1

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION

DAWON A. WORDLAW, individually 

and on behalf of all similarly situated 

individuals,

Plaintiff,

v.

ENTERPRISE LEASING COMPANY 

OF CHICAGO, LLC, a Delaware limited 

liability company; ENTERPRISE 

HOLDINGS, INC., a Delaware 

corporation,

Defendants.

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No. 

Hon. 

CLASS ACTION COMPLAINT WITH JURY DEMAND

Plaintiff Dawon A. Wordlaw (“Plaintiff”), individually and on behalf of all similarly 

situated individuals, brings this Class Action Complaint against Defendants Enterprise Leasing 

Company of Chicago, LLC, and Enterprise Holdings, Inc. (collectively, “Enterprise” or 

“Defendants”) for their 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 Plaintiff’s own experiences, and as to all other 

matters, upon information and belief, including an investigation conducted by Plaintiff’s attorneys.

INTRODUCTION

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

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

information based on a biometric identifier, regardless of how it is converted or stored. 740 ILCS 

§ 14/10. Collectively, biometric identifiers and biometric information are known as “biometrics.”

2020CH03702

FILED

4/3/2020 4:39 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH03702

9019010

Return Date: No return date scheduled

Hearing Date: 8/4/2020 9:30 AM - 9:30 AM

Courtroom Number: 2008

Location: District 1 Court

 Cook County, IL FILED DATE: 4/3/2020 4:39 PM 2020CH03702

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2

2. This case concerns the misuse of individuals’ biometrics by Defendants, providers 

of automobile leasing services throughout Illinois. Using biometric enabled technology, 

Defendants are capturing, collecting, disseminating, or otherwise using the biometrics of Plaintiff 

and other Class members, without their informed written consent as required by law, in order to 

track their time at work.

3. BIPA provides, inter alia, that private entities, such as Defendants, may not obtain 

and/or possess an individual’s biometrics unless they first:

(1) inform the person whose biometrics are to be collected in writing that 

biometric identifiers or biometric information will be collected or stored; 

(2) inform the person whose biometrics are to be collected in writing of the 

specific purpose and the length of term for which such biometric identifiers 

or biometric information is being collected, stored and used;

(3) receive a written release from the person whose biometrics are to be collected, 

allowing the capture and collection of their biometric identifiers or biometric 

information; and

(4) publish publicly available retention guidelines for permanently destroying 

biometric identifiers and biometric information. 740 ILCS 14/15(a).

4. Compliance with BIPA is straightforward and may be accomplished through a 

single, signed sheet of paper. BIPA’s requirements bestow a right to privacy in biometrics and a 

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

5. Defendants’ biometric timekeeping system works by extracting biometric 

information from individuals, such as handprints, fingerprints or portions thereof, and 

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subsequently using the same for authentication and timekeeping purposes. The system includes 

the dissemination of biometrics to third parties, such as data storage vendors and payroll services. 

6. The Illinois Legislature has found that “biometrics are unlike other unique 

identifiers that are used to access finances or other sensitive information. For example, even 

sensitive information like Social Security numbers can be changed. Biometrics, however, are 

biologically unique to each individual and, once compromised, such individual has no recourse, is 

at a heightened risk for identity theft, and is likely to withdraw from biometric facilitated 

transactions.” 740 ILCS 14/5. The risk is compounded when a person’s biometrics are also 

associated with their other personally identifiable information. 

7. The deprivation of the statutory rights conferred by BIPA constitutes the actual 

injuries the Illinois Legislature sought to prevent.

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

Defendants’ conduct in violating Plaintiff’s state biometric privacy rights.

9. On Plaintiff’s own behalf, and on behalf of the proposed Class defined below, 

Plaintiff seeks an injunction requiring Defendants to comply with BIPA, as well as an award of 

statutory damages to the Class members, together with costs and reasonable attorneys’ fees.

PARTIES

10. At all relevant times, Plaintiff Dawon A. Wordlaw has been a resident and a citizen 

of the state of Illinois and Cook County.

11. Defendant Enterprise Leasing Company of Chicago, LLC is a limited liability 

company organized under the laws of the state of Delaware, with its principal place of business in 

Lombard, Illinois, that conducts substantial business throughout Illinois, including in Cook 

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County, and is registered with and authorized by the Illinois Secretary of State to transact business 

in Cook County, Illinois.

12. Defendant Enterprise Holdings, Inc. is a corporation organized under the laws of 

the state of Delaware, with its principal place of business in St. Louis, Missouri, that conducts 

substantial business throughout Illinois, including Cook County, and is the corporate parent of 

Defendant Enterprise Leasing Company of Chicago, LLC. Defendant Enterprise Holdings, Inc.’s 

former Chief Executive Officer, Pamela Nicholson, current Executive Chairman, Andrew Taylor,

and current Chief Financial Officer, Rick Short, are registered with the Illinois Secretary of State 

as the managers of Enterprise Leasing Company of Chicago, LLC. 

