EXHIBIT 1 

Case: 1:20-cv-03843 Document #: 1-1 Filed: 06/30/20 Page 1 of 15 PageID #:8
Dorothy Brown, Clerk of the Circuit Court of Cook County, Illinois

cookcountyclerkofcourt.org

Page 1 of 1

Chancery Division Civil Cover Sheet

General Chancery Section (02/19/20) CCCH 0623

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION

Plaintiff

v.

Defendant

Case No:

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CHANCERY DIVISION CIVIL COVER SHEET

GENERAL CHANCERY SECTION

0005 Administrative Review

0001 Class Action

0002 Declaratory Judgment

0004 Injunction

0007 General Chancery

0010 Accounting

0011 Arbitration

0012 Certiorari

0013 Dissolution of Corporation

0014 Dissolution of Partnership

0015 Equitable Lien

0016 Interpleader

0017

0018

0019

0020

0021

0022

0023

0024

0025

0026

0050

Mandamus

Ne Exeat

Partition

Quiet Title

Quo Warranto

Redemption Rights

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Rescission of a Contract

Specific Performance

Trust Construction

Internet Take Down Action (Compromising Images)

Other (specify) ____________________________

Pro Se Only: I have read and agree to the terms of the Clerk’s

Clerk’s Office Electronic Notice Policy and 

choose to opt in to electronic notice from the 

Clerk’s office for this case at this email address:

Email:

Atty. No.: ________________ Pro Se 99500

Atty Name:

Atty. for:

Address:

City: ____________________________ State: ____

Zip: ________

Telephone: ________________________

Primary Email:

Melissa Thornley, Deborah Benjamin-Koller, and Josue Herrera, 

individually and on behalf of all others similarly situated,

Clearview AI, Inc. ✔

90236 Daniel M. Feeney/Miller Shakman Levine & Feldman Plaintiffs 180 N. LaSalle St, Suite 3600 Chicago IL 60187312.263.3700 dfeeney@millershakman.com

FILED

5/27/2020 2:03 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH04348

9314164

Return Date: No return date scheduled

Hearing Date: 9/24/2020 10:00 AM - 10:00 AM

Courtroom Number: 2510

Location: District 1 Court

 Cook County, IL FILED DATE: 5/27/2020 2:03 PM 2020CH04348

Case: 1:20-cv-03843 Document #: 1-1 Filed: 06/30/20 Page 2 of 15 PageID #:9 12-Person Jury
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS 

COUNTY DEPARTMENT, CHANCERY DIVISION

MELISSA THORNLEY, DEBORAH 

BENJAMIN-KOLLER, and JOSUE HERRERA, 

individually and on behalf of all others similarly 

situated,

 Plaintiffs,

 v. 

CLEARVIEW AI, INC. 

 Defendant 

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No. ____________________ 

JURY TRIAL DEMANDED

CLASS ACTION COMPLAINT

Plaintiffs Melissa Thornley, Deborah Benjamin-Koller, and Josue Herrera (“Plaintiffs”), 

individually and on behalf of all others similarly situated (collectively, the “Class”), bring the 

following Class Action Complaint pursuant to Sections 2-801 and 2-802 of the Illinois Code of 

Civil Procedure against Defendant Clearview AI, Inc. (“Clearview AI” or “Defendant”) for redress 

of Defendant’s improper sales in Illinois, for profit, of software technology containing, and 

allowing users to search, a database of Plaintiffs’ and the Class’s biometric identifiers and 

biometric information, in violation of Section 15(c) of the Illinois Biometric Information Privacy 

Act, 740 ILCS 14/1 et seq. (“BIPA” or the “Act”). 

