EXHIBIT A 

Case: 1:20-cv-02526 Document #: 1-1 Filed: 04/24/20 Page 1 of 16 PageID #:6
Service of Process

Transmittal

03/26/2020

CT Log Number 537459504

TO: Stephanie Schaeffer

Paychex, Inc.

911 Panorama Trl S

Rochester, NY 14625-2396

RE: Process Served in Illinois

FOR: Paychex of New York LLC  (Domestic State: DE)

Page 1 of  1 / AG

Information displayed on this transmittal is for CT

Corporation's record keeping purposes only and is provided to

the recipient for quick reference. This information does not

constitute a legal opinion as to the nature of action, the

amount of damages, the answer date, or any information

contained in the documents themselves. Recipient is

responsible for interpreting said documents and for taking

appropriate action. Signatures on certified mail receipts

confirm receipt of package only, not contents.

ENCLOSED ARE COPIES OF LEGAL PROCESS RECEIVED BY THE STATUTORY AGENT OF THE ABOVE COMPANY AS FOLLOWS:

 

TITLE OF ACTION: Arturo Bedolla, etc,. Pltf. vs. Paychex of New York LLC

DOCUMENT(S) SERVED: -

COURT/AGENCY: None Specified

Case # 2020CH01535

ON WHOM PROCESS WAS SERVED: C T Corporation System, Chicago, IL

DATE AND HOUR OF SERVICE: By Process Server on 03/26/2020 at 13:29

JURISDICTION SERVED : Illinois

APPEARANCE OR ANSWER DUE: None Specified

ATTORNEY(S) / SENDER(S): None Specified

ACTION ITEMS: CT has retained the current log, Retain Date: 03/28/2020, Expected Purge Date:

04/02/2020

Image SOP

Email Notification,  Stephanie Schaeffer  slschaefer@Paychex.com

Email Notification,  Dana Bolia  dbolia@paychex.com

Email Notification,  Denise Mackowiak  DMackowiak@paychex.com

SIGNED: C T Corporation System

ADDRESS: 1209 N Orange St

Wilmington, DE 19801-1120

For Questions: 866-401-8252

EastTeam2@wolterskluwer.com

Case: 1:20-cv-02526 Document #: 1-1 Filed: 04/24/20 Page 2 of 16 PageID #:7
PROCESS SERVER DELIVERY DETAILS

Date: Thu, Mar 26, 2020

Server Name: Sheriff Drop

Location: Chicago, IL-CHI

Entity Served PAYCHEX OF NEW YORK LLC

Agent Name C T CORPORATION SYSTEM

Case Number 2020CH01535

Jurisdiction IL-CHI

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Return D^te: No return date scheduled

Hearii

Court

Locati8i?2ftistFli<?t|

23Za>elS@ocs#0^ Mail

2420 - Served By Publication 2421 - Served By Publication

Sununons - Alias Summons

2221 - Not Served FILED

3/19/2020 3:07 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH01535

2321 - Served By Mail

(06/28/18) CCG 0001

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

8918137

3>

TVrturo Bedolla, individually and for a Class

:

2020-CH-01535 (Name aU parties) Case No.

V.

3 c/o CT Corporation System

208 S. LaSalle St., Suite 814

Chicago, IL 60604

3

5 Paychex ofNew York LLC

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3 0 SUMMONS ALIAS SUMMONS

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J To each Defendant:

YOU vUlE SUMMONED and required to file an answer to the complaint in this case, a copy ofwhich is hereto attached, or otherwise

file your appearance and pay the required fee within thirty (30) days after service ofthis Summons, not counting the day of service.

To file your answer or appearance you need access to the internet. Please visit www.cookcotmtvclerkofcourt.ory to initiate this process.

Kiosks with internet access are available at all Clerk’s Office locations. Please refer to the last page ofthis document for location

information.

If you fail to do so, a judgment by default may be entered against you for the relief requested in the complaint.

