal), # 3 Exhibit C, # 4 Exhibit D)(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

CASENO.l:ll-cv-5807

Plaintiff,

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.

On Oct. 22, 2013 comScore produced an Excel spreadsheet in native format Bates

labeled CS0096515 and titled "CS0096515 _Confidential-Attorney's Eyes Only" to Plaintiffs.

3.

A true and correct copy of excerpts from a November 1, 2013 letter sent to Rafey

Balabanian, counsel for Plaintiffs, is attached as Exhibit A to this Declaration. Portions of
Exhibit A not relevant to the Plaintiff Jeff Dunstan's Renewed Motion to Compel comScore, Inc.
to Respond to Plaintiffs' Written Discovery (Dkt. No. 247) have been redacted.

99999.77815/5189084.1

4.

A true and correct copy of a document Bates labeled CSOO 16810, produced by

comScore on April13, 2012 and marked "Confidential," is attached as Exhibit B to this
Declaration.
5.

A true and correct copy of the Google Search Engine Optimization Starter Guide,

available at available at http://static.googleusercontent.com/extemal_content/
untrusted_ dlcp/www. google. corn/en/us/webmasters/docs/ search-engine-optimization-starterguide.pdf, which I accessed Nov. 6, 2013, is attached as Exhibit C to this Declaration.
6.

A true and correct copy of an October 3, 2013 letter sent to Rafey Balabanian,

counsel for Plaintiffs, is attached as Exhibit D to this Declaration.
7.

I hereby declare under the penalty of perjury that all statements made herein are

true and correct.

Executed this 6th ofNovember, 2013.

Robyn M. Bowland
Attorney for comScore, Inc .

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