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Case: 1:20-cv-04589 Document #: 1 Filed: 08/05/20 Page 1 of 16 PageID #:1
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`ISELA CARMINE,
`on behalf of herself and all others
`similarly situated,
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`Plaintiff,
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`vs.
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`Case No. 20-cv-4589
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`Jury Demanded
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`MACY’S RETAIL HOLDINGS, INC.,
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`Defendant.
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`CLASS ACTION COMPLAINT
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`Plaintiff Isela Carmine, on behalf of herself and a putative class (“Plaintiff” or “Carmine”),
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`brings this Class Action Complaint against Macy’s Retail Holdings, Inc. (“Macy’s”) and alleges
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`the following:
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`Introduction
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`1.
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`A New York Times article published on January 18, 2020 introduced Americans to the
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`then relatively unknown company Clearview AI, Inc (“Clearview”). The article described a
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`dystopian surveillance database, owned and operated by a private company and leased to the
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`highest bidder.
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`2.
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`On February 27, 2020, BuzzFeed News released an article based on a review of
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`Clearview’s documents, revealing that Clearview is working or contracted with over 2,200 law
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`enforcement agencies, companies, and individuals around the world.
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`3.
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`The same article and subsequent reporting by several news outlets revealed that
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`Defendant Macy’s, among other private businesses and government entities, was using
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`Clearview’s surveillance database to aid in its operations.
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`

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`4.
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`Macy’s has run the identities of over six thousand individual customers through the
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`database.
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`5.
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`Clearview AI’s database includes the photographs, and personal and private data,
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`including names, home addresses, and work addresses, of millions of Americans. Clearview
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`acquired the billions of data points by “scraping” or harvesting the data from publicly available
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`internet-based platforms such as Facebook, Instagram, and Twitter.
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`6.
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`Clearview’s database is unique – it has run every one of the 3 billion photographs it has
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`acquired through facial recognition software to extract and index the unique biometric data from
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`each face. The database thus also contains the biometric identifiers and information of millions
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`of Americans. Any private citizen can be identified by uploading a photo to the database. Once
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`identified, the end-user – here Macy’s – then has access to all of the individual’s personal details
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`that Clearview has also obtained.
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`7.
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`Macy’s acquisition and use of consumer’s biometric information and identifiers is illegal
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`in Illinois.
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`8.
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`Macy’s practice of identifying and tracking their customers using Clearview’s illegal
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`surveillance database is unfair and directly violates each customers’ right to privacy.
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`Parties
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`9.
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`Plaintiff Isela Carmine is a natural person and resident of this district. She maintains an
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`active presence on social media, including Facebook and Instagram. She also uses Venmo to
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`make and accept payments to other individuals. Carmine is a regular customer at Macy’s.
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`10.
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`Defendant Macy’s Retail Holdings, Inc. is a Delaware corporation, doing business in
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`Illinois, with twenty-one department stores in the state.
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`2
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`Jurisdiction
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`11.
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`This Court has jurisdiction under 28 U.S.C. § 1332(d)(2) and the Class Action Fairness
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`Act (“CAFA”) because there are 100 or more members of the class, the parties and putative class
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`members are minimally diverse and the aggregate amount in controversy is greater than
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`$5,000,000.
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`12.
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`This Court has personal jurisdiction over Macy’s because they conduct a substantial
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`amount of business here which forms the basis of Plaintiff’s claims. Macy’s operates multiple
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`stores in Illinois and is registered to do business in this state.
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`13.
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`Venue is proper here under 28 U.S.C. § 1391(b)(2) because a substantial amount of the
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`acts and omissions giving rise to the claims occurred in Illinois.
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`Macy’s Surveillance and Clearview’s Database
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`14.
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`Clearview ‘scrapes,’ ‘harvests,’ or otherwise obtains information and photos of millions
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`of Americans from the internet, in particular social media platforms like Facebook and
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`Instagram. That is, they use automated software or processes to obtain massive amounts of data
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`without the consent or knowledge of the platform users.
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`15. Macy’s stores are equipped with video surveillance that captures the images of its visitors
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`and customers.
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`16. Macy’s sends or has sent pictures of persons who have visited its stores to Clearview, to
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`identify the people in the pictures and obtain their personal information.
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`17.
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`Clearview then runs the photos through facial recognition software which identifies the
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`photos that contain faces.
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`3
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`