JURISDICTION AND VENUE

1. This Court has jurisdiction over Defendant in that Clearview AI has conducted the 

following business in Illinois and has engaged in the following conduct in violation of BIPA in the 

State of Illinois during the Class Period (as defined below in Paragraph 25):

a. Defendant Clearview AI has actively marketed its products at issue in this 

lawsuit – the Clearview AI App (as defined in Paragraph 7 below), the 

Clearview AI Database (as defined in Paragraph 7 below) and the software 

technology Clearview AI has developed to enable users of the Clearview AI 

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App to search the Clearview AI Database – to prospective customers in 

Illinois including (without limitation) by delivering proposals, quotes and 

other marketing communications to prospective customers in Illinois; 

negotiating with prospective customers based in Illinois; offering trial use 

of the App and Database, and, on information and belief, through in-person 

meetings and telephone and email communications with prospective 

customers and co-marketers in Illinois;

b. Defendant Clearview AI has, for profit, directly or through third parties, 

entered into agreements with customers based in Illinois for the use of the 

Clearview AI App in Illinois to search the Clearview AI Database;

c. Defendant Clearview AI has received payments from customers based in 

Illinois for the customers’ licensing and use of the Clearview AI App in 

Illinois to search the Clearview AI Database; 

d. Defendant Clearview AI has, as a sales marketing technique, provided the 

Clearview AI App to persons in Illinois on a trial basis to search the 

Clearview AI Database;

e. Defendant Clearview AI has, for profit, sold its products at issue in this 

lawsuit to over 100 customers based in Illinois, licensing or otherwise 

authorizing such customers and their employees to use the Clearview AI 

App in Illinois to conduct searches of the Clearview AI Database;

f. Defendant Clearview AI has provided follow-up support services to 

licensed users of the Clearview AI App based in Illinois;

g. Defendant Clearview AI has advertised and promoted, or caused or 

approved the advertising and promotion of, its products in Illinois; 

h. Defendant Clearview AI has entered into one or more agreements with 

persons or businesses to market its products, including the Clearview AI 

App and Database, in Illinois, authorizing such persons or businesses to 

serve as its duly-authorized agents and representatives for such purpose and 

knowing and intending that such persons or businesses would market and 

provide the Clearview AI App to customers (and prospective customers) for 

use in Illinois to search the Clearview AI Database;

i. Defendant Clearview AI has, through its duly-authorized agents and 

representatives, actively marketed the Clearview AI App, the Clearview AI 

Database and the software technology it has developed to enable users of 

the Clearview AI App to search the Clearview AI Database, to prospective 

customers in Illinois including (without limitation) by delivering proposals, 

quotes and other marketing communications to prospective customers in 

Illinois; negotiating with prospective customers based in Illinois; and 

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through in-person meetings and telephone communications with its 

representatives and agents and prospective customers in Illinois; 

j. Defendant Clearview AI has, for profit, provided the Clearview AI App, the 

Clearview AI Database and its software technologies to third parties in 

Illinois to enable such third parties to market and deliver such products to 

persons and businesses in Illinois, knowing and intending that the 

Clearview AI App would be used to run searches of the Clearview AI 

Database in Illinois; and

k. Defendant Clearview AI has conducted searches of servers based in Illinois 

and downloaded photographs to its Database from servers based in Illinois.

2. Venue is proper in Cook County because Defendant conducted business during the 

Class Period in this State, and in particular in Cook County, and committed the statutory violations 

alleged herein in Cook County and throughout Illinois. 

PARTIES

A. Plaintiffs

3. At all times mentioned herein, including throughout the Class Period, Plaintiff 

Melissa Thornley has been, and is to date, a citizen of the State of Illinois, residing in Cook County. 

4. At all times mentioned herein, including throughout the Class Period, Plaintiff 

Deborah Benjamin-Koller has been, and is to date, a citizen of the State of Illinois, residing in 

Cook County. 

5. At all times mentioned herein, including throughout the Class Period, Plaintiff 

Josue Herrera has been, and is to date, a citizen of the State of Illinois, residing in Cook County. 

B. Defendant

6. Defendant Clearview AI, Inc. is a business incorporated under the laws of the State 

of Delaware that does business in the State of Illinois, including in Cook County. 

