Exhibit 2 

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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

FAIR ISAAC CORPORATION, 

Plaintiff/Counterclaim Defendant, 

v. 

TRANS UNION LLC, 

Defendant/Counterclaim Plaintiff. 

No. 17-cv-08318 

Hon. Sharon Johnson Coleman 

MEMORANDUM OF LAW IN SUPPORT OF 

MOTION TO REASSIGN CASES AS RELATED 

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TABLE OF CONTENTS 

I. INTRODUCTION ................................................................................................................... 1 

II. PROCEDURAL BACKGROUND ......................................................................................... 1 

III. ARGUMENT ....................................................................................................................... 4 

A. The Cases Are Related ......................................................................................................... 4 

B. The Conditions for Reassignment Are Met ......................................................................... 7 

IV. CONCLUSION .................................................................................................................. 10 

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TABLE OF AUTHORITIES 

 Page(s) 

Cases 

DBD Franchising, Inc. v. DeLaurentis, 

No. 09 C 669, 2009 U.S. Dist. LEXIS 52890 (N.D. Ill. June 23, 2009) ...............................7, 9 

Fairbanks Capital Corp. v. Jenkins, 

No. 02 C 3930, 2002 U.S. Dist. LEXIS 26297 (N.D. Ill. Dec. 3, 2002) .......................5, 6, 7, 9 

Hollinger, Int’l, Inc. v. Hollinger, Inc., 

No. 04 C 0698, 2004 U.S. Dist. LEXIS 7883 (N.D. Ill. May 5, 2004) .................................7, 8 

Karamelion v. Elexa Consumer Prods., Inc., 

No. 19-cv-06329, ECF No. 23 (N.D. Ill. Jan. 29, 2020) ............................................................7 

KPASA, LLC v. U.S., 

No. 04 C 109, 2004 U.S. Dist. Lexis 8720 (N.D. Ill. May 17, 2004) ........................................3 

Martin v. Midland Funding LLC, 

No. 11 C 3104, 2011 U.S. Dist. Lexis 97789 (N.D. Ill. Aug. 31, 2011) ...................................6 

In re Midland Credit Mgmt. Inc., Telephone Consumer Protection Act Litig., 

818 F. Supp. 2d 1377 (2011) .....................................................................................................6 

Murry v. America’s Mortg. Banc, Inc., 

No. 03 C 5811, 2004 U.S. Dist. Lexis (N.D. Ill. Mar. 1, 2004) .........................................5, 7, 9 

Teamsters Local 705 Pension v. A.D. Conner, Inc., 

No. 10 C 6352, 2011 U.S. Dist. LEXIS 47853 (N.D. Ill. May 4, 2011) ...............................7, 8 

Williams v. Walsh Constr., 

No. 05 C 6807, 2007 U.S. Dist. LEXIS 3970 (N.D. Ill. Jan. 16, 2007) ....................................9 

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Pursuant to Northern District of Illinois Local Rule 40.4, Movants, Plaintiffs in five 

pending proposed class actions (the “Class Actions”) assigned to other judges in this District,1

respectfully move for entry of an order finding that their cases are related to the above-captioned 

action and, accordingly, should be reassigned to this calendar because this is the earliest-numbered 

case. In support of their motion, Movants state: 

I. INTRODUCTION 

Movants filed actions against Fair Isaac Corporation (“Fair Isaac”), the counterclaim 

defendant in this action, for conduct that is substantially identical to that alleged in the 

counterclaim brought here by Trans Union LLC (“TransUnion”). Each alleges that Fair Isaac 

violated federal antitrust laws in its monopolization, and attempted monopolization, of the 

business-to-business market for credit scores in the United States. The same issues of fact and law 

arise in all of these actions, presenting a textbook example of related matters. Moreover, the 

present action has not progressed to the point that any substantial delay would result by reassigning 

the related cases: written discovery is in progress but has not been substantially completed. 

Reassignment would result in a substantial saving of judicial time and effort, and avoid the risk of 

conflicting legal rulings, as these matters all involve the same legal issues, documents, and 

witnesses. 

