Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 1 of 19 Page ID #:1
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`Mohammad Tajsar (SBN 280152)
`mtajsar@aclusocal.org
`ACLU Foundation of Southern California
`1313 West 8th Street
`Los Angeles, CA 90017
`Telephone: (213) 977-9500
`Facsimile: (213) 977-5297
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`Jacob A. Snow (SBN 270988)
`jsnow@aclunc.org
`ACLU Foundation of Northern California
`39 Drumm Street
`San Francisco, CA 94111
`Telephone: (415) 621-2493
`Facsimile: (415) 255-8437
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`Counsel for Plaintiffs
`(continued on next page)
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`UNITED STATES DISTRICT COURT FOR THE
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`CENTRAL DISTRICT OF CALIFORNIA
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`CASE NO: 2:20-cv-05044
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`COMPLAINT
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`Plaintiffs,
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`JUSTIN SANCHEZ and ERIC ALEJO;
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`v.
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`LOS ANGELES DEPARTMENT OF
`TRANSPORTATION and CITY OF
`LOS ANGELES,
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` Defendants.
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 2 of 19 Page ID #:2
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`(continued from previous page)
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`Jennifer Lynch (SBN 240701)
`jlynch@eff.org
`Electronic Frontier Foundation
`815 Eddy Street
`San Francisco, CA 94109
`Tel: (415) 463-9333
`Fax: (415) 436-9993
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`Douglas E. Mirell (SBN 94169)
`DMirell@ggfirm.com
`Timothy J. Toohey (SBN 140117)
`TToohey@ggfirm.com
`Greenberg Glusker Fields Claman & Machtinger LLP
`2049 Century Park East, Suite 2600
`Los Angeles, California 90067
`Telephone: (310) 553-3610
`Fax:
`(310) 553-0687
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`INTRODUCTION
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`1.
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`Beginning in late 2017, communities across California witnessed a
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`near-overnight invasion of motorized electric scooters on city sidewalks. Equipped
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`with tiny motors, batteries, and the sleek insignia of their proprietor technology
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`companies, they introduced a new dockless mode of transit for smartphone-
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`equipped consumers as an alternative to cars, bicycles, and public transit. Similar
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`to a car ride-share service, riders reserve and pay for scooter rentals through a
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`smartphone app. At the end of a trip, the user leaves the scooter on the street,
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`where it can be rented again.
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`2.
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`Soon after scooters appeared, complaints targeting the scooter
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`companies followed. Although dockless scooters represented a novel and
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`potentially useful form of transit, they also cluttered city sidewalks, lacked safety
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`features, and interfered with disabled access to city streets. The scooter companies
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`themselves often did jurisdictions no favors, aggressively pushing back against
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`attempts to regulate the vehicles.
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`3.
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`As in other cities across the country, this was the story of scooters in
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`Los Angeles. In an attempt to avoid the unpopular profusion of scooters filling the
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`sidewalks, Defendants Los Angeles Department of Transportation and the City of
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`Los Angeles (collectively “LADOT” or “Defendants”) developed a far-reaching
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`software tool that (they claim) is necessary to managing the right of way. Dubbed
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`the Mobility Data Specification (“MDS”), this software interface, crafted in
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`partnership with a private consultancy, forces operators of dockless vehicles to
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`provide real-time and historical data about each vehicle and trip taken in Los
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`Angeles, all as a condition of operating. Most importantly, the tool requires that
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`scooter companies produce detailed trip data about every single scooter trip taken
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`within city limits, including where each trip starts, the route it takes, and where it
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`ends.
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`4.
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`Although MDS does not record the identity of the rider directly, the
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`COMPLAINT
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`precision with which it captures riders’ location information—often to within a few
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`feet—likely allows riders to be identified. Knowing that a particular trip began at
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`an office building and ended in front of a home, for example, makes the difficulty
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`of identifying the individual rider as simple as knowing their home and work
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`addresses. Given the large amount of public or otherwise accessible data about
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`people’s lives that exists, simply cross-referencing MDS data about a particular
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`trip with any other dataset (including mere observation of a routinely-taken scooter
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`trip) can reveal who took the trip.
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`5.
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`Beyond identifying an individual rider, the locations where an
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`individual’s trip starts and ends can also reveal why that rider made the trip.
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`Regular trips that start near a residence and end at an office reveal that a person
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`living at the residence works at the office and takes a particular route to work.