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FACTUAL ALLEGATIONS

7. Defendant Clearview AI is an artificial intelligence company founded in 2016 that 

secretly created a database of over three billion facial scans (the “Clearview AI Database” or 

“Database”) and a facial recognition application (the “Clearview AI App” or “App”) and 

technologies that enable App users in Illinois to identify individuals by comparing the individuals’ 

facial scans to the facial scans of individuals included in the Clearview AI Database.

8. Defendant Clearview AI created its Database of facial scans through the use of 

proprietary algorithms that enable it to convert photographs in the Database to biometric facial 

recognition identifiers. Defendant obtained the photographs for its Database by “scraping” 

photographs posted and accessible on the internet from, among other sources, social media 

platforms Facebook, Twitter, Instagram, and LinkedIn, video sharing platform YouTube, and 

payment platform Venmo. (“Scraping” is the automated extraction of data from websites.)

9. For a number of years prior hereto and to the present time, Plaintiff Thornley 

maintained public social media accounts containing accessible photographs of her facial image on 

the Facebook, Instagram, and LinkedIn social media platforms. 

10. For a number of years prior hereto and to the present time, Plaintiff BenjaminKoller maintained social media accounts containing accessible photographs of his facial image on 

the Facebook, Instagram, and Twitter social media platforms. 

11. For a number of years prior hereto and to the present time, Plaintiff Herrera 

maintained accounts containing accessible photographs of his facial image on the Facebook, 

Instagram, and LinkedIn social media platforms, the digital payment platform Venmo, and on the 

YouTube video-sharing platform. 

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12. Because Plaintiffs’ photographs were posted and accessible on one or more of the 

platforms scraped by Defendant Clearview AI, Plaintiffs’ photographs were collected into the 

Clearview AI Database, converted to biometric facial recognition identifiers and maintained in the 

Database during the Class Period in both their original and biometric formats.

13. Similarly, the photographs of the millions of other Illinois residents in the Class 

were posted and accessible on one or more of the platforms scraped by Defendant Clearview AI, 

and, as a result, collected into the Clearview AI Database, converted to biometric facial recognition 

identifiers and maintained in the Database during the Class Period in both their original and 

biometric formats.

14. During the Class Period, Defendant Clearview AI owned and possessed and offered 

for sale in Illinois the Clearview App and Database (and Clearview AI’s supporting technologies) 

and furnished and provided possession, control, dominion and access to its App and Database to 

third parties in Illinois, for sale to customers in Illinois.

15. During the Class Period, Defendant Clearview AI, directly and through its thirdparty agents and representatives, sold access to Plaintiffs’ and the Class’ biometric identifiers and 

biometric information in the Clearview AI App and Database to over 100 customers based in 

Illinois or otherwise profited in Illinois from such biometric identifiers and biometric information.

16. During the Class Period, Defendant Clearview AI, for profit, directly or through 

third parties, licensed or otherwise authorized persons, businesses and other entities based in 

Illinois to use the Clearview AI App in Illinois to search the Clearview AI Database to identify 

individuals whose photographs were scraped to the Database and converted to biometric 

identifiers.

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17. During the Class Period, Defendant Clearview AI, for profit, authorized third 

parties to license or sell access to the Clearview AI App and Database to persons and business 

based in Illinois and provided the Clearview AI App and Database to such third parties for such 

purpose. 

18. During the Class Period, persons in Illinois, who were provided access and 

authorization to use the Clearview AI App in Illinois by Defendant, used the Clearview AI App in 

Illinois to identify unknown individuals (or confirm the identity of known individuals) by utilizing 

the following process: the App user in Illinois has uploaded a photograph of an individual the user 

is seeking to identify; Clearview AI’s facial recognition technologies scanned the face in the 

uploaded photograph and converted the facial geometries of the individual pictured in the 

photograph into mathematical formulas or “vectors;” Clearview AI’s technologies then identified 

the individual in the photograph by comparing the newly-created facial geometries with facial 

vectors of individuals whose photographs had previously been stored and converted to biometric 

form in Clearview AI’s Database; the Clearview AI App then displayed all photographs in the 

Clearview AI’s Database of the matched individual to the App user. 