II. PROCEDURAL BACKGROUND 

On November 16, 2017, Fair Isaac filed its complaint in this action, alleging that, inter alia, 

TransUnion breached its contract with Fair Isaac and infringed its copyrights. (ECF No. 1.) On 

February 12, 2018, TransUnion filed the public version of its counterclaims, alleging that Fair 

1 Movants include Sky Federal Credit Union, First Choice Federal Credit Union, 

Amalgamated Bank, Alcoa Community Federal Credit Union, and Getten Credit Company. 

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Isaac violated federal and state antitrust laws by, inter alia, monopolizing and attempting to 

monopolize the business-to-business credit score market in the United States. (ECF No. 38.) On 

March 27, 2019, the Court largely denied Fair Isaac’s motion to dismiss TransUnion’s antitrust 

counterclaims. (ECF No. 96.) 

On April 2, 2020, Sky Federal Credit Union filed its class action complaint against Fair 

Isaac for violations of federal and state antitrust laws, including the monopolization and attempted 

monopolization of the business-to-business credit score market in the United States, in Sky Federal 

Credit Union v. Fair Isaac Corp., No. 20-cv-02114 (the “Sky Case”), which was assigned to Judge 

Chang. A copy of the Sky Case complaint is attached as Exhibit A. Concurrent with its complaint, 

the Plaintiff filed a Notice of Related Case, informing Judge Chang that the Sky Case was related 

to this action. Id., ECF No. 4. 

On April 23, 2020, First Choice Federal Credit Union filed its class action complaint 

against Fair Isaac for violations of federal antitrust laws, including the monopolization and 

attempted monopolization of the business-to-business credit score market in the United States, in 

First Choice Federal Credit Union v. Fair Isaac Corp., No. 20-cv-02516 (the “First Choice

Case”), which was assigned to Judge Pallmeyer. A copy of the First Choice Case complaint is 

attached as Exhibit B. 

On April 24, 2020, Amalgamated Bank filed its class action complaint against Fair Isaac 

for violations of federal and state antitrust laws, including the monopolization and attempted 

monopolization of the business-to-business credit score market in the United States, in 

Amalgamated Bank v. Fair Isaac Corp., No. 20-cv-02533 (the “Amalgamated Case”), which was 

assigned to Judge Chang. A copy of the Amalgamated Case complaint is attached as Exhibit C. 

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On April 27, 2020, Alcoa Community Federal Credit Union filed its class action complaint 

against Fair Isaac for violations of federal and state antitrust laws, including the monopolization 

and attempted monopolization of the business-to-business credit score market in the United States, 

in Alcoa Community Federal Credit Union v. Fair Isaac Corp., No. 20-cv-02559 (the “Alcoa

Case”), which was assigned to Judge Norgle. A copy of the Alcoa Case complaint is attached as 

Exhibit D. 

On April 30, 2020, Getten Credit Company filed its complaint against Fair Isaac for 

violations of federal and state antitrust laws, including the monopolization and attempted 

monopolization of the business-to-business credit score market in the United States in Getten 

Credit Company v. Fair Isaac Corp., No. 20-cv-02651 (the “Getten Case”), which was assigned 

to Judge Guzman. A copy of the Getten Case complaint is attached as Exhibit E. 

On April 29, 2020, Fair Isaac made a motion (the “Fair Isaac Motion,” attached, without 

exhibits, as Exhibit F) in the Sky Case to reassign the First Choice and Alcoa Cases, and to 

consolidate the Class Actions. However, rather than have the cases assigned to the judge with the 

earliest-numbered case, as required by Local Rule 40.4, Fair Isaac seeks to have them assigned to 

Judge Chang, to whom two of the later-filed cases are currently assigned. (Id. at 1.)2 On May 1, 

2020, Judge Chang entered an order in the Sky Case (ECF No. 27), providing that, if any of the 

2 Although Local Rule 40.4 states that motions for reassignment “should not generally be 

filed until after the answer or motions in lieu of answer have been filed in each of the proceedings 

involved” – which is not the case here – this is “[i]n order that all parties to a proceeding be 

permitted to respond on the questions of relatedness and possible reassignment.” L.R. 40.4(c). 