JURISDICTION AND VENUE

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

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

because Defendants are doing business within this State and because Plaintiff’s claims arise out of 

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

Plaintiff’s biometric identifiers and/or biometric information in this State.

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

are doing business in Cook County and thus reside there under § 2-102. 

FACTS SPECIFIC TO PLAINTIFF

15. Defendants operate automobile leasing services in the state of Illinois. 

16. During the relevant time, Plaintiff worked for Defendants in Chicago, Illinois.

17. While Plaintiff worked for Defendants, Defendants implemented biometric 

scanning and time-tracking devices and technology to monitor and manage its workers’, including 

Plaintiff’s, time on the job.

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18. Plaintiff was required to provide biometric scans each time Plaintiff clocked in and 

clocked out of a shift at work. 

19. Plaintiff relied on Defendants to not only provide a lawful and legally compliant 

system, but to also disclose all material information regarding the technology and system, 

including all relevant retention, destruction, and dissemination policies. 

20. Further, on information and belief, Defendants disseminated information derived 

from the scanning of Plaintiff’s biometric identifiers to third parties, including vendors for 

timekeeping, data storage, and payroll purposes. 

21. Prior to taking Plaintiff’s biometrics, Defendants did not inform Plaintiff in writing 

that Plaintiff’s biometrics were being collected, stored, used, or disseminated, or publish any policy 

specifically about the collection, retention, use, deletion, or dissemination of biometrics. 

22. Defendants did not seek, and Plaintiff never provided, any written consent relating 

to the collection, use, storage, or dissemination of Plaintiff’s biometrics.

23. Prior to taking Plaintiff’s biometrics, Defendants did not make publicly available 

any written policy as to its biometric retention schedule, nor did Defendants disclose any 

guidelines for permanently destroying the collected biometrics. 

24. Additionally, Defendants did not obtain consent from Plaintiff for any 

dissemination of Plaintiff’s biometrics to third parties. 

25. To this day, Plaintiff is unaware of the status of the biometrics obtained by 

Defendants. Defendants have not informed Plaintiff whether they still retain Plaintiff’s biometrics, 

and if so, for how long they intend to retain such information without Plaintiff’s consent.

26. By failing to comply with BIPA, Defendants have violated Plaintiff’s substantive 

state rights to biometric privacy.

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CLASS ALLEGATIONS

27. Plaintiff brings this action individually and on behalf of all similarly situated 

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

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

transmitted, or disseminated by or on behalf of Defendants within the state of 

Illinois at any time within the applicable limitations period. 

28. Excluded from the Class are any members of the judiciary assigned to preside over 

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

officers or directors.

29. Upon information and belief, there are scores, if not hundreds of members of the 

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

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

can be easily identified through Defendants’ personnel records.

30. Plaintiff’s claims are typical of the claims of the members of the Class Plaintiff 

seeks to represent, because the factual and legal bases of Defendants’ liability to Plaintiff and the 

other members are the same, and because Defendants’ conduct has resulted in similar injuries to 

Plaintiff and to the Class. As alleged herein, Plaintiff and the Class have all suffered damages as a 

result of Defendants’ BIPA violations and common law transgressions. 

31. There are many questions of law and fact common to the claims of Plaintiff and the 

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

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

a. Whether Defendants’ conduct is subject to BIPA;

b. Whether Defendants made available to the public a written policy that 

establishes a retention schedule and guidelines for destroying biometrics;

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

capturing, collecting, or otherwise obtaining their biometrics;

d. Whether Defendants 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 Defendants’ conduct violates BIPA;

f. Whether Defendants’ violations of the BIPA are willful or reckless; and

g. Whether Plaintiff and the Class are entitled to damages and injunctive relief.

32. Absent a class action, most members of the Class would find the cost of litigating 

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 in that it 

conserves the resources of the courts and the litigants and promotes consistency of adjudication.

33. Plaintiff will adequately represent and protect the interests of the members of the 

Class. Plaintiff has retained counsel with substantial experience in prosecuting complex litigation 

and class actions. Plaintiff and Plaintiff’s counsel are committed to vigorously prosecuting this 

action on behalf of the other members of the Class and have the financial resources to do so. 

Neither Plaintiff nor Plaintiff’s counsel have any interest adverse to those of the other members of 

the Class.

34. Defendants have acted and failed to act on grounds generally applicable to Plaintiff 

and the other members of the Class, requiring the Court’s imposition of uniform relief to ensure 

compatible standards of conduct toward the members of the Class and making injunctive or 

corresponding declaratory relief appropriate for the Class as a whole.

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COUNT I

Violation of the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq.

(On behalf of Plaintiff and the Class) 

35. Plaintiff incorporates the foregoing allegations as if fully set forth herein.

36. Defendants are each a private entity under BIPA.

37. BIPA requires private entities, such as Defendants, to obtain informed written 

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

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).