To the Officer:

This Summons must be returned by the officer or other person to whom it was given for service, with endorsement of service and fees,

if any, immediately after service. If service caimot be made, this Summons shall be returned so endorsed. This Summons may not be

served later than thirty (30) days after its date.

E-filing is now mandatory for documents in civil cases with limited exemptions. To e-fQe, you must first create an account

with an e-filing service provider. Visit https://efile.illinoiscourts.gov/service-providers.htm to leam more and to select a

service provider. Ifyou need additional help or have trouble e-filing, visit http://www.ilUnoiscoutts.gov/FAQ/gethelp.asp.

Witness:

3/19/2020 3:07 PM DOROTHY BROWN

56618 Atty. No.:

Atty Name:

Atty. for: _

Address:

City: Chicago

60601

DOROT [, Clerk of Court

Date of Service:!-‘I ?^1

(To be inserted PY '^th Defendant

or other person):

Timothy P. Kingsbury

. Plaintiff

55 W. Wacker Dr., 9th FI.

State: ^

Zip:

Telephone:

Primary Email:

Secondary Email:

Tertiary Email: _

Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois cookcountyclerkofcourt.org

Page 1 of 2

(312)-893-7002

tkingsbury@mcgpc.com

aheldut@mcgpc.com

Case: 1:20-cv-02526 Document #: 1-1 Filed: 04/24/20 Page 4 of 16 PageID #:9
CLERK OF THE CIRCUIT COURT OF COOK COUNTY OFFICE LOCATIONS

O Richard J Daley Center O

50 W Washington

Chicago, IL 60602

O District 2 - Skokie

5600 Old Orchard Rd

Skokie, IL 60077

O District 3 - Rolling Meadows

2121 Euclid

Rolling Meadows, IL 60008

District 4 - Maywood

1500 Maybrook Ave

Maywood, IL 60153

District 5 - Bridgeview

10220 S 76th Ave

Bridgeview, IL 60455

O District 6 - Markham

16501 S Kedzie Pkwy

Markham, IL 60428

Domestic Violence Court

555 W Harrison

Chicago, IL 60607

O Juvenile Center Building

2245 W Ogden Ave, Rm 13

Chicago, IL 60602

O Criminal Court Building

2650 S California Ave, Rm 526

Chicago, IL 60608

Domestic Relations Division

Richard J Daley Center

50 W Washington, Rm 802

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Civil Appeals

Richard) Daley Center

50 W Washington, Rm 801

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Criminal Department

Richard J Daley Center

50 W Washington, Rm 1006

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

County Division

Richard J Daley Center

50 W Washington, Rm 1202

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Probate Division

Richard J Daley Center

50 W Washington, Rm 1202

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Law Division

Richard J Daley Center

50 W Washington, Rm 801

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

Traffic Division

Richard) Daley Center

50 W Washington, Lower Level

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

J

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E

o

i

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0

5

C o

3 o

i

o

o

o

o

o

Daley Center Divisions/Departments

O Civil Division

Richard) Daley Center

50 W Washington, Rm 601

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

® Chancery Division

Richard J Daley Center

50 W Washington, Rm 802

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

o

Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois cookcountyclerkofcourt.org

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Case: 1:20-cv-02526 Document #: 1-1 Filed: 04/24/20 Page 5 of 16 PageID #:10
FILED

3/13/2020 4:37 PM

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH01535

COUNTY DEPARTMENT, CHANCERY DIVISION

ARTURO BEDOLLA, individually and )

on behalfofsimilarly situated individuals, ) 8865251

)

Plaintiff, ) No. 2020-CH-01535

)

V. ) Hon. Pamela M. Meyerson

)

PAYCHEX OF NEW YORK LLC, a

Delaware limited liability company,

) Jury Trial Demanded

)

)

Defendant. )

FIRST AMENDED CLASS ACTION COMPLAINT & JURY DEMAND

PlaintiffArturo Bedolla (“Plaintiff’), individually and on behalf of other similarly situated

individuals, brings this Class Action Complaint against Defendant Paychex of New York LLC

d^/a Icon Time Systems, Inc. (“Defendant”), for its violations of the Illinois Biometric

Information Privacy Act, 740 ILCS 14/1, et seq. (“BIPA”), and to obtain redress for persons

injured by its conduct. Plaintiff alleges the following based on personal knowledge as to his own

experiences, and as to all other matters, upon information and belief, including an investigation

conducted by his attorneys.

