IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Chris Marron, an Individual, and Maryann 

Daker, an Individual, Individually and on 

Behalf of All Others Similarly Situated, 

Plaintiffs, 

v. 

Clearview AI, Inc., a Delaware 

Corporation, Hoan Ton-That, an 

Individual; Richard Schwartz, an 

Individual; and CDW Government LLC, 

an Illinois Company, 

Defendant. 

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Case No. 20-2989 

Hon. Sharon Johnson Coleman 

UNOPPOSED MOTION OF DEFENDANTS 

FOR AN EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND 

Defendants Clearview AI, Inc. (“Clearview”), Richard Schwartz, Hoan Ton-That 

(Clearview, Schwartz and Ton That, together the “Clearview Defendants”) jointly with CDW 

Government LLC (“CDW-G” and with the Clearview Defendants, the “Defendants”) respectfully 

move the Court for the entry of an Order extending the time for the Defendants to file an answer 

or otherwise respond to Plaintiffs’ Class Action Complaint, to and including July 30, 2020. In 

support of this unopposed Motion, the Defendants state as follows: 

1. Plaintiffs filed their Class Action Complaint on May 20, 2020. 

2. Clearview was served on or about May 27, 2020. CDW-G was served on or about 

May 29, 2020. Counsel for the Clearview Defendants have agreed to accept service for Schwartz 

and Ton-That. 

Case: 1:20-cv-02989 Document #: 17 Filed: 06/09/20 Page 1 of 4 PageID #:59
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3. Pursuant to Fed. R. Civ. P. 12, Clearview has until June 17, 2020, CDW-G has until 

June 19, 2020, and Schwartz and Ton-That will have until at least June 30, 2020 in which to answer 

or otherwise respond to the Class Action Complaint. 

4. There are two, related cases pending before the Court. Those cases are captioned 

Hall v. Clearview et al., No. 20-846 and Mutnick v. Clearview et al., No. 20-512. In both of those 

cases, the Defendants’ deadline for answering or otherwise responding to the relevant complaint 

is July 30, 2020. Also pending in the Hall and Mutnick cases is the Clearview Defendants’ motion 

to dismiss, or, in the alternative, to transfer. A ruling on that motion could impact the Clearview 

Defendants’ response to the Marron complaint. 

5. Given the nature of the claims, the complex facts and technical details that are 

implicated by this lawsuit, the fact that the Defendants currently have multiple, different response 

dates, the fact that two, related cases have a July 30, 2020 response deadline, and the fact that there 

is a pending motion which may impact the Marron litigation, the Defendants respectfully request 

an extension of time in which to serve their responsive papers in this action to and including July 

30, 2020. 

6. This is the Defendants’ first request for an extension of time in this matter. 

7. Counsel for the Clearview Defendants’ and counsel for CDW-G have separately 

communicated with Plaintiffs’ counsel regarding this motion. In response to both of those 

inquiries, Plaintiffs’ counsel indicated that they do not oppose the extension. 

8. The requested extension of time will not prejudice any party or delay this action. 

9. The Clearview Defendants submit this motion without waiving, and while 

expressly reserving, their rights to contest personal and subject matter jurisdiction in this litigation. 

Case: 1:20-cv-02989 Document #: 17 Filed: 06/09/20 Page 2 of 4 PageID #:60
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WHEREFORE, for the reasons set forth above, the Defendants respectfully request that 

the Court grant this motion and enter an Order extending the time for the Defendants to file their 

responsive papers, to and including July 30, 2020. 

Respectfully Submitted, June 9, 2020 

By: /s/ David P. Saunders 

Lee Wolosky (pro hac vice to be filed) 

Andrew J. Lichtman (pro hac vice to be filed)

JENNER & BLOCK LLP 

919 Third Avenue 

New York, New York 10022-3908 

Phone: (212) 891-1600 

lwolosky@jenner.com 

alichtman@jenner.com 

David P. Saunders 

Howard S. Suskin 

JENNER & BLOCK LLP 

353 North Clark Street 

Chicago, Illinois 60654 

Phone: (312) 222-9350 

hsuskin@jenner.com 

dsaunders@jenner.com 

Attorneys for Defendants Clearview AI, Inc., 

Richard Schwartz and Hoan Ton-That 

By: /s/ Joseph A Strubbe 

Joseph A. Strubbe 

Brian W. Ledebuhr 

Zachary J. Watters 

VEDDER PRICE P.C. 

222 North LaSalle Street 

Chicago, Illinois 60601 

Phone: 1 312 609 7500 

jstrubbe@vedderprice.com 

bledebuhr@vedderprice.com 

zwatters@vedderprice.com 

Attorneys for Defendant CDW 

Government LLC 

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CERTIFICATE OF SERVICE 

I certify that on June 9, 2020, I electronically filed the foregoing with the Clerk of Court 

using the CM/ECF system, which will then send a Notice of Electronic Filing to all counsel of 

record. 

/s/ _David P. Saunders__ 

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