38. BIPA also requires that private entities in possession of biometric identifiers and/or 

biometric information establish and maintain a publicly available retention policy. An entity which 

possesses biometric identifiers or information must (i) make publicly available a written policy 

establishing a retention schedule and guidelines for permanent deletion of biometric information 

(entities may not retain biometric information longer than three years after the last interaction with 

the individual); and (ii) adhere to the publicly posted retention and deletion schedule. 

39. Plaintiff and the other Class members have had their “biometric identifiers,” 

namely their fingerprints, collected, captured, or otherwise obtained by Defendants. Plaintiff and 

the other Class members’ biometric identifiers were also used to identify them, and therefore 

constitute “biometric information” as defined by BIPA. 740 ILCS 14/10.

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40. Each instance Plaintiff and the other Class members were required to scan their 

fingerprints, Defendants captured, collected, stored, and/or used Plaintiff’s and the other Class 

members’ biometric identifiers or biometric information without valid consent and without 

complying with and, thus, in violation of BIPA. 

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

biometrics fails to comply with applicable BIPA requirements:

a. Defendants failed to inform Plaintiff and the members of the Class in writing 

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

or storage, as required by 740 ILCS 14/15(b)(1);

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

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

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

c. Defendants 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. Defendants failed to obtain a written release, as required by 740 ILCS 

14/15(b)(3);

e. Defendants failed to provide 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); and

f. Defendants failed to obtain informed consent to disclose or disseminate the 

Class’ biometrics, as required by 740 ILCS 14/15(d)(1).

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42. By obtaining and operating an employee timekeeping system which uses biometrics 

that was devoid of the privacy protections required by BIPA, Defendants profited from Plaintiff’s 

and the Class members’ biometric identifiers and biometric information in violation of 740 ILCS 

14/15(c). Defendants knew, or were reckless in not knowing, that the biometric systems used 

would be subject to the provisions of BIPA yet wholly failed to comply with the statute. 

43. By capturing, collecting, storing, using, and disseminating Plaintiff’s and the Class’ 

biometrics as described herein, Defendants denied Plaintiff and the Class their right to statutorily 

required information and violated their respective rights to biometric information privacy, as set 

forth in BIPA.

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

violation of BIPA and, alternatively, damages of $1,000 for each negligent violation of BIPA. 740 

ILCS 14/20(1)-(2).

45. Defendants’ violations of BIPA, a statute that has been in effect since 2008, were 

knowing and willful, or were at least in reckless disregard of the statutory requirements. 

Alternatively, Defendants negligently failed to comply with BIPA.

46. Accordingly, with respect to Count I, Plaintiff, individually and on behalf of the 

proposed Class, prays for the relief set forth below.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff, individually and on behalf of 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;

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b. Declaring that Defendants’ actions, as set forth herein, violate BIPA Sections 15(b) 

and 15(d);

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

Plaintiff and the Class by requiring Defendants to comply with BIPA;

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

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

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

pursuant to 740 ILCS 14/20(1); 

f. Awarding reasonable attorneys’ fees, costs, and other litigation expenses pursuant 

to 740 ILCS 14/20(3); 

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

h. Awarding such further and other relief as the Court deems just and equitable.

JURY DEMAND

Plaintiff requests trial by jury of all claims that can be so tried.

Dated: April 3, 2020 Respectfully submitted,

DAWON A. WORDLAW, individually and on 

behalf of all similarly situated individuals

By: /s/ Timothy P. Kingsbury

One of Plaintiff’s Attorneys

Timothy P. Kingsbury

Andrew T. Heldut

MCGUIRE LAW, P.C. (Firm ID: 56618)

55 W. Wacker Drive, 9th Fl.

Chicago, IL 60601

Tel: (312) 893-7002

tkingsbury@mcgpc.com

aheldut@mcgpc.com

Attorneys for Plaintiff and the Putative Class

FILED DATE: 4/3/2020 4:39 PM 2020CH03702

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 1 of 3

2120 - Served 2121 - Served

2220 - Not Served 2221 - Not Served

2320 - Served By Mail 2321 - Served By Mail

2420 - Served By Publication 2421 - Served By Publication

Summons - Alias Summons (08/01/18) CCG 0001 A

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

(Name all parties)

v.

Case No. 

SUMMONS ALIAS SUMMONS

To each Defendant:

YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of 

which is hereto attached, or otherwise file your appearance and pay the required fee within thirty

(30) days after service of this Summons, not counting the day of service. To file your answer or

appearance you need access to the internet. Please visit www.cookcountyclerkofcourt.org to initiate

this process. Kiosks with internet access are available at all Clerk’s Office locations. Please refer to

the last page of this 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 cannot be made, 

this Summons shall be returned so endorsed. This Summons may not be served later than thirty (30) 

days after its date.

Dawon A. Wordlaw, on behalf of a class,

Enterprise Leasing Company of Chicago, LLC, et. al.