Here, Fair Isaac not only has the opportunity to respond, but has itself sought reassignment (albeit 

to the wrong judge). In such circumstances, pre-answer reassignment is proper. See KPASA, LLC 

v. U.S., No. 04 C 109, 2004 U.S. Dist. Lexis 8720, at *13-*14 (N.D. Ill. May 17, 2004) (Exhibit 

G )(“That interest [in giving all parties opportunity to respond] is simply not implicated here, where 

the defendant has clearly weighed in on the issue of the cases’ relatedness and has, in fact, agreed 

that the cases are related and should be consolidated.”). 

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Class Action plaintiffs filed a motion to reassign the cases to this action, then any response to the 

Fair Isaac Motion is suspended. 

III. ARGUMENT 

Pursuant to Local Rule 40.4, cases should be reassigned to a single judge if: (i) they are 

related; and (ii) the practical conditions for reassignment are met. L.R. 40.4(a), (b). Both are true 

here. 

A. The Cases Are Related 

Cases are related if, inter alia, they “involve some of the same issues of fact or law,” or 

“grow out of the same transaction or occurrence.” L.R. 40.4(a)(2)-(3).3 The Class Actions, like 

the present action, all center on Fair Isaac’s anticompetitive conduct, in monopolizing the market 

for business-to-business credit scores. Indeed, the monopolization allegations made in each of 

the Class Actions is based in substantial part on TransUnion’s counterclaim in this action and on 

the investigation of Fair Isaac by the Antitrust Division of the United States Department of 

Justice, which was itself based on TransUnion’s counterclaims here. See Press Release, FICO, 

FICO Statement Regarding Antitrust Investigation (Mar. 15, 2020), https://www.fico.com/en/ 

newsroom/fico-statement-regarding-antitrust-investigation. 

Hence, as would be expected, a predominant portion of the factual and legal issues involved 

in the Class Actions overlap with those in this matter. Like TransUnion, Plaintiffs in the Class 

Actions allege that Fair Isaac monopolized the market for business-to-business credit scores. They 

allege the same relevant market. They allege the same bases for concluding that Fair Isaac has 

3 Fair Isaac itself agrees that the Class Actions are related to each other. (Fair Isaac Motion 

at 3.) As additional support for that conclusion, Fair Isaac noted there that the Class Actions also 

involve substantially the same class, which independently supports a finding of relatedness. L.R. 

40.4(a)(4). 

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monopoly power. They also allege the same anticompetitive actions by Fair Isaac to maintain and 

extend its monopoly, including: (i) imposing anticompetitive agreements on credit reporting 

agencies, including the “No Equivalent Products” and “Level Playing Field” provisions; (ii) use 

of a pricing scheme that prevents lenders from using both FICO and competing credit scores, i.e., 

the “Dynamic Royalty Schedule” and “Pre-Qualification” royalty category; and (iii) employing a 

false and misleading public relations campaign against VantageScore, Fair Isaac’s primary 

competitor. These are not only the “same issues of fact or law,” but also “grow out of the same 

transaction or occurrence,” in that they involve the same agreements that Fair Isaac executes with 

the credit reporting bureaus. 

Anticipating this motion, Fair Isaac argued in its own motion to assign the Class Actions 

to Judge Chang that they are not related to the present matter, because: (i) this action also involves 

some matters specific to the commercial dispute between TransUnion and Fair Isaac; (ii) the Class 

Actions include some legal theories not alleged in this action; and (iii) this is not a class action. 

(Fair Isaac Motion at 5.) These dissimilarities do not change the fact that these matters are related. 

As the governing rule itself says, only “some” of the same issues need overlap for the cases to be 

related, and here the overlapping issues predominate. L.R. 40.4(a)(2); see Murry v. America’s 

Mortg. Banc, Inc., No. 03 C 5811, 2004 U.S. Dist. Lexis, at *6 (N.D. Ill. Mar. 1, 2004) (Exhibit 

H) (“[T]he rule does not require complete identity of issues in order for cases to be considered 

related.”). 