19. During the Class Period, persons in Illinois who were, for profit, provided the 

Clearview AI App by Defendant conducted searches in Illinois on their mobile devices and 

computers of Clearview AI’s Database. 

20. Plaintiffs are unaware of any user who uploaded photographs of any of the Plaintiffs

nor who sought to identify any of the Plaintiffs by using the Clearview AI App during the Class 

Period. It is highly probable that no user has uploaded photographs of any of the Plaintiffs nor 

sought to identify any of the Plaintiffs by using the Clearview AI App during the Class Period. 

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21. During the Class Period, Plaintiffs’ biometric identifiers or biometric information 

in the Clearview AI App were not disclosed to any users of the Clearview AI App or to any thirdparties. 

22. During the Class Period, none of the Plaintiffs or Class members knew (or had 

reason to suspect) that their biometric identifiers or biometric information were contained in the 

Clearview AI Database. 

23. Section 15(c) of BIPA prohibits a private entity in possession of biometric 

identifiers or biometric information from selling, leasing, trading, or otherwise profiting in Illinois 

from a person’s biometric identifier or biometric information. 740 ILCS 14/15(c). 

24. During the Class period, Defendant Clearview AI, individually and through its 

agents and representatives, sold access to the Clearview AI Database containing Plaintiffs’ 

biometric identifiers or biometric information to customers in Illinois or otherwise profited from 

Plaintiffs’ biometric identifiers or biometric information in Illinois in knowing violation of 

Section 15(c) of BIPA.

CLASS ACTION ALLEGATIONS

25. Plaintiffs bring this action pursuant the Illinois Code of Civil Procedure, 735 ILCS 

5/2-801, on their own behalf and as representatives of all other similarly-situated individuals, 

defined as follows (the “Class”): 

All current Illinois citizens whose biometric identifiers or biometric information

were, without their knowledge, included in the Clearview AI Database at any time 

from January 1, 2016 to January 17, 2020 (the “Class Period”) and who suffered no 

injury from Defendant’s violation of Section 15(c) of BIPA other than statutory 

aggrievement in that there is no evidence that during the Class Period: (i) a 

photograph of the Class member was ever uploaded to the Clearview AI App by 

any user of the Clearview AI App; (ii) any user of the Clearview AI App sought to 

use the Clearview AI App and Database to identify them; and (iii) their biometric 

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identifiers or biometric information in the Clearview AI Database were never 

disclosed to any users of the Clearview AI App or any third-parties.

1

26. This action is properly maintained as a class action under 735 ILCS 5/2-801 

because: (1) the class is so numerous that joinder of all member is impracticable (“Numerosity”); 

(2) there are questions of law or fact that are common to the class (“Commonality”); (3) Plaintiffs’ 

claims are typical of the claims of the class (“Typicality”); and (4) Plaintiffs will fairly and 

adequately protect the interest of the class (“Adequate Representation”).

27. Numerosity. The Class likely consists of millions of individuals, and the members 

can be identified through Defendant’s records. The exact number of members of the Class is 

unknown and unavailable to Plaintiffs at this time, but Facebook, Inc., one of the social media 

platforms scraped by Defendant Clearview AI, has recently disclosed that it has approximately 

6 million Illinois residents with photographs on its platform. Individual joinder in this case is 

impracticable.

28. Predominant Common Questions. The Class’s claims present common questions 

of law and fact and those questions predominate over any questions that may affect individual 

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

a. Whether Defendant Clearview AI was in possession of Plaintiffs’ and the 

Class’s biometric identifiers or biometric information during the Class 

Period; 

b. Whether, during the Class Period, Defendant Clearview AI sold access to 

Plaintiffs’ and the Class’s biometric identifiers or biometric information to 

customers in Illinois or otherwise profited from Plaintiffs’ and the Class’s 

biometric identifiers or biometric information in Illinois;

c. Whether, during the Class Period, Defendant Clearview AI violated Section 

15(c) of BIPA; and 

1

 Plaintiffs have defined the Class based on currently available information and reserve the 

right to amend the definition of the Class, including, without limitation, the Class Period.