2020-CH-03702

ENTERPRISE LEASING COMPANY OF CHICAGO, LLC

c/o CT CORPORATION SYSTEM 

208 SO LASALLE ST, SUITE 814

CHICAGO, IL 60604

FILED

4/27/2020 5:41 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH03702

9151563

Return Date: No return date scheduled

Hearing Date: No hearing scheduled

Courtroom Number: No hearing scheduled

Location: No hearing scheduled

 FILED DATE: 4/27/2020 5:41 PM 2020CH03702

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 2 of 3

Witness: 

DOROTHY BROWN, Clerk of Court

Date of Service: ___________

(To be inserted by officer on copy left with 

Defendant or other person):

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

create an account with an e-filing service provider. Visit http://efile.illinoiscourts.gov/service-providers.htm

to learn more and to select a service provider. If you need additional help or have trouble e-filing, visit http://

www.illinoiscourts.gov/FAQ/gethelp.asp, or talk with your local circuit clerk’s office.

Summons - Alias Summons (08/01/18) CCG 0001 B

Address: 

City: ____________________________

State: ____ Zip: ________

Telephone: ________________________

Primary Email: 

Atty. No.: 56618________________

Atty Name: Brendan Duffner 

Atty. for: Plaintiff

 

Chicago

IL 60601

312 893 7002

bduffner@mcgpc.com

55 West Wacker Drive, 9th Floor 

4/27/2020 5:41 PM DOROTHY BROWN

FILED DATE: 4/27/2020 5:41 PM 2020CH03702

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 3 of 3

 Richard J Daley Center

 50 W Washington

 Chicago, IL 60602

 District 2 - Skokie

 5600 Old Orchard Rd

 Skokie, IL 60077

 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

 District 6 - Markham

 16501 S Kedzie Pkwy

 Markham, IL 60428

 Domestic Violence Court

 555 W Harrison

 Chicago, IL 60607

 Juvenile Center Building

 2245 W Ogden Ave, Rm 13

 Chicago, IL 60602

 Criminal Court Building

 2650 S California Ave, Rm 526

 Chicago, IL 60608

Daley Center Divisions/Departments

 Civil Division

 Richard J 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

 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 J 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 J Daley Center

 50 W Washington, Lower Level

 Chicago, IL 60602

 Hours: 8:30 am - 4:30 pm

CLERK OF THE CIRCUIT COURT OF COOK COUNTY OFFICE LOCATIONS

FILED DATE: 4/27/2020 5:41 PM 2020CH03702

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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION

DAWON A. WORDLAW, individually 

and on behalf of all similarly situated 

individuals,

Plaintiff,

v.

ENTERPRISE LEASING COMPANY 

OF CHICAGO, LLC, a Delaware limited 

liability company; ENTERPRISE 

HOLDINGS, INC., a Missouri

corporation,

Defendants.

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No. 2020-CH-03702

Hon. Sanjay T. Tailor

PLAINTIFF’S MOTION FOR CLASS CERTIFICATION OR, ALTERNATIVELY, 

FOR A DEFERRED CLASS CERTIFICATION RULING PENDING DISCOVERY

Plaintiff Dawon A. Wordlaw, by and through the undersigned counsel, pursuant to 735 

ILCS 5/2-801, moves for entry of an order certifying the Class proposed below, appointing 

Plaintiff as Class Representative, and appointing Plaintiff’s attorneys as Class Counsel. 

Alternatively, Plaintiff requests, to the extent the Court determines further evidence is necessary 

to prove any element of 735 ILCS 5/2-801, that the Court defer consideration of this Motion 

pending a reasonable period to complete discovery. See, e.g., Ballard RN Center, Inc. v. Kohll’s 

Pharmacy & Homecare, Inc., 2015 IL 118644, at ¶¶ 42–43 (citing Damasco v. Clearwire Corp., 

662 F.3d 891, 896–97 (7th Cir. 2011). In support of Plaintiff’s Motion, Plaintiff submits the 

following Memorandum of Law.

Respectfully submitted,

Dated: April 27, 2020 By: /s/ Brendan Duffner

Timothy P. Kingsbury

FILED

4/27/2020 7:29 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH03702

9151763

Return Date: No return date scheduled

Hearing Date: No hearing scheduled

Courtroom Number: No hearing scheduled

Location: No hearing scheduled

 FILED DATE: 4/27/2020 7:29 PM 2020CH03702

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2

Andrew T. Heldut

Brendan Duffner

MCGUIRE LAW, P.C. (Firm ID: 56618)

55 W. Wacker Drive, 9th Fl.

Chicago, IL 60601

Tel: (312) 893-7002

tkingsbury@mcgpc.com

aheldut@mcgpc.com

bduffner@mcgpc.com

Counsel for Plaintiff and the Putative Class

FILED DATE: 4/27/2020 7:29 PM 2020CH03702

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3

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF’S

MOTION FOR CLASS CERTIFICATION OR, ALTERNATIVELY, FOR

A DEFERRED CLASS CERTIFICATION RULING PENDING DISCOVERY

This Court should certify a class of Illinois residents whose biometric identifiers and 

biometric information were captured, collected, stored, and used by Defendants Enterprise Leasing 