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`18.
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`The faces are then processed by Clearview’s software, and their biometric data is
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`extracted. The biometric data is a collection of vectors and/or other data points that allows faces
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`to be classified, searched and indexed.
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`19.
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`Clearview’s database links the biometric data to the other data Clearview has scraped so
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`an end-user, like Macy’s, can find out where the photos came from along with a significant
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`amount of personal and private details about a given individual.
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`20.
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`In short, anyone with access to the database, including a reseller of the database or end-
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`user, can upload a single photo and identify the person in real-time. A single picture on the
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`internet means that any private citizen can immediately be identified and tracked.
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`21.
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`Clearview sells or leases access to the surveillance database to public and private entities,
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`for profit. Clearview additionally contracts with third parties, like Macy’s, to sell or lease access
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`to the surveillance database.
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`22. Macy’s has a paid contract with Clearview.
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`23.
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`The pictures and images from video surveillance at Macy’s are uploaded to Clearview’s
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`database. If there is a match, the results identifying individual shoppers based on their facial
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`geometry are sent back to Macy’s.
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`The Illinois Biometric Information Privacy Act (“BIPA”)
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`24. More than ten years ago, the Illinois Legislature recognized the promises and perils of
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`biometric identification technology. It passed the Biometric Information Privacy Act, 740 ILCS
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`§ 14/1 et seq., to establish and safeguard Illinois’ residents absolute right to control their
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`biometric data.
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`25.
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`26.
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`BIPA regulates both biometric identifiers and biometric information. See, id.
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`Under the act, a “scan of…face geometry,” is a biometric identifier. Id. at § 14/10.
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`4
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`

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`27.
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`Biometric information is any information derived from a biometric identifier, regardless
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`of how it is captured, stored, or shared. Id.
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`28.
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`The positive ID’s that Macy’s received back from Clearview are biometric information,
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`as they are based on the biometric data Clearview has harvested and are used to identify
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`individuals.
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`29.
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`Once the photo is positively identified based on the biometric information in Clearview’s
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`possession, the positive identification of those photos become biometric information.
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`30.
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`Under the act, a private entity, like Clearview or Macy’s, in possession of either
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`biometric identifiers or information must develop a written policy, available to the public,
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`establishing a retention schedule and guidelines for permanently destroying the information or
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`identifiers. Id. § 14/15(a).
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`31.
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`Defendant has not provided any policy whatsoever establishing either a retention
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`schedule or guidelines for permanently destroying the biometric data.
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`32.
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`Under the act, a private entity like Macy’s is prohibited from collecting, capturing, or
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`otherwise obtaining a person’s biometric information or identifier unless it first: a) informs the
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`subject in writing that the information or identifier is being collected or stored; b) informs the
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`subject in writing of the specific purpose and length of term for which the information or
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`identifier is being collected, stored, or used;, and, c) receives a written release from the subject of
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`the information or identifier. Id. at § 14/15(b).
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`33. Macy’s had not at any relevant time informed Plaintiff or any member of the Class
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`(described below) any of the information required under § 14/15(b). Neither the Plaintiff nor
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`members of the putative Class executed a written release to Macy’s.
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`5
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`

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`34.
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`Under the act, a private entity, like Macy’s, in possession of a person’s biometric
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`identifier or information may not sell, lease, trade, or otherwise, profit from a person’s
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`information or identifier. Id. § 14/15(c).
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`35. Macy’s is actively profiting off of Plaintiff’s and each member of the putative class’
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`information or identifier through improved security and/or through marketing.
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`36.
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`Under the act, a private entity, like Macy’s, in possession of a person’s biometric
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`identifier or information may not disclose or disseminate the information except in certain
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`specific situations, such as to comply with a valid warrant or subpoena. Id. at § 14/15(d).
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`37.
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` Finally, under the act, a private entity, like Macy’s, in possession of a person’s biometric
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`identifier or information must store, transmit, and protect the information from disclosure using a
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`reasonable standard of care for their industry and in a manner that is the same or more protective
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`than the manner in which the private entity stores, transmits, and protects other confidential and
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`sensitive information. Id. at § 14/15(e).
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`38.
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`BIPA provides a private right of action for violations of the act. For each individual
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`violation, a person may recover the greater of actual damages or $1,000 for each negligent
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`violation or $5,000 for each intentional or reckless violation. Id. at § 14/20. The act also provides
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`for reasonable attorneys’ fees, costs, and expenses and any other relief the court deems
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`appropriate, including injunctive relief. Id.
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`39. Macy’s knew that to covertly collect personal and private data and biometric information
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`would violate the privacy rights that BIPA was enacted to protect and that the violations would
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`cause substantial harm to Illinois residents.
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`6
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`