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d. Whether Defendant Clearview AI’s violations of Section 15(c) of BIPA 

were committed intentionally, recklessly, or negligently. 

29. Typicality. Plaintiffs’ claims are typical of the claims of the other members of the 

proposed Class. Plaintiffs and Class members were aggrieved as a result of Defendant’s violations 

of Section 15(c) of BIPA in a manner that is uniform across the Class.

30. Adequate Representation. Plaintiffs have and will continue to fairly and 

adequately represent and protect the interests of the Class. Plaintiffs have retained counsel that is 

competent and experienced in complex litigation and class actions. Plaintiffs have no interest that 

is antagonistic to those of the Class, and Defendant has no defenses unique to Plaintiffs. Plaintiffs 

and Plaintiffs’ counsel are committed to vigorously prosecuting this action on behalf of the 

members of the Class, and they have the resources to do so. Neither Plaintiffs nor Plaintiffs’ 

counsel have any interest adverse to those of the other members of the Class.

31. Superiority. A class action is superior to other available methods for the fair and 

efficient adjudication of this controversy and joinder of all members of the Class is impracticable. 

It would be unduly burdensome to the Court for each class member to pursue their claims 

individually. This proposed class action presents fewer management difficulties than individual 

litigation and provides the benefits of single adjudication, economies of scale, and comprehensive 

supervision by a single court. Class treatment will create economies of time, effort, and expense 

and promote uniform decision-making.

32. Plaintiffs reserve the right to revise the foregoing class allegations and definitions 

based on facts learned and legal developments following additional investigation, discovery, or 

otherwise.

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CLAIM FOR RELIEF

Violations of Section 15(c) of the Illinois Biometric Information Privacy Act

(On Behalf of Plaintiffs and the Class)

33. Plaintiffs incorporate the foregoing allegations as if fully set forth herein.

34. During the Class Period, Defendant, acting for profit, individually and through its 

agents and representatives, sold access to Plaintiffs’ and the Class’s biometric identifiers or 

biometric information in the Clearview AI Database to customers based in Illinois or otherwise 

profited in Illinois from Plaintiffs’ and the Class’s biometric identifiers or biometric information 

included in the Clearview AI Database.

35. Were it not for the inclusion of Plaintiffs’ and the Class’s biometric identifiers or 

biometric information in the Clearview AI Database, Defendant would not have been able to so 

profit.

36. At all times mentioned herein, Defendant Clearview AI was aware of the provisions 

of Section 15(c) of BIPA that prohibit a private entity in Illinois, such as Clearview AI, from 

selling, leasing, trading, or otherwise profiting in Illinois from a person’s biometric identifier or 

biometric information.

37. Defendant Clearview AI, during the Class Period, intentionally sold access to 

Plaintiffs’ and the Classes biometric identifiers or biometric information to customers in Illinois 

or otherwise profited in Illinois from Plaintiffs’ and the Classes biometric identifiers or biometric 

information, in violation of Section 15(c) of BIPA. 

38. Pursuant to Section 20 of BIPA, Plaintiffs and the Class are statutorily aggrieved 

by Defendant’s violations of Section 15(c) of BIPA. 

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39. During the Class Period, none of the Plaintiffs nor any Class Members suffered any 

injury as a result of the violations of Section 15(c) of BIPA other than the statutory aggrievement 

alleged in Paragraph 38. 