Company of Chicago, LLC and Enterprise Holdings, Inc. (collectively, “Enterprise” or 

“Defendants”). Defendants operate automobile leasing services. Defendants captured, collected, 

stored, and used their workers’ biometric information and identifiers in an attempt to track their 

time at work. And in so doing, the Defendants have violated Illinois law by obtaining, storing, and 

using this data without the employees’ proper consent, by failing to provide the workers with a 

retention schedule explaining how and when such biometric information will be used, stored, and 

destroyed, and by transmitting this information to third parties without the express consent of the 

plaintiffs and the putative class. 

After Plaintiff learned of Defendants’ wrongful conduct, Plaintiff commenced suit on 

behalf of a class of similarly situated individuals to bring an end to the Defendants’ capture, 

collection, storage and use of biometric identifiers and/or biometric information in violation of the 

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

for all persons injured by its conduct.

I. INTRODUCTION: BIPA

The Illinois Biometric Information Protection Act, or BIPA, is designed to protect 

individuals’ personal biometric information. Under BIPA, biometric identifiers include 

fingerprints, handprints and vocal identifiers; while biometric information can be defined as any 

information based on a biometric identifier, regardless of how it is converted or stored. (Complaint, 

“Compl.,” ¶ 1.) In recognition of the importance of the security of individuals’ biometrics, the 

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Illinois Legislature enacted BIPA, which provides, inter alia, that private entities, such as 

Defendants, may not obtain and/or possess an individual’s biometrics unless they: (1) inform that 

person in writing that biometric identifiers or information will be captured, collected, stored, or 

used; (2) inform that person in writing of the specific purpose and the length of term for which 

such biometric identifiers or biometric information is being captured, collected, stored, and used; 

(3) received a written release from the person for the collection of his or her biometric identifiers 

and/or information; and (4) publicly publish and make available a written retention schedule and 

guidelines for permanently destroying biometric identifiers and biometric information. 740 ILCS 

14/5. (Compl., ¶ 3.)

II. FACTUAL BACKGROUND

A. The Underlying Misconduct.

Defendants have taken the biometrics of scores, if not hundreds, of individuals within the 

state of Illinois. (Compl., ¶ 30.) During the relevant time period in the state of Illinois, Defendants 

implemented biometric fingerprint scanning and recognition technology to collect biometric 

information from their workers to track the exact “clock-in” and “clock-out” times of their 

workers, including from Plaintiff. (Compl., ¶ 2.) Each fingerprint extracted by the Defendants is 

biologically unique to the particular individual. (Compl., ¶ 6.) Defendants continue to use their 

biometric technology to capture, collect, and store Plaintiff’s and other Class members’ biometrics. 

(Compl., ¶ 40.)

However, Defendants failed to obtain informed consent from the individuals prior to 

capturing and collecting their biometric information, Defendants failed to provide individuals with 

a retention schedule and deletion policies detailing how and when Defendants would retain and 

destroy the individuals’ biometric information and/or biometric identifiers and, finally, Defendants 

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did not obtain consent to transmit or disseminate Plaintiff’s biometrics to third parties. (Compl., ¶ 

42.) On information and belief, Defendants do not have a policy of informing individuals, 

including Plaintiff, of what happens to their biometric information after it is collected and obtained, 

whether they still retain Plaintiff’s biometrics, and if they do, for how long they intend to retain 

such information without Plaintiff’s consent, whether the information is transmitted to a third party 

and, if so, which third party. Id. Despite their practice of taking the biometric information of every 

employee who uses their biometric technology, Defendants failed to comply with BIPA’s statutory 

requirements regarding collection of biometric identifiers and biometric information. (Compl., ¶ 

43.)

B. The Proposed Class

Plaintiff brings this action individually and on behalf of all similarly situated individuals 

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

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

transmitted, or disseminated by or on behalf of Defendants within the state of 

Illinois at any time within the applicable limitations period. 

(Compl., ¶ 28.) As explained below, the proposed Class satisfies each of the four requirements 

for certification under Section 2-801 of the Illinois Code of Civil Procedure—numerosity, 

commonality, adequacy of representation, and fair and efficient adjudication. A class action is not 

just appropriate here, it is also the only way that the members of the putative Class can obtain 

appropriate redress for Defendants’ unlawful conduct.

III. ARGUMENT

A. Standards for Class Certification

To obtain class certification, it is not necessary for a plaintiff to establish that she will 

prevail on the merits of the action. Eisen v. Carlisle & Jacquelin, 417 U.S. 156, 178 (1974) (“[T]he 

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question is not whether the plaintiff or plaintiffs have stated a cause of action or will prevail on the 

merits, but rather whether the requirements of Rule 23 are met.” (internal quotation marks and 

citation omitted)). As such, in determining whether to certify a proposed class, the Court should 

accept the allegations of the complaint as true. Ramirez v. Midway Moving & Storage, Inc., 378 

Ill. App. 3d 51, 53 (1st Dist. 2007). 