INTRODUCTION

1. BIPA defines a “biometric identifier” as any personal feature that is unique to an

individual, including fingerprints and palm scans. “Biometric information” is any information

based on a biometric identitler, regardless of how it is converted or stored. 740 ILCS § 14/10.

Collectively, biometric identifiers and biometric information are known as “biometrics.”

2. Defendant is a leading provider of employee timekeeping solutions, including

timekeeping equipment that relies on biometric information to track workers’ time.

Case: 1:20-cv-02526 Document #: 1-1 Filed: 04/24/20 Page 6 of 16 PageID #:11
3. Through the biometric devices it provides to various businesses and employers,

Defendant captured, stored, and disseminated the biometrics ofPlaintiff and other Class members

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} without their informed written consent as required by BIPA.

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: 4. BIPA provides, inter alia, that private entities, such as Defendant, may not collect.

r capture, or otherwise obtain an individual’s biometric identifiers, such as fingerprints and hand

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scans, or any biometric information, including any data regardless of the manner from which it 3

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c was converted, or is converted or stored, unless they first;

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a. inform that person in writing that his/her biometrics will be collected or stored; J

b. inform that person in writing ofthe specific purpose and the length ofterm for which

such biometrics are being collected, stored and used; and

c. receive a written release from the person for the collection oftheir biometrics.

740 ILCS 14/15(b)(l)-(3).

5. BIPA also requires private entities in possession of biometric information to

develop a publicly available written policy outlining the storage and destruction policies of such

biometric identifiers, and/or any biometric information derived from such identifiers. 740 ILCS

14/15(a).

6. Finally, private entities are prohibited from disseminating or re-disclosing

biometric information without informed consent. 740 ILCS 14/15(d).

7. Plaintiff brings this action for statutory damages and other remedies as a result of

Defendant’s conduct in violating his biometric privacy rights under BIPA.

8. BIPA’s requirements bestow upon individuals in Illinois a right to privacy in

biometrics and a right to make an informed decision when electing whether to provide or withhold

their biometrics.

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9. Defendant’s deprivation of Plaintiff’s statutory rights conferred by BIPA

constitutes the actual injuries the Illinois Legislature sought to prevent.

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5 10. On behalf of himself and the proposed Class defined below. Plaintiff seeks an

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injunction requiring Defendant to comply with BIPA, as well as an award ofstatutory damages to i

t the Class members and monetary damages to be determined at trial, together with costs and

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reasonable attorneys’ fees. 5

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c PARTIES

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11. Defendant Paychex of New York LLC d/b/a Icon Time Systems, Inc. is a limited

liability company organized under the laws of the state of Delaware that conducts substantial

business throughout Illinois, including in Cook County, and is licensed by the Illinois Secretary of

State to transact business in Cook County, Illinois.

12. Plaintiffis a resident of Cook County, Illinois, and a citizen ofthe state ofIllinois.

JURISDICTION AND VENUE

13. This Court may assert personal jurisdiction over Defendant pursuant to 735 ILCS

5/2-209 in accordance with the Illinois Constitution and the Constitution of the United States,

because Defendant is doing business within this State and because Plaintiffs claims arise out of

Defendant’s unlawful in-state actions, as Defendant captured, collected, stored, and used

Plaintiffs biometric identifiers and/or biometric information in this State.

14. Venue is proper in Cook Coxmty pursuant to 735 ILCS 5/2-101, because Defendant

is doing business in Cook County and thus resides there under § 2-102, and because the transaction

out ofwhich this cause of action arises occurred in Cook Coimty.