Moreover, Fair Isaac’s first and third objections were squarely rejected in Fairbanks 

Capital Corp. v. Jenkins, No. 02 C 3930, 2002 U.S. Dist. LEXIS 26297 (N.D. Ill. Dec. 3, 2002) 

(Exhibit I). The plaintiff lenders there sought to foreclose on the defendant mortgagors, who 

brought counterclaims based on the Truth in Lending Act. Id., at *2-*3. Considering a motion to 

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reassign later-filed actions, against the same lenders for the same practices, the court held that it 

was of no moment that: (i) the foreclosure claims of the lenders’ own complaint were unrelated to 

the later-filed cases, and (ii) the later-filed cases were putative class actions. Id., at *9-*11. At 

most, the latter was an argument that the cases should not be fully consolidated, which is a different 

issue. Id., at *11. 

The cases cited by Fair Isaac are not to the contrary; they involve situations where there 

was a much smaller overlap in parties and legal theories. In Martin v. Midland Funding LLC, No. 

11 C 3104, 2011 U.S. Dist. Lexis 97789 (N.D. Ill. Aug. 31, 2011) (Exhibit J), the cases involved 

different defendants, different theories of liability for each defendant, and legal claims with 

different factual bases. Id., at *4-*5. By contrast, here, the Class Actions have the same Defendant 

as TransUnion’s counterclaim and involve the same theory of liability with the same factual basis 

– the additional claims of the Class Actions are causes of action based on the same facts already 

at issue.4 Fair Isaac also failed to disclose that, ultimately, the actions for which reassignment had 

been sought in Martin were centralized and transferred to the Southern District of California for 

pretrial proceedings: “we find that these four actions involve common questions of fact, and that 

centralization . . . will serve the convenience of the parties and witnesses and promote the just and 

efficient conduct of this litigation.” In re Midland Credit Mgmt. Inc., Telephone Consumer 

Protection Act Litig., 818 F. Supp. 2d 1377, 1377-78 (2011). 

Finally, it is telling that Fair Isaac does not argue that these differences mean that the 

matters are not related under L.R. 40.4(a), but only that there would not be a substantial savings 

4

In Martin, there were also two different class actions with substantial differences in the 

class definitions, requiring two separate approaches to class discovery. Id., at *5. Here, as the 

TransUnion claim is not a class action, there is no risk of conducting inconsistent class discovery 

in the same proceeding. (See Fair Isaac Motion at 3, asserting that the class definitions in the Class 

Actions are the same.) 

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of judicial time and effort – one of the “conditions for reassignment” issue under L.R. 40.4(b). See 

Teamsters Local 705 Pension v. A.D. Conner, Inc., No. 10 C 6352, 2011 U.S. Dist. LEXIS 47853, 

at *3 (N.D. Ill. May 4, 2011) (Exhibit K) (cited by Fair Isaac, but finding that the cases were related 

under L.R. 40.4(a)); Hollinger, Int’l, Inc. v. Hollinger, Inc., No. 04 C 0698, 2004 U.S. Dist. LEXIS 

7883, at *4-*5 (N.D. Ill. May 5, 2004) (Exhibit L) (cited by Fair Isaac, but considering only 

whether L.R. 40.4(b) had been met); Karamelion v. Elexa Consumer Prods., Inc., No. 19-cv06329, ECF No. 23 (N.D. Ill. Jan. 29, 2020) (Exhibit M) (same). 

B. The Conditions for Reassignment Are Met 

A related case may be reassigned if four requirements are met: (1) the cases are pending in 

this Court; (2) the handling of the cases by one judge “is likely to result in a substantial saving of 

judicial time and effort”; (3) “the earlier case has not progressed to the point” that reassignment 

“would be likely to delay the proceedings in the earlier case substantially”; and (4) “the cases are 

susceptible of disposition in a single proceeding.” L.R. 40.4(b). All are met here. 

First, there is no question that all of the cases are pending here in the Northern District of 

Illinois. 

Second, reassignment to one judge will very likely result in a substantial saving of judicial 

time and effort, because the related cases all involve substantially the same claims, against the 

same defendant, based on the same conduct. When “[n]one of the cases can be disposed of without 

determining the legality” of the defendant’s conduct, “significant judicial efficiency will result 

from having one judge handle all . . . of the cases.” Fairbanks Capital, 2002 U.S. Dist. LEXIS 

26297, at *8. Indeed, to do otherwise would risk “numerous and disparate decisions, as well as 

multiple appeals,” which is detrimental to the “overall administration of justice.” Id., at *8-*9. 