To proceed with a class action, the movant must satisfy the “prerequisites for the 

maintenance of a class action” set forth in Section 2-801 of the Illinois Code of Civil Procedure, 

which provides:

An action may be maintained as a class action in any court of this State and a party 

may sue or be sued as a representative party of the class only if the court finds:

(1) The class is so numerous that joinder of all members is 

impracticable.

(2) There are questions of fact or law common to the class, which 

common questions predominate over any questions affecting only 

individual members.

(3) The representative parties will fairly and adequately protect the 

interest of the class.

(4) The class action is an appropriate method for the fair and efficient 

adjudication of the controversy. 

735 ILCS 5/2-801. As demonstrated below, each prerequisite is established for the Class, and the 

Court should therefore certify the proposed Class.

Section 2-801 is modeled after Rule 23 of the Federal Rules of Civil Procedure and “federal 

decisions interpreting Rule 23 are persuasive authority with regard to questions of class 

certification in Illinois.” Avery v. State Farm Mut. Auto. Ins. Co., 216 Ill. 2d 100, 125 (Ill. 2005). 

Circuit courts have broad discretion in determining whether a proposed class meets the

requirement for class certification and ought to err in favor of maintaining class certification. 

Ramirez, 378 Ill. App. 3d at 53. While a court may rule on class certification without requiring 

further discovery, see Manual for Complex Litigation (Fourth) § 21.14, at 255 (2004), courts have 

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found that discovery is helpful prior to addressing a motion for class certification. See, e.g., Ballard 

RN Center, Inc. v. Kohll’s Pharmacy & Homecare, Inc., 2015 IL 118644, at ¶ 42 (“If the parties 

have yet to fully develop the facts needed for certification, then they can also ask the district court 

to delay its ruling to provide time for additional discovery or investigation.”) (quoting Damasco v. 

Clearwire Corp., 662 F.3d 891, 896 (7th Cir. 2011)).

All the prerequisites for class certification are satisfied here, even though Plaintiff has not 

yet had an opportunity to engage in and complete discovery. However, in the interests of 

establishing a more fully developed record before ruling on class certification issues, the Court 

should defer ruling on this Motion pending the completion of discovery and submission of 

supplemental briefing. 

B. The Numerosity Requirement is Satisfied

The first step in certifying a class is a showing that “the class is so numerous that joinder 

of all members is impracticable.” 735 ILCS 5/2-801(1). This requirement is met when “join[ing] 

such a large number of plaintiffs in a single suit would render the suit unmanageable and, in 

contrast, multiple separate claims would be an imposition on the litigants and the courts.” Gordon 

v. Boden, 224 Ill. App. 3d 195, 200 (1st Dist. 1991) (citing Steinberg v. Chicago Med. Sch., 69 

Ill.2d 320, 337 (Ill. 1977)). To satisfy this requirement a plaintiff need not demonstrate the exact 

number of class members but, must offer a good faith estimate as to the size of the class. Smith v. 

Nike Retail Servs., Inc., 234 F.R.D. 648, 659 (N.D. Ill. 2006). 

Plaintiff alleges that there are at least several scores, if not hundreds, of members in the 

Class. (Compl., ¶ 30.) Because definitive evidence of numerosity can only come from the records 

of Defendants and their agents, it is proper to rely upon the allegations of the Complaint in 

certifying the Class. See 2 A. Conte & H. Newberg, Newberg on Class Actions § 7.20, at 66 (stating 

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that where numerosity information is in the sole possession of the party opposing the class, courts 

generally rely on the complaint as prima facie evidence or defer ruling). 

Additionally, the members of the putative Class can be easily and objectively determined 

from Defendants’ records. Furthermore, it would be completely impracticable to join the claims 

of the members of the Class, because they are disbursed throughout Illinois, and because absent a 

class action, few members could afford to bring an individual lawsuit over the amounts at issue in 

this case, since each individual member’s claim is relatively small. See Gordon, 224 Ill. App. 3d 

at 200. Accordingly, the first prerequisite for class certification is met.

C. Common Questions of Law and Fact Predominate

The second requirement of Section 2-801(2) is met where there are “questions of fact or 

law common to the class” and those questions “predominate over any questions affecting only 

individual members.” 735 ILCS 5/2-801(2). Such common questions of law or fact exist when the 

members of the proposed class have been aggrieved by the same or similar misconduct. See Miner 

v. Gillette Co., 87 Ill.2d 7, 19 (Ill. 1981); Steinberg, 69 Ill.2d at 342. These common questions 

must also predominate over any issues affecting individual class members. See O-Kay Shoes, Inc. 

v. Rosewell, 129 Ill. App. 3d 405, 408 (1st Dist. 1984). 