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FACTS SPECIFIC TO PLAINTIFF

0 15. Defendant is a leading provider of employee timekeeping solutions, including •)

5 timekeeping equipment that relies on biometric information to track workers’ time by comparing

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real-time biometric scans against stored biometrically derived templates. :

t 16. During his employment throughout the relevant limitations period. Plaintiff was

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5 required to scan his fingerprints, and/or other biometrics, into Defendant’s biometric timekeeping

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c device each time he needed to “clock-in” and “clock-out” of a shift at hisjob.

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17. Via its biometric technology. Defendant captured, collected, and otherwise

obtained, and then stored for subsequent processing and comparison, the biometric identifiers

and/or biometric information ofPlaintiff and the Class members.

18. Upon each biometric scan. Defendant received and stored, even if temporarily.

either biometric identifiers, and/or portions or data derived therefrom, in some medium and format.

in order to allow Defendant’s customers the ability to subsequently access such biometrics and

data for accurate timekeeping and payroll calculation.

19. After capturing and storing Plaintiffs biometrics on its biometric devices.

Defendant redisclosed the same, in some manner orformat, to Plaintiffs employer for timekeeping

and payroll calculation.

20. Prior to obtaining Plaintiffs biometric identifiers, or data derived therefrom, i.e.

biometric information. Defendant did not inform Plaintiffin writing that his biometrics were being

collected, stored, used, or disseminated. Defendant did not seek, and Plaintiff never provided, any

written consent relating to the collection, use, storage, or dissemination of his biometrics.

21. Prior to obtaining Plaintiffs biometric identifiers and information, during the

process of obtaining same, and for an indefinite period following such collection or otherwise

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handling, Defendant did not make publicly available any written policy as to a biometric retention

schedule and guidelines for permanently destroying the collected biometrics. 1

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3 22. On information and belief, Defendant did not have a BIPA-compliant retention and 5

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destruction policy at the time it first came into possession of Plaintilfs and other class members’

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biometric identifiers and information, and for some time thereafter such initial collection.

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5 23. Additionally, Defendant did not obtain consent from Plaintifffor any dissemination

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c or redisclosure ofhis biometrics.

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24. By failing to comply withBIPA, Defendant has violated Plaintiffs substantive state

rights to biometric privacy.

CLASS ALLEGATIONS

25. Plaintiff brings this action on behalf of himself and similarly situated individuals

pursuant to 735 ILCS § 5/2-801. Plaintiffseeks to represent a Class defined as follows:

Class: All individuals whose biometrics were captured, collected, stored, used,

transmitted, disseminated, or otherwise obtained by or on behalf of Defendant or

its technology or equipment within the state of Illinois any time within the

applicable limitations period.

26. Excluded from the Class are any members ofthe judiciary assigned to preside over

this matter; any officer or director of Defendant; and any immediate family member of such

officers or directors.

27. Upon information and belief, there are at least himdreds ofmembers ofthe Class,

making the members of the Class so numerous that joinder of all members is impracticable.

Although the exact number ofmembers ofthe Class is currently unknown to Plaintiff, the members

can be easily identified through Defendant’s records.

28. Plaintiffs claims are typical ofthe claims ofthe members ofthe Class he seeks to

represent, because the factual and legal bases of Defendant’s liability to Plaintiff and the other

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members are the same, and because Defendant’s conduct hasresulted in similar injuriesto Plaintiff

and to the Class. As alleged herein. Plaintiffand the Class have all suffered damages as a result of

3 Defendant’s BIPA violations.

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29. There are many questions oflaw and fact common to the claims ofPlaintiff and the :

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t Class, and those questions predominate over any questions that may affect individual members.