See also Murry, 2004 U.S. Dist. LEXIS 3148, at *6-*7 (“With the reassignment . . . only one judge 

will need to rule on the dispositive motions filed by defendants. . . .”); DBD Franchising, Inc. v. 

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DeLaurentis, No. 09 C 669, 2009 U.S. Dist. LEXIS 52890, at *19 (N.D. Ill. June 23, 2009) (Exhibit 

N) (“The disposition of both cases will require a court to consider the meaning of and the facts 

surrounding the Agreement. If one judge handles both cases, judicial resources will be saved.”). 

The cases upon which Fair Isaac relies are inapposite; the judicial efficiencies were found 

to be minimal because, unlike here, the cases involved fundamentally distinct causes of action, 

with different discovery and different elements. See Teamsters Local 705 Pension, 2011 U.S. Dist. 

LEXIS 47853, at *3-*5 (“[T]he causes of action are fundamentally distinct as they are brought . . . 

pursuant to two different statutes, and each requires proof of different factual elements.”); 

Hollinger, 2004 U.S. Dist. LEXIS 7883, at *8 (“The actions involve ‘fundamentally distinct’ 

claims – breach of common law duties and securities law claims – which will require different 

discovery and legal findings.”). 

Third, reassignment is not likely to cause substantial delay in these proceedings. Fair Isaac 

cites the fact that this matter has been pending for three years, and that written discovery and 

document production “would have been” subject to a substantial completion deadline if not for the 

COVID-19-related automatic extensions that have, so far, pushed that date into June.5 However, 

notwithstanding the three years that this matter has been pending, as a result of the parties’ 

procedural maneuvering, multiple motions on the pleadings, and repeated failed attempts at 

settlement, this matter is still at the written discovery stage. 

There is also reason to expect that, if reassigned, the Class Actions would proceed at an 

accelerated pace. The Court has already ruled on the legal sufficiency of allegations substantially 

the same as those in the Class Actions. Significant efficiencies in discovery would also be realized, 

5 Tellingly, Fair Isaac does not represent that written discovery and document production 

have actually been completed, or even that they will be completed by the new deadline. 

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as Fair Isaac has, no doubt, already produced, or been requested to produce, most of the materials 

the Class Action Plaintiffs would seek. Written discovery can proceed during the COVID-19 

extensions. This distinguishes the present situation from that in Williams v. Walsh Constr., No. 

05 C 6807, 2007 U.S. Dist. LEXIS 3970 (N.D. Ill. Jan. 16, 2007) (Exhibit O), upon which Fair 

Isaac relies. Unlike here, the later-filed class action in Williams involved claims that were much 

broader in scope than the earlier-filed individual action; the requisite “extensive” additional 

discovery in the class action would have taken months beyond not only the imminent discovery 

cutoff in the earlier case, but also the scheduled trial date. Id., at *7-*8. Here, there is no deadline 

for the close of discovery (only a scheduled date for “substantial completion” of written discovery), 

nor has a trial date been set. Certainly, these related actions could be managed to avoid a 

substantial delay in the current matter. 

Fourth, these cases are capable of disposition in a single proceeding. This element is met 

when the cases have outcome-determinative issues in common, and the core evidence is admissible 

in all of the actions. Fairbanks Capital, 2002 U.S. Dist. LEXIS 26297, at *10-*11; DBD 

Franchising, 2009 U.S. Dist. LEXIS 52890, at *21 (“Both cases involve essentially the same 

parties, similar factual issues, and the same Agreement. Additionally, we think it is highly likely 

that the same witnesses will be called in both cases. Accordingly, it appears that the cases are 

susceptible to disposition in a single proceeding.”); Murry, 2004 U.S. Dist. LEXIS 3148, at *7-*8 

(holding cases susceptible of disposition in a single proceeding because they both required a 

determination of whether the same conduct of defendant complied with governing law).6 This is 

certainly true here, as all of the actions turn on whether Fair Isaac’s imposition of the challenged 

6 By contrast, in Karamelion, upon which Fair Isaac relies, the cases involved allegations of 

patent infringement by different products, which obviously required different proofs. No. 19-cv06329, ECF No. 23. 