Here, the claims of the Class members arise out of the same activity by Defendants, are 

based on the same legal theory, and implicate, among others, the following common issues: 

whether Defendants’ conduct is subject to BIPA; whether Defendants made available to the public 

a written policy that establishes a retention schedule and guidelines for destroying biometrics; 

whether Defendants obtained a written release from the Class before capturing, collecting, or 

otherwise obtaining their biometrics; whether Defendants provided a written disclosure that 

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

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collected, stored and used before taking their biometrics; whether Defendants’ conduct violates 

BIPA; whether Defendants’ violations of the BIPA are willful or reckless; and whether Plaintiff 

and the Class are entitled to damages and injunctive relief. (Compl., ¶ 32.) As alleged, and as will 

be shown through obtainable evidence, Defendants engaged in a common course of conduct by 

collecting, capturing, storing and/or or using the biometrics of Class members without retaining a 

written release and without providing a retention schedule to them or to the public. Any potential 

individualized issues remaining after common issues are decided would be de minimis. 

Accordingly, common issues of fact and law predominate over any individual issues, and Plaintiff 

have satisfied this hurdle to certification.

D. Adequate Representation

The third prong of Section 2-801 requires that “[t]he representative parties will fairly and 

adequately protect the interest of the class.” 735 ILCS 5/2-801(3). The class representative’s 

interests must be generally aligned with those of the class members, and class counsel must be 

“qualified, experienced and generally able to conduct the proposed litigation.” See Miner, 87 Ill.2d 

at 14; see also Eshaghi v. Hanley Dawson Cadillac Co., Inc., 214 Ill. App. 3d 995, 1000 (1st Dist. 

1991). The purpose of this adequacy of representation requirement is “to insure that all Class 

members will receive proper, efficient, and appropriate protection of their interests in the 

presentation of the claim.” Purcell & Wardrope Chtd. v. Hertz Corp., 175 Ill. App. 3d 1069, 1078 

(1st Dist. 1988).

In this case, Plaintiff has the exact same interests as the members of the proposed Class. 

Plaintiff has alleged that, like the other members of the Class, Plaintiff was subjected to 

Defendants’ biometric timekeeping technology and that Defendants captured, collected, and stored 

Plaintiff’s biometrics. Plaintiff has also alleged that Defendants did so without complying with 

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BIPA’s requirements. Plaintiff’s pursuit of this matter against Defendants demonstrates that 

Plaintiff will be a zealous advocate for the Class. Furthermore, proposed class counsel has 

regularly engaged in major complex and class action litigation in state and federal courts and have 

been appointed as class counsel in several complex consumer class actions. Accordingly, the 

proposed class representative and proposed class counsel will adequately protect the interests of 

the members of the Classes, thus satisfying Section 2-801(3).

E. Fair and Efficient Adjudication of the Controversy

The final requirement for class certification under 5/2-801 is met where “the class action 

is an appropriate method for the fair and efficient adjudication of the controversy.” 735 ILCS 5/2-

801(4). “In applying this prerequisite, a court considers whether a class action: (1) can best secure 

the economies of time, effort and expense, and promote uniformity; or (2) accomplish the other 

ends of equity and justice that class actions seek to obtain.” Gordon, 224 Ill. App. 3d at 203. In 

practice, a “holding that the first three prerequisites of section 2-801 are established makes it 

evident that the fourth requirement is fulfilled.” Gordon, 224 Ill. App. 3d at 204; Purcell & 

Wardrope Chtd., 175 Ill. App. 3d at 1079 (“The predominance of common issues [may] make a 

class action . . . a fair and efficient method to resolve the dispute.”). Because numerosity, 

commonality and predominance, and adequacy of representation have been satisfied in the instant 

case, it is “evident” that the appropriateness requirement is met as well.

Other considerations further support certification in this case. A “controlling factor in many 

cases is that the class action is the only practical means for class members to receive redress.” 

Gordon, 586 N.E.2d at 467; Eshaghi, 574 N.E.2d at 766 (“In a large and impersonal society, class 

actions are often the last barricade of...protection.”). A class action is superior to multiple 

individual actions “where the costs of litigation are high, the likely recovery is limited” and 

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11

individuals are unlikely to prosecute individual claims absent the cost-sharing efficiencies of a 

class action. Maxwell, 2004 WL 719278, at *6. This is especially true in cases involving data 

privacy violations and data breaches, which can involve significant injury to the those effected, 

but result in many small, individual claims. Here, absent a class action, most members of the Class 

would find the cost of litigating their statutorily-limited claims to be prohibitive, and multiple 

individual actions would be judicially inefficient. Id.