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Common questions for the Class include, but are not limited to, the following: 5

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c a. Whether Defendant’s conduct is subject to BIPA;

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i b. When Defendant made available to the public a written policy that establishes

a retention schedule and guidelines for destroying biometrics;

c. Whether Defendant obtained a written release from the Class before

capturing, collecting, or otherwise obtaining their biometrics;

d. Whether and when Defendant provided a written disclosure that explains the

specific purposes, and the length of time, for which biometrics were being

collected, stored and used before taking such biometrics;

e. Whether Defendant’s conduct violates BIPA; and

f Whether Plaintiff and the Class are entitled to damages and injunctive relief

30. Absent a class action, most members ofthe Class would find the cost oflitigating

their claims to be prohibitively expensive and would thus have no effective remedy. The class

treatment of common questions of law and fact is superior to multiple individual actions or

piecemeal litigation in that it conserves the resources ofthe courts and the litigants and promotes

consistency and efficiency of adjudication.

31. Plaintiff will fairly and adequately represent and protect the interests ofthe other

members of the Class he seeks to represent. Plaintiff has retained coimsel with substantial

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experience in prosecuting complex litigation and class actions. Plaintiff and his coimsel are

'> committed to vigorously prosecuting this action on behalf ofthe other members ofthe Class and

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5 have the financial resources to do so. Neither Plaintiff nor his counsel has any interest adverse to

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those ofthe other members ofthe Class. :

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32. Defendant has acted and failed to act on grounds generally applicable to the

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5 Plaintiff and the other members ofthe Class, requiring the Court’s imposition of uniform reliefto

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c ensure compatible standards of conduct toward the members ofthe Class and making injimctive

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i or corresponding declaratory relief appropriate for the Class as a whole.

COUNTI

Violation ofthe Illinois Biometric Information Privacy Act, 740 ILCS 14/1, etseq.,

(On behalf ofPlaintiff and the Class)

33. Plaintiffincorporates the foregoing allegations as iffully set forth herein.

34. Defendant is a private entity under BIPA.

BIPA requires private entities, such as Defendant, to obtain informed written

consent from individuals before acquiring their biometric information. Specifically, BIPA makes

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it unlawful to “collect, capture, purchase, receive through trade, or otherwise obtain a person’s or

customer’s biometric identifiers or biometric information unless [the entity] first: (1) informs the

subject ... in writing that a biometric identifier or biometric information is being collected or

stored; (2) informs the subject ... in writing of the specific purpose and length of for which a

biometric identifier or biometric information is being captured, collected, stored, and used; and (3)

receives a written release executed by the subject of the biometric identifier or biometric

information ....” 740 ILCS 14/15(b).

36. Illinois’ BIPA also requires that private entities in possession of biometric

identifiers and/or biometric information establish and maintain a publicly available retention

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policy. Entities that possess biometric identifiers or information must (i) make publicly available

a written policy establishing a retention schedule and guidelines for permanent deletion of ?

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) biometric information (entities may not retain biometric information longer than three years after

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the last interaction with the individual); and (ii) adhere to the publicly posted retention and deletion >

I- schedule. 740ILCS 14/15(a).

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5 37. Plaintiff and the other Class members have had their “biometric identifiers,” or

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c portions and/or information derived therefi’om, i.e. biometric information, collected, captured.

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received or otherwise obtained by Defendant. Defendant obtained such biometrics using its

biometric timekeeping devices located at Plaintiffs and the Class members’ respective places of

employment.

38. On each instance Plaintiff and the other Class members scanned their respective

biometrics into Defendant’s biometric devices. Defendant captured, collected, stored, and/or

otherwise obtained Plaintiffs and the other Class members’ biometric identifiers or biometric

information without valid consent and without complying with BIPA.

39. In order to provide accurate and precise employee management services for

Plaintiffs employer. Defendant obtained data and information that would not exist absent

Defendant’s capture, collection and storage ofPlaintiffs biometric identifiers, and/or portions of

information derived therefi’om. This information allowed Defendant, inter alia, to provide its

customers the ability to discern the identity and hours ofwork ofa given worker, such as Plaintiff

40. In order to provide employee management services for Plaintiffs employer.

Defendant necessarily, in some format or medium, stored biometric identifiers and/or biometric

information on its devices and then disclosed the same so that Plaintiffs employer could access

and use the same.

