Dunstan et al v. comScore, Inc.
Filing
269
DECLARATION of Chandler Givens regarding motion for protective order 268 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Thomassen, Benjamin)
EXHIBIT B
Amir Missaghi
Fwd: Dunstan et al. v. comScore, Inc., Case No. 1:11cv5807
Chandler Givens
To: Amir Missaghi
Wed, Nov 6, 2013 at 11:10 AM
Forwarded message
From: Robyn Bowland
Date: Wed, Nov 6, 2013 at 11:00 AM
Subject: Dunstan et al. v. comScore, Inc., Case No. 1:11cv5807
To: Chandler Givens
Cc: Rafey Balabanian , Jay Edelson , Ben Thomassen
, Ari Scharg , David Mindell , Andy
Schapiro , Stephen Swedlow , Paul
Stack
Chandler,
I write to followup on our meet and confer yesterday regarding the files comScore’s expert retrieved from the image of
Plaintiff Dunstan’s hard drive.
Based on our conversation, I understand our experts pulled the following types of files from the image of Dunstan’s hard
drive: a file listing, Windows registry information, event logs, log files, internet browsing history, and a listing of emails
without the body of the emails themselves. Plaintiffs objected to the collection of information past the alleged date
Dunstan downloaded comScore’s software, and the collection of internet browsing history and emails.
As I mentioned on the phone, comScore believes internet browsing history and the listing of emails is relevant to
comScore’s concerns about the operation of Dunstan’s computer, particularly with respect to computer viruses.
Additionally, Dunstan’s browsing history just before, during, and just after the removal of comScore’s software is
relevant to Plaintiffs’ claims, in that some of them depend on a panelist’s activities online. Thus, comScore contends
this email and browsing information was properly collected and should be provided to comScore.
With respect to the timeframe involved, comScore proposes the following: limiting collection of the file listing, internet
browsing history, and listing of emails so that no files created after September 1, 2010 are collected and/or listed. All
other files collected are related to the operation of the computer and not Dunstan’s activities on the computer. These
files should be produced regardless of timeframe, because they may provide information regarding any ongoing issues
the computer may have had. Please let us know if this proposal is acceptable to you. Also, please let us know if you
have the capability to remove the postSeptember 1, 2010 data from the three categories of data listed above. If not,
we will attempt to coordinate with our expert to do so.
Regards,
Robyn Bowland
Associate,
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
312.705.7479 Direct
312.705.7400 Main Office Number
312.705.7499 FAX
robynbowland@quinnemanuel.com
www.quinnemanuel.com
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