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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`DAVID MUTNICK, for himself and others
`similarly situated,
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`Plaintiff,
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`v.
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`CLEARVIEW AI, INC., et al.
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`Defendants.
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`Case No. 20 C 512
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`Judge Sharon Johnson Coleman
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`Magistrate Judge Maria Valdez
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`PLAINTIFF’S NOTICE OF SUPPLEMENTAL FACTUAL INFORMATION IN
`OPPOSITION TO DEFENDANTS’ MOTION TO STAY
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`Plaintiff David Mutnick, through his attorneys, respectfully notifies the Court on May 7,
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`2020, it was disclosed in Buzzfeed News that more than 105 Illinois-based entities (including law
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`enforcement entities) have used Defendant Clearview AI, Inc.’s biometric database more than
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`12,500 times.1 The reported number of Illinois users is far more extensive than previously known
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`and provides further basis for the Court to deny the pending motion to stay (Dkt. 47). Given these
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`extensive contacts with Illinois entities in a manner that directly relates to this litigation, it is clear
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`that, at minimum, the Court has jurisdiction over Clearview AI, Inc. (“Clearview”). As such, any
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`injunction this Court enters against Clearview will be fully enforceable. Plaintiff notes that the
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`Court also has jurisdiction over Hoan Ton-That and Richard Schwartz for the reasons set forth in
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`Plaintiff’s response to the motion to stay (Dkt. 57 at 11-12), which reasons will further be expanded
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`1 Ryan Mac, et al., Clearview AI Has Promised to Cancel All Relationships with Private Companies, Buzzfeed
`News (May 7, 2020) https://www.buzzfeednews.com/article/ryanmac/clearview-ai-no-facial-recognition-private-
`companies (last accessed on May 8, 2020).
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`1
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`Case: 1:20-cv-00512 Document #: 58 Filed: 05/08/20 Page 2 of 3 PageID #:665
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`upon in Plaintiff’s response to the pending motion to dismiss for lack of personal jurisdiction or,
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`alternatively, to transfer venue (Dkt. 45).
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`Dated: May 8, 2020
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`Respectfully submitted,
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`/s/ Scott R. Drury
`SCOTT R. DRURY
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`Arthur Loevy (arthur@loevy.com)
`Michael Kanovitz (mike@loevy.com)
`Jon Loevy (jon@loevy.com)
`Scott R. Drury (drury@loevy.com
`LOEVY & LOEVY
`311 N. Aberdeen, 3rd Floor
`Chicago, Illinois 60607
`312.243.5900
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`2
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`Case: 1:20-cv-00512 Document #: 58 Filed: 05/08/20 Page 3 of 3 PageID #:666
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`CERTIFICATE OF SERVICE
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`I, Scott R. Drury, an attorney, hereby certify that, on May 8, 2020, I filed the foregoing
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`document using the Court’s CM/ECF system, which effected service on all counsel of record.
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`/s/ Scott R. Drury
`One of David Mutnick’s Attorneys
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