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41. Defendant’s practice with respect to capturing, collecting, storing, and using

biometrics fails to comply with applicable BIPA requirements:

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5 a. Defendant failed to inform Plaintiff and the members ofthe Class in writing

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that their biometrics were being collected and stored, prior to such collection

r or storage, as required by 740ILCS 14/15(b)(l);

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5 b. Defendant failed to inform Plaintiff and Class in writing of the specific

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c purpose for which their biometrics were being captured, collected, stored, and

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i used, as required by 740 ILCS 14/15(b)(2);

c. Defendant failed to inform Plaintiff and the Class in writing the specific

length of term their biometrics were being captured, collected, stored, and

used, as required by 740 ILCS 14/15(b)(2);

d. Defendant failed to obtain a written release, as required by 740 ILCS

14/15(b)(3);

e. Defendant failed to maintain a publicly available retention schedule detailing

the length of time for which the biometrics are stored and/or guidelines for

permanently destroying the biometrics they store, as required by 740 ILCS

14/15(a) at all times it was in possession of Plaintiff and the class members’

biometrics; and

f Prior to disclosing or re-disclosing Plaintiffs biometric identifiers and/or

information for employee management purposes. Defendant failed to obtain

informed consent, as required by 740 ILCS 14/15(d)(1).

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42. By capturing, storing, using, and disseminating Plaintiffs and the Class’ biometrics

as described herein. Defendant denied Plaintiff and the Class their right to statutorily required ■i

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) information and violated their respective rights to biometric privacy, as set forth in BIPA.

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43. BIPA provides for statutory damages of $5,000 for each willful ahd/or reckless

violation and damages of$1,000 for each negligent violation ofBIPA. 740ILCS I4/20(l)-(2).

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5 44. Defendant’s violations ofBIPA, as set forth herein, were knowing and willful, or

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were at least in reckless disregard of the statutory requirements. Alternatively, Defendant c

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negligently failed to comply with BIPA.

With respect to Coimt I, Plaintiff, on behalf of himself and the proposed Class,

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prays for the reliefset forth below.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff, on behalf of himself and the proposed Class, respectfully

requests that this Court enter an Order:

a. Certifying the Class as defined above, appointing Plaintiff as class

representative and the undersigned as class counsel;

b. Declaring that Defendant’s actions, as set forth herein, violate BIPA;

c. Awarding injunctive and equitable relief as necessary to protect the interests

of Plaintiff and the Class by requiring Defendant to comply with BIPA

requirements for the capture, collection, storage, use, and dissemination of

biometric identifiers and biometric information;

d. Awarding statutory damages of $5,000 for each willful and/or reckless

violation ofBIPA, pursuant to 740 ILCS 14/20(2);

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e. Awarding statutory damages of $1,000 for each negligent violation ofBIPA,

pursuant to 740ILCS 14/20(1); 1

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5 f Awarding monetary damages and equitable relieffor Defendant’s negligence

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in an amount to be determined at trial; :

t g- Awarding reasonable attorneys’ fees, costs, and other litigation expenses

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> pursuant to 740 ILCS 14/20(3);

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c h. Awarding pre- and post-judgment interest, as allowable by law; and

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1 1. Awarding such further and other relief as the Court deemsjust and equitable.

JURY DEMAND

Plaintiffrequests trial by jury ofall claims that can be so tried.

Dated: March 13, 2020 Respectfully submitted.

ARTURO BEDOLLA, individually and on behalf

ofsimilarly situated individuals

By: /s/ Timothy P. Kingsbury

One ofPlaintiff’s Attorneys

Timothy P. Kingsbxuy

Andrew T. Heldut

MCGUIRE LAW, P.C.

55 W. Wacker Drive, 9th FI.

Chicago, IL 60601

Tel: (312) 893-7002

tkingsbury@mcgp.com

aheldut@mcgpc.com

Attorneysfor Plaintiff'and the Putative Class

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