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`Periodic trips that begin at a high school and end in a family-planning clinic could
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`reveal that a student is seeking reproductive health care. Even a single trip to a
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`protest against police violence may result in a rider’s name being revealed and her
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`presence at the protest exposed against her wishes.
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`6.
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`LADOT has never articulated an adequate or reasonable justification
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`for the collection of such sensitive location information en masse. When mandated
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`by the Los Angeles City Council to identify, by February 25, 2020, its reasons for
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`collecting precise location data, LADOT failed to do so. Now, over three months
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`after this deadline, LADOT has still not articulated an operationally specific need
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`for this data. To date, it has offered only the most generic justifications for
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`collecting precise location information, stating at one point that its goal is to
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`“experiment” with riders’ protected information when setting agency policy.
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`7.
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`The Constitution prohibits LADOT from experimenting with the
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`rights of its constituents. The Fourth Amendment strictly limits the warrantless
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`collection of vehicular location information. As a Supreme Court majority
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`recognized in United States v. Jones, “GPS monitoring generates a precise,
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`COMPLAINT
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`comprehensive record of a person’s public movements that reflects a wealth of
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`detail about her familial, political, professional, religious, and sexual associations.”
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`565 U.S. 400, 415 (2012) (J., Sotomayor, concurring); id. at 430 (J., Alito,
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`concurring) (long-term capture of vehicle location information violates reasonable
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`expectation of privacy). This is particularly true here, where the scale and breadth
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`of that data collection has no conceivable relation to a targeted investigation of a
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`particular individual. MDS collects precise location data associated with every
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`single rider of scooters within the City, every single time they ride such a vehicle.
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`And once MDS software is deployed, it gathers location data without any human
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`involvement and at the maximum precision generated by the vehicles.
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`8.
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`Plaintiffs ride electric scooters in the City of Los Angeles, using the
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`vehicles to make trips from their homes to work, friends, businesses, and places of
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`leisure. LADOT uses MDS to warrantlessly collect sensitive vehicle location data
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`associated with each of Plaintiffs’ trips, in violation of their right to be free from
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`unreasonable searches and seizures in contravention of the United States and
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`California Constitutions. The compelled production of Plaintiffs’ location
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`information also violates the California Electronic Communications Privacy Act
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`(“CalECPA”).
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`9.
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`LADOT violates these rights irrespective of whether it collects data
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`about Plaintiffs’ movements in real-time or after a period of delay. The gathering
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`of historical location information about individuals without sufficient justification
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`violates the Constitution. United States v. Carpenter, 138 S. Ct. 2206, 2218 (2018)
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`(comparing the greater harms of historical location tracking as opposed to manual
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`real-time observation, and explaining that “[u]nlike with the GPS device in Jones,
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`police need not even know in advance whether they want to follow a particular
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`individual, or when.”). When that location data is highly precise (as the MDS data
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`is), the risks with collecting historical location information are too great without a
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`warrant.
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`COMPLAINT
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 6 of 19 Page ID #:6
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`10. Through this action, Plaintiffs seek, among other forms of relief,
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`expungement of their location data from LADOT’s servers and an injunction
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`preventing MDS from collecting and storing precise location information en
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`masse.
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`JURISDICTION
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`11. This Court has subject matter jurisdiction over this action under 28
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`U.S.C. § 1331 and 28 U.S.C. § 1343 because it alleges violations of the United
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`States Constitution enforceable through 42 U.S.C. § 1983, and under 28 U.S.C.
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`§ 1367 because it alleges violations of the California Constitution and the
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`California Penal Code.
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`12. Venue is proper under 28 U.S.C. § 1391(a) because Defendants are
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`VENUE
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`residents of this district, 28 U.S.C. § 1391(b) because the events and actions giving
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`rise to the claims herein occurred in this District, and 28 U.S.C. § 1391(c) because
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`Defendants are subject to the court’s personal jurisdiction in this District.
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`13. Plaintiff Justin Sanchez is a resident of Los Angeles, and a customer
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`PARTIES
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`of and rider of dockless vehicles offered by Lime, Bird, and Lyft. Mr. Sanchez has
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`ridden scooters operated by these three providers within the City of Los Angeles
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`while MDS has been in effect. Mr. Sanchez intends to continue riding these
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`dockless vehicles within Los Angeles in the future.
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`14. Plaintiff Eric Alejo is a resident of Los Angeles, and a customer of
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`and rider of dockless vehicles offered by Lyft, JUMP, Bird, and Lime. Mr. Alejo
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`has ridden scooters operated by these four providers within the City of Los
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`Angeles while MDS has been in effect. Mr. Alejo also intends to continue riding
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`these dockless vehicles within Los Angeles in the future.
