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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

DAVID MUTNICK, for himself and others 

similarly situated,

Plaintiff,

v.

CLEARVIEW AI, INC.; HOAN TON-THAT; 

RICHARD SCHWARTZ; and CDW 

GOVERNMENT LLC

Defendants.

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Case No. 20 C 512

Judge Sharon Johnson Coleman

Magistrate Judge Maria Valdez

ANTHONY HALL, on behalf of himself and 

all others similarly situated,

 Plaintiff,

 v.

 

CDW GOVERNMENT LLC, and 

CLEARVIEW AI, INC.,

Defendants.

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Case No. 20 C 846

Judge Sharon Johnson Coleman

Magistrate Judge Jeffrey Cummings 

DECLARATION OF RICHARD SCHWARTZ

I, Richard Schwartz, hereby declare: 

1. I am the President of Clearview AI, Inc. (“Clearview”). My current responsibilities 

at Clearview include managing sales. I have personal knowledge of the facts described below, and 

if called as a witness, could and would testify competently thereto. 

2. I am a resident of New York. I serve as the primary caregiver to a close relative 

who has a serious medical condition. Due to this commitment, I infrequently leave New York.

3. I do not reside, pay taxes, or own any property in Illinois. I do not have an Illinois 

driver’s license or an Illinois bank account. I have not traveled to Illinois in the past five years. 

Case: 1:20-cv-00512 Document #: 46-2 Filed: 04/27/20 Page 1 of 3 PageID #:274
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4. I have never traveled to Illinois to conduct Clearview business. 

5. Clearview is a Delaware corporation with its headquarters and principal place of 

business in New York. 

6. Clearview is a technology company that collects publicly available images on the 

internet and organizes them into a searchable database, which can then be searched on an app by 

licensed users. Clearview does not share biometric information with its users.

7. Clearview’s technology searches the “open web” and public sources for image files, 

and downloads the files and webpage URL into a database. Anyone with internet capability is 

able to access the files that Clearview collects for use in its database. The images collected by 

Clearview were accessible to Clearview from its place of business in New York.

8. Clearview has eight full-time employees, the majority of whom work in New York, 

and none of whom are in Illinois. 

9. The servers hosting the data necessary for Clearview’s business are located in New 

York. Some of Clearview’s servers are also located in New Jersey. The publicly available images 

collected by Clearview are stored on these servers. 

10. Clearview has no employees, real estate, servers, facilities, or offices in Illinois, nor 

is it registered to do business in Illinois.

11. Clearview does not target Illinois through advertising and marketing or the use of 

sales and service representatives. Clearview’s services and app are marketed and available 

nationwide. 

12. Litigation is pending against Clearview in the U.S. District Court for the Southern 

District of New York, including the cases Calderon v. Clearview AI, Inc., Burke v. Clearview AI,

Case: 1:20-cv-00512 Document #: 46-2 Filed: 04/27/20 Page 2 of 3 PageID #:275
Case: 1:20-cv-00512 Document #: 46-2 Filed: 04/27/20 Page 3 of 3 PageID #:276