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`The Illinois Consumer Fraud and Deceptive Business Practices Act (“ICFA”)
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`40.
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`The ICFA proscribes any unfair or deceptive acts or practices in the course of trade or
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`commerce. 815 ILCS § 505/2.
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`41.
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`The ICFA allows any consumer who suffers actual damages from a violation of the act to
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`bring a private action to recover actual damages or any other relief the court deems proper,
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`including punitive damages, as well as attorney’s fees and costs. Id. at §§ 505/10a(a); 505/10a(c).
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`42. Macy’s does not provide notice that individual’s entering their stores will be
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`photographed or filmed and that their faces will be run through the illegal Clearview surveillance
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`database.
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`43. Macy’s does not notify consumers that Macy’s is acquiring their identity and personal
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`information from the Clearview database.
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`44. Macy’s secret collection of photos and videos and positive identifications through
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`Clearview’s database occurred in the course of commerce or trade.
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`45. Macy’s secret identification of its shoppers based on their photographs is an unfair
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`business practice.
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`46. Macy’s use of the illegal Clearview database without notice to consumers is an unfair
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`business practice.
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`47. Macy’s intended for Illinois residents to be unaware of their covert data harvesting and
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`surveillance operation, knowing that if they were aware, they would take steps to protect their
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`personal and private data, including by not shopping at or entering any of Macy’s stores.
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`48.
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`Once Plaintiff became aware of Macy’s practices and/or Clearview’s database, and the
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`likelihood she was included in it, she was harmed by the invasion of her privacy, the anxiety and
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`fear from being included in the surveillance database without her knowledge and consent, and by
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`7
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`having to pay for an attorney to file and litigate this suit to have her data removed from the
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`database.
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`Plaintiff’s Allegations
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`49.
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`50.
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`Plaintiff has been an Illinois resident, residing in the Northern District of Illinois.
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`At relevant times, Plaintiff posted photos of herself on various publicly-accessible
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`platforms and websites. Plaintiff posted the photos described in the preceding sentence while
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`located in the Northern District of Illinois.
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`51.
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`At relevant times, others posted photos of Plaintiff on various publicly-accessible
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`platforms and websites.
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`52.
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`At relevant times, photos of Plaintiff have appeared on various publicly-accessible
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`websites.
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`53.
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`At no time did Defendant nor Clearview inform Plaintiff or a legally authorized
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`representative of Plaintiff in writing that they had collected or obtained Plaintiff’s biometric
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`identifier or biometric information.
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`54.
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`At no time did Defendant nor Clearview inform Plaintiff or a legally authorized
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`representative of Plaintiff in writing of the specific purpose and length of term for which
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`Plaintiff’s biometric identifier and/or biometric information was being collected, stored and used.
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`55.
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`At no time did Plaintiff or her legally authorized representative provide Defendant with
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`an executed written release allowing them to collect, obtain, or use her biometric identifier
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`and/or biometric information.
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`56.
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`At no time did Plaintiff or her legally authorized representative consent to Defendant
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`disclosing or redisclosing her biometric identifiers and/or biometric information.
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`8
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`

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`57.
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`Based on publicly-available information, Defendant Macy’s obtained biometric
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`information for over six thousand individual searches – including the biometric identifiers and
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`information of Plaintiff and Class Members – and subsequently profited from that biometric
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`information.
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`58.
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`Clearview, directly and through its agents, provided customers, such as Defendant
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`Macy’s, with a service agreement that ensured customers would have unlimited access to its
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`database. Based on a service agreement, the agreement made no mention of privacy protections,
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`constitutional safeguards or limitations on information sharing of any kind.
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`59.
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`In practice, Macy’s could use the database to identify individual shoppers, whose pictures
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`they have taken, via biometric searches and then share or use the results in its desired way. As a
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`result, a single shopper’s biometric search could potentially snowball into a nationwide dragnet.
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`60. Moreover, any Macy’s employee with access to the surveillance database could use it for
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`their own personal ends -- for example, to stalk or track an individual.
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`61.
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`62.
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`Carmine learned of the Clearview surveillance database and its use by Macy’s.
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`Because Carmine has such a widespread and active social media presence, on
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`information and belief, Carmine’s biometric information and identifiers and her personal and
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`private information are contained in Clearview’s database.
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`63.
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`Carmine was immediately concerned for her own privacy and safety and the privacy and
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`safety of her friends and family.
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`64.
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`Plaintiff Carmine has experienced anxiety, stress and other emotional distress based on
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`her inclusion in the surveillance database and the unauthorized, for-profit acquisition and use of
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`her biometric information by Defendant Macy’s.
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`9
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`65.
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`Carmine has suffered actual damages from the loss of control over her personal
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`property—her biometric identifiers and information—as a result of the Defendant’s actions.
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`66.
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`Due to Defendant’s actions, Carmine’s unique biometric information, which BIPA was
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`designed to protect, has been compromised and sold for profit. It is unclear whether Carmine will
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`ever be able to regain control over her biometric information.
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`67.
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`Further, and as a result of all Defendant’s actions, Carmine, and her family and friends,
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`are at a greater risk of stalking, harassment, and identity theft.
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`Class Allegations
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`68.
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`Isela Carmine brings this action on behalf of herself and under Fed. R. Civ. P. 23, on
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`behalf of a class defined as:
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`All persons who reside or resided in Illinois whose biometric identifier or information is
`or was contained in the Clearview database at any time and subsequently provided to
`Macy’s.
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`69.
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`Plaintiff reserves the right to amend or modify the Class definition as necessary following
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`discovery.
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`70.
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`On information and belief, the Class is so numerous that joinder is impracticable. While
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`the exact number is unknown, Plaintiff believes, based on reputable news sources, that
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`Defendant has run over 6,000 searches on individuals.
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`71.
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`Common questions of law and fact exist and predominate over individual questions and
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`include:
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`a.
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`Whether any of the members consented to their inclusion in the surveillance
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`database;
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`10
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`