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`15. Defendant City of Los Angeles is a public entity, duly organized and
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`existing under the laws of the State of California.
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`COMPLAINT
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`16. Defendant Los Angeles Department of Transportation is a government
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`agency created by Los Angeles city ordinance. It advertises that its mission is “to
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`lead transportation planning, project delivery, and operations in the City of Los
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`Angeles.” LADOT developed and operates the permitting program that licenses the
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`operation of dockless vehicle providers within Los Angeles.
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`STATEMENT OF FACTS
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`I.
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`DOCKLESS VEHICLES LAUNCH IN SOUTHERN CALIFORNIA IN
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`2017, AND ARE FORMALLY ALLOWED IN THE CITY OF LOS
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`ANGELES BEGINNING IN MARCH 2019.
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`17. Beginning in 2017, numerous private companies began dropping
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`dockless vehicles, including motorized scooters and electric bicycles, on Los
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`Angeles streets. These vehicles are owned and maintained by private companies,
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`and individual customers can rent them via a smartphone application. These
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`vehicles are “dockless” in that rides need not start from a fixed docking station,
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`like a traditional municipal bicycle share. Instead, rides can begin and end
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`wherever a vehicle is located, with a user employing only the provider’s mobile
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`application to terminate the rental. At that point, the application informs the rider
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`of the cost of the ride, and charges the user accordingly.
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`18. The operators typically outfit the vehicles with rechargeable batteries,
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`Global Positioning System (“GPS”) trackers, and wireless connectivity to the
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`internet. The vehicles broadcast precise GPS coordinates to the operator, which
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`allows it to track rides and charge customers accordingly.
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`19. With the growing use of dockless vehicles in neighboring cities, the
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`Los Angeles City Council passed an ordinance on September 28, 2018 compelling
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`LADOT to implement a “Shared Mobility Device Pilot Program” establishing an
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`application process for the approval of City-issued permits to operators of dockless
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`bicycles, electric bicycles, motorized scooters, and electric scooters. The ordinance
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`mandated that under the Pilot Program, “an operator of a shared mobility device
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`COMPLAINT
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`shall obtain a permit from the Department [of Transportation] and comply with all
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`Department permit rules, regulations, indemnification, insurance and fee
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`requirements.”
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`20.
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`In response, LADOT created the permitting program via an
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`application and review process. In exchange for a license to operate a
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`micromobility company within City limits, LADOT instructed operators to submit
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`an application detailing their intended deployment in the City and agreeing to
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`numerous regulatory requirements.1 These requirements included otherwise
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`standard insurance requirements, an agreement to an indemnification provision,
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`limits on the total number of vehicles any individual operator could deploy within
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`Los Angeles, agreements to place safety features like lights and reflectors on
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`vehicles, requirements that operators ensure vehicles are appropriately parked and
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`not blocking pedestrian rights of way, and incentives for operators to diversify the
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`geographic distribution of their vehicles. Relevant here, the permitting application
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`required operators agree to implement MDS’s data collection protocols.
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`21. Once an operator applied for a permit, LADOT reviewed the
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`application and awarded an operating permit to the applicant accordingly.
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`Individual end users were not parties to the application agreement, despite their
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`sensitive location data being critical to the process.
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`22. The original one-year pilot program launched in March 2019, and has
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`been extended for six months through September 15, 2020. At the close of the
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`now-eighteen-month pilot, LADOT plans to establish a one-year formal dockless
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`mobility pilot program.
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`II. DEFENDANTS UTILIZE THE MOBILITY DATA SPECIFICATION
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`TO UNLAWFULLY COLLECT PRECISE MOVEMENT DATA.
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`23. As a condition of securing a permit to operate in the City of Los
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`1 LADOT’s original permit application is available at
`https://files.acluwest.org/s/XATp4ErkW4WsSsT.