Certification of the proposed Class is necessary to ensure that Defendants’ conduct 

becomes compliant with BIPA, to ensure that the Class members’ privacy rights in their biometrics 

are sufficiently protected, and to compensate those individuals who have had their statutorilyprotected privacy rights violated and who have not been informed as to the status of their own 

biometric information. Were this case not to proceed on a class-wide basis, it is unlikely that any 

significant number of Class members would be able to obtain redress, or that Defendants would 

willingly implement the procedures necessary to comply with the statute. Thus, proceeding as a 

class action here is an appropriate method to fairly and efficiently adjudicate the controversy.

IV. CONCLUSION

For the foregoing reasons, the requirements of 735 ILCS 5/2-801 are satisfied. Plaintiff 

respectfully requests that the Court enter an Order certifying the proposed Class, appointing 

Plaintiff as Class Representative, appointing Plaintiff’s attorneys as Class Counsel, and awarding 

such additional relief as the Court deems reasonable. Alternatively, the Court should defer ruling 

on this Motion pending the completion of appropriate discovery and supplemental briefing.

Respectfully submitted,

Dated: April 27, 2020 By: /s/ Brendan Duffner

Timothy P. Kingsbury

Andrew T. Heldut

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12

Brendan Duffner

MCGUIRE LAW, P.C. (Firm ID: 56618)

55 W. Wacker Drive, 9th Fl.

Chicago, IL 60601

Tel: (312) 893-7002

tkingsbury@mcgpc.com

aheldut@mcgpc.com

bduffner@mcgpc.com

Counsel for Plaintiff and the Putative Class

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13

CERTIFICATE OF FILING

The undersigned, an attorney, hereby certifies that on April 27, 2020, a copy of Plaintiff’s 

Motion for Class Certification or, Alternatively, for a Deferred Class Certification Ruling Pending 

Discovery was filed electronically with the Clerk of Court using the e-filing system. 

/s/ Brendan Duffner

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 1 of 3

2120 - Served 2121 - Served

2220 - Not Served 2221 - Not Served

2320 - Served By Mail 2321 - Served By Mail

2420 - Served By Publication 2421 - Served By Publication

Summons - Alias Summons (08/01/18) CCG 0001 A

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

(Name all parties)

v.

Case No. 

SUMMONS ALIAS SUMMONS

To each Defendant:

YOU ARE SUMMONED and required to file an answer to the complaint in this case, a copy of 

which is hereto attached, or otherwise file your appearance and pay the required fee within thirty

(30) days after service of this Summons, not counting the day of service. To file your answer or

appearance you need access to the internet. Please visit www.cookcountyclerkofcourt.org to initiate

this process. Kiosks with internet access are available at all Clerk’s Office locations. Please refer to

the last page of this 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 cannot be made, 

this Summons shall be returned so endorsed. This Summons may not be served later than thirty (30) 

days after its date.

Dawon A. Wordlaw, on behalf of a class,

Enterprise Leasing Company of Chicago, LLC, et. al.

2020-CH-03702

ENTERPRISE HOLDINGS, INC.

c/o C T CORPORATION SYSTEM

120 S Central Ave 

St Louis, MO 63105

FILED

4/27/2020 5:37 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH03702

9151548

Return Date: No return date scheduled

Hearing Date: No hearing scheduled

Courtroom Number: No hearing scheduled

Location: No hearing scheduled

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 2 of 3

Witness: 

DOROTHY BROWN, Clerk of Court

Date of Service: ___________

(To be inserted by officer on copy left with 

Defendant or other person):

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

create an account with an e-filing service provider. Visit http://efile.illinoiscourts.gov/service-providers.htm

to learn more and to select a service provider. If you need additional help or have trouble e-filing, visit http://

www.illinoiscourts.gov/FAQ/gethelp.asp, or talk with your local circuit clerk’s office.

Summons - Alias Summons (08/01/18) CCG 0001 B

Address: 

City: ____________________________

State: ____ Zip: ________

Telephone: ________________________

Primary Email: 

Atty. No.: 56618________________

Atty Name: Brendan Duffner 

Atty. for: Plaintiff

 

Chicago

IL 60601

312 893 7002

bduffner@mcgpc.com

55 West Wacker Drive, 9th Floor 

4/27/2020 5:37 PM DOROTHY BROWN

FILED DATE: 4/27/2020 5:37 PM 2020CH03702

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Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 3 of 3

Richard J Daley Center

50 W Washington

Chicago, IL 60602

District 2 - Skokie

5600 Old Orchard Rd

Skokie, IL 60077

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

District 6 - Markham

16501 S Kedzie Pkwy

Markham, IL 60428

Domestic Violence Court

555 W Harrison

Chicago, IL 60607

Juvenile Center Building

2245 W Ogden Ave, Rm 13

Chicago, IL 60602

Criminal Court Building

2650 S California Ave, Rm 526

Chicago, IL 60608

Daley Center Divisions/Departments

Civil Division

Richard J 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

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 J 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 J Daley Center

50 W Washington, Lower Level

Chicago, IL 60602

Hours: 8:30 am - 4:30 pm

CLERK OF THE CIRCUIT COURT OF COOK COUNTY OFFICE LOCATIONS

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