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contractual terms and pricing scheme, and dissemination of false information about its principal 

competitor, violated the antitrust laws. Substantially the same evidence – the same documents and 

the same witnesses – will be central to this determination in the present action and in the Class 

Actions. 

IV. CONCLUSION 

The Class Actions and this action are extraordinarily closely related. The allegations are 

virtually the same. Per Local Rule 40.4, the Class Actions should be reassigned to this calendar 

to achieve the significant efficiencies that would result for the benefit of the Court and the parties 

alike. Wherefore, Movants respectfully request that the Court enter an Order finding that the Class 

Actions are related to each other and to this action, and that the Class Actions should be reassigned 

to this calendar, and providing such other and further relief as the Court deems proper. 

Dated: May 4, 2020 Respectfully submitted, 

SCOTT+SCOTT ATTORNEYS AT LAW LLP

 s/ Joseph P. Guglielmo 

Joseph P. Guglielmo (N.D. Ill. No. 2759819) 

Peter A. Barile III (N.D. Ill. No. 4364295) 

Justin W. Batten 

The Helmsley Building 

230 Park Avenue, 17th Floor 

New York, NY 10169 

Telephone: 212-223-6444 

Facsimile: 212-223-6334 

jgugliemo@scott-scott.com 

pbarile@scott-scott.com 

jbatten@scott-scott.com 

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Christopher M. Burke 

SCOTT+SCOTT ATTORNEYS AT LAW LLP

600 W. Broadway, Suite 3300 

San Diego, CA 92101 

Telephone: 619-233-4565 

Facsimile: 619-233-0508 

cburke@scott-scott.com 

George A. Zelcs (Ill. Bar No. 3123738) 

Randall P. Ewing, Jr. (Ill. Bar No. 6294238) 

Ryan Z. Cortazar (Ill. Bar No. 6323766) 

KOREIN TILLERY, LLC 

205 North Michigan Avenue, Suite 1950 

Chicago, IL 60601 

Telephone: 312-641-9750 

Facsimile: 312-641-9751 

gzelcs@koreintillery.com 

rewing@koreintillery.com 

rcortazar@koreintillery.com 

Steven M. Berezney (N.D. Ill. Bar No. 56091) 

Michael E. Klenov (Ill. Bar No. 6300228) 

KOREIN TILLERY, LLC 

505 North 7th Street, Suite 3600 

St. Louis, MO 63101 

Telephone: 314-241-4844 

Facsimile: 314-241-3525 

sberezney@koreintillery.com 

mklenov@koreintillery.com 

Counsel for Plaintiff Sky Federal Credit Union 

Steven F. Molo 

Lisa W. Bohl 

MOLOLAMKEN LLP 

300 N. LaSalle Street, Suite 5350 

Chicago, IL 60654 

Telephone: 312-450-6700 

Facsimile: 312-450-6701 

smolo@mololamken.com 

lbohl@mololamken.com 

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Lauren M. Weinstein 

MOLOLAMKEN LLP 

600 New Hampshire Avenue, N.W., Suite 500 

Washington, D.C. 20037 

Telephone: 202-556-2000 

Facsimile: 202-556-2001 

lweinstein@mololamken.com 

Gary F. Lynch 

CARLSON LYNCH LLP 

1133 Penn Avenue, 5th Floor 

Pittsburgh, PA 15222 

Telephone: 412-322-9243 

Facsimile: 412-231-0246 

glynch@carlsonlynch.com 

Katrina Carroll 

CARLSON LYNCH LLP 

111 W. Wacker Drive, Suite 1240 

Chicago, IL 60602 

Telephone: 312-750-1265 

kcarroll@carlsonlynch.com 

Counsel for Plaintiff First Choice Federal Credit 

Union 

Jennifer W. Sprengel (Ill. Bar No. 06204446) 

CAFFERTY CLOBES MERIWETHER & 

SPRENGEL LLP 

150 S. Wacker, Suite 3000 

Chicago, IL 60606 

Telephone: 312-782-4880 

jsprengel@caffertyclobes.com 

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Barbara J. Hart 

Christian Levis 

Frank Strangeman 

Andrea Farah 

LOWEY DANNENBERG, P.C. 