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`COMPLAINT
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`Angeles, LADOT requires mobility companies to implement MDS’s data
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`collection requirements. MDS contains two interrelated parts: 1) the data-
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`collection standard, which specifies what information mobility providers must
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`deliver to the governing jurisdiction, and 2) reference implementations in software
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`code that both mobility providers and the governing jurisdiction can use to set up
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`the information exchange. MDS ingests data directly from the transportation
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`companies, enabling LADOT “to actively manage private mobility providers and
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`the public right-of-way . . . through a shared data vocabulary and to communicate
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`directly with product companies in real time using code.”2
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`24. The purpose of MDS is to accelerate information collection by cities
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`and counties facing an increase in the volume of permitting associated with
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`dockless scooters. According to the non-profit Open Mobility Foundation, the
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`proprietor of MDS who took over its administration from LADOT, “the goals of
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`MDS are to provide a standardized way for municipalities or other regulatory
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`agencies to ingest, compare and analyze data from mobility service providers, and
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`to give municipalities the ability to express regulation in machine-readable
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`formats. . . . MDS is a key piece of digital infrastructure that supports the effective
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`implementation of mobility policies in cities around the world.” Instead of each
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`city deciding for itself what information to collect and writing the necessary
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`software, MDS encourages cities to adopt a single existing standard.
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`25. MDS, once implemented by private dockless scooter companies,
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`ingests a wide variety of data directly from the providers without any human input.
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`The data includes the provider’s name, a unique device identifier for the vehicle,
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`the type of vehicle, the length of the trip, its starting point, end point, and the route
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`the vehicle took on its trip. Relevant here is the route information requirement,
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`2 “Mobility Data Specification: Information Briefing,” Los Angeles
`Department of Transportation, https://ladot.io/wp-content/uploads/2018/12/What-
`is-MDS-Cities.pdf, Oct. 31, 2018.
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`COMPLAINT
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`which calls for granular trip data from the providers to LADOT about every ride
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`taken within Los Angeles—including the starting point of the ride, the starting time
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`of the ride, the end point for the ride, and the ending time of the ride. LADOT
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`requires that start and end locations be provided in real-time, and the route that the
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`trip took between those points provided after 24 hours.
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`26. While MDS does not collect any information directly identifying the
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`rider of a particular vehicle, the sensitivity of movement information makes it
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`possible to identify individual riders anyway. Coupling a rider’s precise trip data
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`with information from just one other dataset—for instance, additional scooter rides
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`that show a pattern of repeated trips to and from the same locations, public voting
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`records from particular addresses, or even simple physical observation of a rider—
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`can likely identify the individual who took the trip. In addition, it may reveal
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`important information about the individual’s residence, the identity of her
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`employer, associates, or friends, the type of physicians she visits, or her favorite
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`recreational activities. And when end points are sensitive locations—like
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`therapists’ offices, marijuana dispensaries, or Planned Parenthood clinics—those
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`routes may reveal why she made that trip.
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`27.
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`In a time when protests are erupting around the country, the risk of
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`identifying individuals based on physical observation takes on a new importance.
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`Imagine a person who takes a scooter to a political protest, or even rides past and is
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`captured by one of the many cameras used to document interaction between
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`protesters and police. With the information LADOT ingests through MDS, that
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`individual ride could be picked out of a haystack of data and handed over to the
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`police, who would then know where the person ended their trip, where they started,
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`and the precise route they took.
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`28. The likelihood of identifying individuals based only on location
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`information is not a hypothetical concern. A growing body of research has
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`demonstrated that location datasets are easily susceptible to identification. “With
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`COMPLAINT
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`merged mobility datasets, this becomes even easier: An agent could potentially
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`match users trajectories in anonymized data from one dataset, with deanonymized
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`data in another, to unmask the anonymized data.”3 For instance, researchers have
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`found that they could identify 50% of people from only two randomly chosen data
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`points in a dataset that contained only time and location data.4
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`29.
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`Identification of location data poses grave risks to individuals—
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`particularly marginalized or justice-impacted members of the community. In
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`addition to revealing sensitive information about people’s lives, this information
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`can exacerbate persistent forms of state violence and bias that target those at the
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`fringes. This includes police encounters, immigration enforcement, homelessness
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`sweeps, or enforcement of pre-trial release terms or probation conditions, to name
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`a few. Past experience has also shown that individual location information in the
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`hands of authorities can stoke racial and gender-based violence. When collected
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`without adequate safeguards, location information often results in cases of
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`domestic abuse and stalking, as a recent investigation of automatic license plate
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`reader information in California revealed.5
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`3 Rob Matheson, The privacy risks of compiling mobility data: Merging
`different types of location-stamped data can make it easier to discern users’
`identities, even when the data is anonymized, MIT News (Dec. 7, 2018),
`http://news.mit.edu/2018/privacy-risks-mobility-data-1207 (describing Daniel
`Kondor et al., “Towards matching user mobility traces in large-scale datasets,”
`IEEE Transactions on Big Data (Sep. 24, 2018), available at
`http://senseable.mit.edu/papers/pdf/20180927_Kondor-
`etal_TowardsMatching_IEEE-BigData.pdf)).