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`b.
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`Whether an individual’s unique biometric identifiers and information, such as
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`facial geometry, is intangible personal property or whether they have property right in
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`such identifiers and information;
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`c.
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`The extent of any damages incurred by Class members as a result of Defendant’s
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`actions.
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`72.
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`Plaintiff’s claims are also typical and co-extensive with the claims of the class because
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`she and members of the Class have all suffered the same injuries as a result of identical conduct
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`by the Defendant.
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`73.
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`Plaintiff will fairly and adequately protect the interests of the proposed Class and she has
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`retained counsel with experience in consumer law, Illinois law, and federal class actions.
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`74.
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`A class action is superior to other methods of adjudication. The Class seeks injunctive
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`relief applicable to the Class as a whole; due to the complexity of the claims, individual actions
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`are not likely to be economically feasible; based on the possibility of a very large Class size,
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`individual litigation would be a burden on the courts and result in delay and inconsistent results.
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`Relief Sought
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`COUNT I – DECLARATORY AND INJUNCTIVE RELIEF
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`Plaintiff restates and alleges the above paragraphs, 1-80, as if set forth fully herein.
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`Plaintiff and the Class seek a declaration:
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`75.
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`76.
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`a.
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`That the Macy’s business practice of using surveillance camera photos to get a
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`positive identification through Clearview’s database are an ongoing violation of the
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`Illinois Biometric Privacy Act;
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`77.
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`Plaintiff and the Class seek a court order:
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`11
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`

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`a.
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`to command Macy’s to expunge, delete, and/or remove all information associated
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`in any way with any member of the Class from their database or any other data
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`collection;
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`b.
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`to restrain Macy’s from using its received positive identification from Clearview’s
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`scraping or harvesting any information related to any member of the class from any
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`source at any time now or in the future;
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`c.
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`to command Macy’s to submit to and pay for court-supervised monitoring by a
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`third party of their database and data-collection procedures to ensure compliance with
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`BIPA and any other order of the court;
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`COUNT II – VIOLATION OF THE BIOMETRIC INFORMATION PRIVACY ACT
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`78.
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`79.
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`Plaintiff restates and alleges the above paragraphs, 1-80, as if set forth fully herein.
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`Defendant violated BIPA 740 ILCS § 14/15(a) by failing to develop and maintain a
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`publicly available retention and destruction schedule.
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`80.
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`Defendant violated BIPA 740 ILCS § 14/15(b) by obtaining biometric information and
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`identifiers without making the required disclosures and receiving a written release from each
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`Class member.
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`81.
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`Defendant violated BIPA 740 ILCS § 14/15(c) by selling, leasing, trading, or otherwise
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`profiting from the Plaintiff’s and Class member’s biometric information and identifiers.
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`82.
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`Defendant violated BIPA 740 ILCS § 14/15(d) by disclosing, re-disclosing, and
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`otherwise disseminating Plaintiff’s and Class members’ biometric identifiers and information
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`where the individuals did not consent to such disclosure and it was not: a) part of a financial
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`transaction; b) required by any law; or, c) pursuant to a valid warrant or subpoena.
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`12
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`83.
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`As a direct result of these violations, Plaintiff and the Class suffered and continue to
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`suffer injury and actual, economic, and emotional damages.
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`84.
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`Plaintiff and the Class seek:
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`a.
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`$1,000 for the Plaintiff and each member of the class for each and every separate
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`negligent violation;
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`b.
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`$5,000 for the Plaintiff and each member of the class for each and every separate
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`intentional or reckless violation;
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`c.
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`d.
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`e.
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`punitive damages;
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`costs, expenses, and reasonable attorneys’ fees;
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`and, any other relief this court deems proper.
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`COUNT III – INVASION OF PRIVACY
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`85.
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`86.
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`Plaintiff restates and alleges the above paragraphs, 1-80, as if set forth fully herein.
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`Defendant did not have the right to Plaintiff’s biometric information, and invaded the
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`privacy of Plaintiff and other Macy’s customers.
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`87.
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`88.
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`As a result, Plaintiff suffered damages as a result of Defendant’s misconduct.
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`Plaintiff and the Class seek:
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`a.
`
`b.
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`c.
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`d.
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`actual damages;
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`punitive damages;
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`costs, expenses, and reasonable attorneys’ fees; and
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`any other relief the Court deems equitable and just.
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`COUNT IV – ILLINOIS CONSUMER FRAUD AND UNFAIR BUSINESS PRACTICES
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`ACT (ICFA) – UNFAIR ACT
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`89.
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`Plaintiff restates and alleges the above paragraphs, 1-80, as if set forth fully herein.
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`13
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`