WHEREFORE, Plaintiffs on behalf of themselves and the proposed Class respectfully 

request that the Court enter an order:

a. Certifying this case as a class action on behalf of the Class defined above, 

appointing Plaintiffs Melissa Thornley, Deborah Benjamin-Koller, and Josue 

Herrera as Class Representatives, and appointing Silver Golub & Teitell LLP, 

Miller Shakman Levine & Feldman LLP, and Forde & O’Meara, LLP as Class 

Counsel; 

b. Declaring that Defendant’s actions, as set forth above, violate Section 15(c) of 

BIPA;

c. Declaring that Defendant’s actions, as set forth above, were intentional and/or 

reckless;

d. Awarding statutory damages of $5,000 per Plaintiff and Class member for each 

intentional and/or reckless violation of Section 15(c) by the Defendant pursuant to 

740 ILCS 14/20(2) or, in the alternative, statutory damages of $1,000 per Plaintiff 

and Class member for each negligent violation of Section 15(c) by the Defendant 

pursuant to 740 ILCS 14/20(1); 

e. Awarding Plaintiffs and the Class their reasonable attorneys’ fees and costs and 

other litigation expenses pursuant to 740 ILCS 14/20(3); 

f. Awarding Plaintiffs and the Class pre- and post-judgment interest, to the extent 

allowable; and

g. Awarding such other and further equitable relief as BIPA, equity, and justice may 

require. 

DEMAND FOR JURY TRIAL

Plaintiffs demand a trial by jury for all issues so triable.

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Dated: May 27, 2020

Daniel M. Feeney

Zachary J. Freeman

Miller Shakman Levine & Feldman LLP

Firm ID: 90236

180 North LaSalle Street, Suite 3600 

Chicago, IL 60601

Tel. (312) 263-3700 

Fax (312) 263-3270 

Email: dfeeney@millershakman.com

 zfreeman@millershakman.com

David S. Golub (pro hac vice forthcoming) 

Steven L. Bloch (pro hac vice forthcoming) 

Ian W. Sloss (pro hac vice forthcoming) 

Silver Golub & Teitell LLP

184 Atlantic Street

Stamford, CT 06901 

Tel. (203) 325-4491 

Fax (203) 325-3769 

Email: dgolub@sgtlaw.com 

 sbloch@sgtlaw.com 

isloss@sgtlaw.com

Respectfully submitted,

MELISSA THORNLEY 

DEBORAH BENJAMIN-KOLLER

JOSUE HERRERA

/s/ Daniel M. Feeney 

One of their attorneys

Kevin M. Forde 

Brian P. O’Meara

Kevin R. Malloy 

Forde & O’Meara LLP

Firm ID: 64371

111 West Washington Street 

Suite 1100 

Chicago IL 60602 

(312) 641-1441 

(312) 641-1288 (fax) 

kforde@fordellp.com 

bomeara@fordellp.com 

kmalloy@fordellp.com 

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SUPREME COURT RULE 222(b) DAMAGES AFFIDAVIT

Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the 

undersigned certifies that this civil action seeks in excess of $50,000 on behalf of the Plaintiffs and the 

proposed Class. 

Dated: May 27, 2020

Daniel M. Feeney

Zachary J. Freeman

Miller Shakman Levine & Feldman LLP

Firm ID: 90236

180 North LaSalle Street, Suite 3600 

Chicago, IL 60601

Tel. (312) 263-3700 

Fax (312) 263-3270 

Email: dfeeney@millershakman.com

 zfreeman@millershakman.com

David S. Golub (pro hac vice forthcoming) 

Steven L. Bloch (pro hac vice forthcoming) 

Ian W. Sloss (pro hac vice forthcoming) 

Silver Golub & Teitell LLP

184 Atlantic Street

Stamford, CT 06901 

Tel. (203) 325-4491 

Fax (203) 325-3769 

Email: dgolub@sgtlaw.com 

 sbloch@sgtlaw.com 

isloss@sgtlaw.com

Respectfully submitted,

MELISSA THORNLEY 

DEBORAH BENJAMIN-KOLLER

JOSUE HERRERA

/s/ Daniel M. Feeney 

One of their attorneys

Kevin M. Forde 

Brian P. O’Meara

Kevin R. Malloy 

Forde & O’Meara LLP

Firm ID: 64371

111 West Washington Street 

Suite 1100 

Chicago IL 60602

(312) 641-1441 

(312) 641-1288 (fax) 

kforde@fordellp.com 

bomeara@fordellp.com 

kmalloy@fordellp.com 

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