`4 Yves-Alexandre de Montjoye, et al., Unique in the Crowd: The privacy
`bounds of human mobility, 3 Nature Scientific Reports 1376 (2013),
`http://www.nature.com/articles/srep01376 (finding that “in a dataset where the
`location of an individual is specified hourly, and with a spatial resolution equal to
`that given by the carrier’s antennas, four spatio-temporal points are enough to
`uniquely identify 95% of the individuals.”).
`5 “Automated License Plate Readers: To Better Protect Individuals’’
`Privacy, Law Enforcement Must Increase Its Safeguards for the Data It Collects,”
`(cont’d)
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 12 of 19 Page ID #:12
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`30. Despite the sensitivity of location data and the increasing legal
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`protections individuals have over their location information, LADOT’s MDS
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`protocol demands maximally precise locations about individuals’ trips. LADOT’s
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`technical consultants developed the program to collect as precise information as
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`the vehicles generate. With the pilot program in full effect, LADOT captured GPS
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`coordinates broadcast by scooters up to seven decimal places, an extraordinary
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`level of accuracy even assuming a wide margin of error. For background, GPS
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`coordinates are often expressed through decimal degrees via longitude and latitude
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`coordinates. The more decimal places a GPS coordinate is measured in, the more
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`precise the location it reveals is.6 MDS compels vehicle operators to provide the
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`coordinates of each vehicle in latitude and longitude to the maximum precision
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`allowed by the vehicle, which can be up to seven decimal places. For reference,
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`coordinates in seven decimal degrees are accurate to within 1.11 centimeters at the
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`equator. In real-world conditions away from the equator, the accuracy with which
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`the companies capture a vehicle’s location depends on the scooter’s hardware, the
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`availability of over-the-air internet connectivity, and the physical conditions
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`surrounding a vehicle that may impact GPS signal strength. Given advances in
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`technology and widespread access to 4G (and, soon, 5G connectivity), the
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`coordinates generated by dockless vehicles can accurately place them within a few
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`dozen feet, indicating with confidence, for example, where on a city block a
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`scooter is and the building or piece of city infrastructure nearest which it is parked.
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`31. Research has demonstrated that even truncating GPS coordinates of
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`trips’ origins and destinations by lopping off GPS decimal places does little to
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`California State Auditor (Feb. 20, 2020),
`https://www.auditor.ca.gov/pdfs/reports/2019-118.pdf, at 12–13 (discussing
`instance of gender-based assault resulting from license plate location information).
`6 For a helpful explanation of the math behind the precision of GPS
`locations, see “Decimal Degrees,” WIKIPEDIA,
`https://en.wikipedia.org/wiki/Decimal_degrees (last visited June 3, 2020).
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 13 of 19 Page ID #:13
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`protect individuals’ privacy. Such is the sensitivity of location data sets, which
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`cannot reasonably be considered “anonymized” in any real sense when collected en
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`masse and with the precision that MDS currently demands.
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`32. Given these facts, and upon information and belief, a simple analysis
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`of MDS data will likely identify the precise trips taken by Plaintiffs in this case and
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`where they live, work, shop, and frequent. Plaintiffs have never agreed to share
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`their precise location data with LADOT, even though LADOT has used MDS to
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`extract this data from the operators whose vehicles Plaintiffs rented.
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`III. DEFENDANTS HAVE FAILED TO PROVIDE REASONABLE
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`JUSTIFICATIONS FOR COMPELLING PRODUCTION OF
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`LOCATION INFORMATION.
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`33. When LADOT launched its pilot MDS program, it did not identify
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`with operational specificity how it intended to use the data ingested by MDS. Nor
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`did it develop a data collection and retention program narrowly tailored to meet
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`even the use cases it did identify. As a result, granular location information easily
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`susceptible to identification is needlessly—and illegally—collected and at risk of
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`being shared with third parties and targeted by other government actors.
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`34. According to LADOT, the purpose of MDS is multifaceted, and
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`allows LADOT to “actively manage private companies who operate in our public
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`space.”7 During the development of the pilot program, LADOT identified
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`numerous overlapping and related benefits that mass location data may provide to
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`the regulators, some more specific than others, but none that necessitated collecting
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`all riders’ granular and precise location information en masse.