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`90.
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`At all times relevant, Defendant was engaged in trade or commerce in the state: Macy’s
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`has a paid contract with Clearview who leased, sold, or otherwise provided, for profit, access to
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`the surveillance database based on pictures that Macy’s provided.
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`91.
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`At all times relevant, Plaintiff and members of the class were consumers within the
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`meaning of ICFA.
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`92.
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`Defendant’s practice of using Clearview’s unauthorized scraping or harvesting of
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`Plaintiff’s and the Class members’ photos, videos, private and personal information, and its
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`conversion into biometric information and identifiers to add to their surveillance database is an
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`unfair practice.
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`93.
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`This practice has caused substantial injury and harm to Plaintiff and the members of the
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`Class. It has also forced the Plaintiff to retain counsel to force Macy’s to comply with BIPA and
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`redress other violations of state law.
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`94.
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`Plaintiff and the Class seek:
`
`a.
`
`b.
`
`c.
`
`d.
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`actual damages;
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`punitive damages;
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`costs, expenses, and reasonable attorneys’ fees; and
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`any other relief the Court deems equitable and just.
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`COUNT V – ILLINOIS CONSUMER FRAUD AND UNFAIR BUSINESS PRACTICES
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`ACT – DECEPTIVE ACT
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`95.
`
`96.
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`Plaintiff restates and alleges the above paragraphs, 1-80, as if set forth fully herein.
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`At all times relevant, Defendant was engaged in trade or commerce in the state: Macy’s
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`has a paid contract with Clearview who leased, sold, or otherwise provided, for profit, access to
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`the surveillance database based on pictures that Macy’s provided.
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`14
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`97.
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`At all times relevant, Plaintiff and members of the class were consumers within the
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`meaning of ICFA.
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`98.
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`Defendant’s practice of using Clearview’s unauthorized scraping or harvesting of
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`Plaintiff’s and the Class members’ photos, videos, private and personal information, and its
`
`conversion into biometric information and identifiers to add to their surveillance database is a
`
`deceptive act.
`
`99.
`
`This practice has caused substantial injury and harm to Plaintiff and the members of the
`
`Class. It has also forced the Plaintiff to retain counsel to force Macy’s to comply with BIPA and
`
`redress other violations of state law.
`
`100. Plaintiff and the Class seek:
`
`actual damages;
`
`punitive damages;
`
`costs, expenses, and reasonable attorneys’ fees; and
`
`any other relief the Court deems equitable and just.
`
`a.
`
`b.
`
`c.
`
`d.
`
`
`
`Jury Demand
`
`Plaintiff demands a trial by jury.
`
`
`
`
`
`
`
`August 5, 2020
`
`
`
`
`
`
`[Signature Page Follows]
`
`15
`
`

`

`Case: 1:20-cv-04589 Document #: 1 Filed: 08/05/20 Page 16 of 16 PageID #:16
`
`Submitted By:
`/s/ Michael W. Drew
`
`Michael Drew
`Neighborhood Legal LLC
`20 N. Clark Street #3300
`Chicago, IL 60602
`312-967-7220
`mwd@neighborhood-legal.com
`
`
`Michael Wood
`Community Lawyers LLC
`20 N. Clark Street, Suite 3100
`Chicago, IL 60602
`Tel (312) 757-1880
`mwood@communitylawyersgroup.com
`
`Attorneys for Plaintiff
`
`16
`
`

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