44 South Broadway, Suite 1100 

White Plains, NY 10601 

Telephone: 914-997-0500 

bhart@lowey.com 

clevis@lowey.com 

fstrangeman@lowey.com 

afarah@lowey.com 

Counsel for Plaintiff Amalgamated Bank 

Paul E. Slater 

Joseph M. Vanek 

Michael G. Dickler 

Matthew T. Slater 

SPERLING & SLATER, P.C. 

55 West Monroe Street, Suite 3200 

Chicago, IL 60603 

Telephone: 312-641-3200 

pes@sperling-law.com 

jvanek@sperling-law.com 

mdickler@sperling-law.com 

mslater@sperling-law.com 

Linda P. Nussbaum 

Bart D. Cohen 

NUSSBAUM LAW GROUP, P.C. 

1211 Avenue of the Americas, 40th Floor 

New York, NY 10036 

Telephone: 917-438-9102 

lnussbaum@nussbaumpc.com 

bcohen@nussbaumpc.com 

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Michael L. Roberts 

Karen Sharp Halbert 

ROBERTS LAW FIRM, P.A. 

20 Rahling Circle 

Little Rock, AR 72223 

Telephone: 501-821-5575 

mikeroberts@robertslawfirm.us 

karenhalbert@robertslawfirm.us 

Counsel for Plaintiff Alcoa Community Federal 

Credit Union

Kenneth A. Wexler 

Melinda J. Morales 

Michelle Perkovic 

WEXLER WALLACE LLP 

55 W. Monroe Street, Suite 3300 

Chicago, IL 60603 

Telephone: 312-346-2222 

kaw@wexlerwallace.com 

mjm@wexlerwallace.com 

mp@wexlerwallace.com 

Daniel E. Gustafson 

Daniel C. Hedlund 

Michelle J. Looby 

Joshua J. Rissman 

Ling S. Wang 

GUSTAFSON GLUEK PLLC 

Canadian Pacific Plaza 

120 South Sixth Street, Suite 2600 

Minneapolis, MN 55402 

Telephone: 612-333-8844 

dgustafson@gustafsongluek.com 

dhedlund@gustafsongluek.com 

mlooby@gustafsongluek.com 

jrissman@gustafsongluek.com 

lwang@gustafsongluek.com 

Dennis Stewart 

GUSTAFSON GLUEK PLLC 

600 B Street, 17th Floor 

San Diego, CA 92101 

Telephone: 619-595-3299 

dstewart@gustafsongluek.com 

Case: 1:17-cv-08318 Document #: 199 Filed: 05/04/20 Page 17 of 19 PageID #:2906 Case: 1:20-cv-02516 Document #: 13-2 Filed: 05/07/20 Page 18 of 20 PageID #:330
15 

Counsel for Plaintiff Getten Credit Company 

Case: 1:17-cv-08318 Document #: 199 Filed: 05/04/20 Page 18 of 19 PageID #:2907 Case: 1:20-cv-02516 Document #: 13-2 Filed: 05/07/20 Page 19 of 20 PageID #:331
16 

CERTIFICATE OF SERVICE 

I, Joseph P. Guglielmo, an attorney, hereby certify that the foregoing MEMORANDUM 

OF LAW IN SUPPORT OF MOTION TO REASSIGN CASES AS RELATED was 

electronically filed on May 4, 2020, and will be served electronically via the Court’s ECF Notice 

system upon the registered parties of record. 

 s/ Joseph P. Guglielmo 

Joseph P. Guglielmo (N.D. Ill. No. 2759819) 

Case: 1:17-cv-08318 Document #: 199 Filed: 05/04/20 Page 19 of 19 PageID #:2908 Case: 1:20-cv-02516 Document #: 13-2 Filed: 05/07/20 Page 20 of 20 PageID #:332