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`35. To the contrary, LADOT leadership expressly identified the MDS
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`pilot as a mechanism to “experiment” with this data collection project.8 Put
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`7 “LADOT | Putting Ideas into motion,” https://ladot.io/ (embedding
`YouTube video entitled “The Future of Mobility – Mobility Data Specification”).
`8 David Zipper, “Cities can see where you’re taking that scooter,” Slate, Apr.
`(cont’d)
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 14 of 19 Page ID #:14
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`differently, LADOT has intentionally gathered sensitive and legally protected
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`location information in an experimental posture with data concerning actual users
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`in real time—unlawfully collecting data in order to determine post hoc how to
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`exploit them to serve non-specific regulatory needs.
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`36. LADOT’s dockless scooter pilot program fails to tailor its collection
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`of individual location data to articulable use cases. Given the lack of specificity for
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`its proposed use cases, it is difficult to identify potential alternatives to maintaining
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`individual trip data, or to gauge the necessity of mass location data collection to
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`achieve LADOT’s regulatory ends.
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`37. To the contrary, LADOT has been exceptionally vague about how it
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`intends to use this data, in part to allow the agency to experiment with exploiting
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`the data after it is collected. Each of the articulated use cases LADOT has offered
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`for its desire to collect en masse individual vehicle location data fails under
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`scrutiny. For instance, the City Council mandated that LADOT’s pilot program
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`incentivize providers to diversify access to its vehicles. Addressing equity in
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`regional distributions of vehicles by itself does not require individual, granular
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`location data. For instance, collecting a vehicle’s neighborhood-level locations at
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`regular, but disparate, time intervals (e.g., every two hours) will adequately inform
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`regulators whether providers are distributing their vehicles equitably—without
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`collecting individuals’ trip data.
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`38. Even the few use cases LADOT has offered for why granular trip data
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`is necessary do not require detailed vehicle telemetry data. For instance, even
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`though MDS calls for acquiring GPS coordinates up to a maximum level of
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`precision, current physical limitations on the accuracy of GPS broadcasts from
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`2, 2019, https://slate.com/business/2019/04/scooter-data-cities-mds-uber-lyft-los-
`angeles.html (quoting LADOT General Manager Seleta Reynolds, “When bikes
`and scooters showed up, they gave us a pretty interesting sandbox to start
`experimenting.”)
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 15 of 19 Page ID #:15
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`vehicles make their coordinates too imprecise to determine whether scooters are
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`appropriately parked adjacent to a curb versus inappropriately parked in the middle
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`of a sidewalk a couple of feet away, another purpose LADOT has offered for why
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`it needs individual users’ trip information.
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`39. Even when the City Council instructed LADOT to articulate “specific
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`regulatory purposes for the collection and use of each type of data required by
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`MDS,” LADOT simply did not comply. This request came in a Los Angeles City
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`Council Motion passed on November 27, 2019, which required LADOT to, among
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`other things, provide a report outlining the “specific regulatory purposes for the
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`collection and use of each type of data required by MDS” by February 25, 2020.9
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`To date, and more than three months after the deadline, LADOT has still not
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`articulated those purposes in response to the request.
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`40.
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`Importantly, LADOT lacks reasonable and justifiable uses for both
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`real-time location information and historical location data—both of which present
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`substantially similar violations of Plaintiffs’ rights. This is in contrast to concerns
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`raised by some of the micromobility providers, including JUMP. While JUMP has
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`historically protested LADOT’s requirement that it produce precise location
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`information in real-time, including by filings its own lawsuit challenging MDS
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`data collection by MDS, JUMP offered to produce that information to LADOT
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`after a 24-hour delay.10 According to JUMP, a 24-hour delay “significantly
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`mitigate[s] the frightening risks of direct and constant government surveillance and
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`possible interception of individual users.”11
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`41. Perhaps most ominously, LADOT plans to extend the same model for
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`9 Motion No. 19-1355, Intro. By David Ryu (Nov. 1, 2019), available at
`http://clkrep.lacity.org/onlinedocs/2019/19-1355_mot_11-01-2019.pdf.
`10 Social Bicycles LLC d/b/a JUMP v. City of Los Angeles, No. 2:20-cv-
`02746 (C.D. Cal. filed Mar. 24, 2020), ECF No. 1, at ¶ 11 (challenging MDS
`location collection from perspective of private scooter operator).
`11 Id.
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`Case 2:20-cv-05044-CJC-PD Document 1 Filed 06/08/20 Page 16 of 19 Page ID #:16
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`real-time geolocation information collection that it uses for dockless vehicles to
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`“all kinds of future transportation forms—