Exhibit B

Case: 1:20-cv-03873 Document #: 1-2 Filed: 07/01/20 Page 1 of 15 PageID #:164
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 (2//) CCCH 0623

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION

Plaintiff

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

individually and on behalf of all others similarly situated,

CDW-Government, LLC; and Wynndalco Enterprises, LLC

✔

90236

Daniel M. Feeney/Miller Shakman Levine & Feldman

Plaintiffs

180 N. LaSalle St, Suite 3600

Chicago IL

60187

312.263.3700

dfeeney@millershakman.com

FILED

5/27/2020 2:39 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH04346

9333208

Return Date: No return date scheduled

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

Courtroom Number: 2601

Location: District 1 Court

 Cook County, IL FILED DATE: 5/27/2020 2:39 PM 2020CH04346

12-Person Jury

2020CH04346

Case: 1:20-cv-03873 Document #: 1-2 Filed: 07/01/20 Page 2 of 15 PageID #:165
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. 

CDW-GOVERNMENT, LLC; and 

WYNNDALCO ENTERPRISES, LLC, 

 Defendants 

)

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

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 Defendants CDW-Government, LLC (“CDW-G”) and Wynndalco 

Enterprises, LLC (“Wynndalco”) for redress of Defendants’ 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 this action in that Defendants are each a limited 

liability company formed pursuant to the laws of the State of Illinois with principal place of 

business in Illinois, and are alleged to have caused injury to citizens of Illinois through violations 

of BIPA committed in this State.

FILED DATE: 5/27/2020 2:39 PM 2020CH04346

2020CH04346

FILED

5/27/2020 2:39 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

2020CH04346

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2 

2. Venue is proper in Cook County because both Defendants 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. Defendants

6. Defendant CDW-Government, LLC is a limited liability company formed pursuant 

to the laws of the State of Illinois that does business in the State of Illinois, including in Cook 

County. 

7. Defendant Wynndalco Enterprises, LLC is a limited liability company formed 

pursuant to the laws of the State of Illinois that does business in the State of Illinois, including in 

Cook County. 

FACTUAL ALLEGATIONS

8. Clearview AI, Inc. (“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”) 

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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.

9. 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. Clearview AI 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.)

10. 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. 

11. 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. 

12. 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. 

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

platforms scraped by 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.

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14. 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 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.

15. Clearview AI’s created the Clearview AI App and Database for commercial 

purposes, including sale of the App and Database to customers in the State of Illinois. 

16. During the Class Period, Clearview AI authorized Defendants CDW-G and 

Wynndalco to license or sell access to the Clearview AI App and Database to customers based in 

Illinois and furnished and provided possession, control, dominion and access to the Clearview AI 

App and Database to Defendants CDW-G and Wynndalco so that Defendants could sell those 

products, for profit, to users in Illinois, which Defendants did. 

17. During the Class Period, Defendants CDW-G and Wynndalco, acting in concert 

and individually, possessed, marketed, and sold or otherwise profited in Illinois from the biometric 

identifiers and biometric information in the Clearview AI App and Database.

18. During the Class Period, Defendant CDW-G exercised dominion and control over 

and possessed the Clearview AI App and Database and Clearview AI’s technologies, and sold 

access to or otherwise profited from the biometric identifiers and biometric information therein in 

Illinois.

19. During the Class Period, Defendant Wynndalco exercised dominion and control 

over and possessed the Clearview AI App and Database and Clearview AI’s technologies, and sold 

access to or otherwise profited from the biometric identifiers and biometric information therein in 

Illinois.

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20. Defendant CDW-G, during the Class Period, worked with Clearview AI and 

Defendant Wynndalco to sell access to Clearview AI’s App, Database and technologies for use by 

persons based in Illinois, and profited from such conduct in Illinois. 

21. Defendant CDW-G, during the Class Period, working in concert with Clearview AI 

and Defendant Wynndalco, caused access to the Clearview AI App and Database to be delivered 

to users in Illinois for use in Illinois to conduct searches using the Clearview AI Database, and 

received payment and profited from such conduct. 

22. Defendant Wynndalco, during the Class Period, worked with Clearview AI and 

Defendant CDW-G to sell access to Clearview AI’s App, Database and technologies for use by 

persons based in Illinois, and profited from such conduct. 

23. Defendant Wynndalco, during the Class Period, working in concert with Clearview 

AI and Defendant CDW-G, caused access to the Clearview AI App and Database to be delivered 

to users in Illinois for use in Illinois to conduct searches using the Clearview AI Database, and 

received payment and profited from such conduct. 

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

authorization to use the Clearview AI App in Illinois by Defendants, 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 

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6 

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. 

25. During the Class Period, persons in Illinois were provided the Clearview AI App 

by Defendants, acting in concert or individually for their joint or individual profit, and conducted 

searches in Illinois on their mobile devices and computers of Plaintiffs’ and the Class’s biometric 

identifiers and biometric information in Clearview AI’s Database. 

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

or 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. 

27. 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.

28. During the Class Period, none of the Plaintiffs knew (or had reason to suspect) that 

their biometric identifiers or biometric information were contained in the Clearview AI Database. 

29. 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).

30. During the Class Period, Defendants, individually and through their joint efforts, 

exercised dominion and control over and possessed Plaintiffs’ biometric identifiers or biometric 

information and sold access to or otherwise profited from such biometric identifiers or biometric 

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

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CLASS ACTION ALLEGATIONS

31. 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, in the Clearview AI Database when Defendants 

sold access to the Clearview AI Database to users in Illinois at any time from 

January 1, 2019 to January 17, 2020 (the “Class Period”) and who suffered no 

injury from Defendants’ violations 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 

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

32. 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”).

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

can be identified through discovery. 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 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.

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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8 

34. 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 CDW-G was in possession of Plaintiffs’ and the Class’s 

biometric identifiers or biometric information during the Class Period;

b. Whether Defendant Wynndalco was in possession of Plaintiffs’ and the 

Class’s biometric identifiers or biometric information during the Class 

Period; 

c. Whether, during the Class Period, Defendant CDW-G sold access to or 

otherwise profited from Plaintiffs’ and the Class’s biometric identifiers or 

biometric information in Illinois; 

d. Whether, during the Class Period, Defendant Wynndalco sold access to or 

otherwise profited from Plaintiffs’ and the Class’s biometric identifiers or 

biometric information;

e. Whether, during the Class Period, Defendant CDW-G violated 

Section 15(c) of BIPA by selling access to or otherwise profiting from 

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

f. Whether, during the Class Period, Defendant Wynndalco violated 

Section 15(c) of BIPA by selling access to or otherwise profiting from 

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

g. Whether Defendant CDW-G’s violations of Section 15(c) of BIPA were 

committed intentionally, recklessly, or negligently; and 

h. Whether Defendant Wynndalco’s violations of Section 15(c) of BIPA were 

committed intentionally, recklessly, or negligently. 

35. 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 Defendants’ violations 

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

36. 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 no Defendant has defenses unique to Plaintiffs. Plaintiffs 

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9 

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.

37. 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.

38. 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.

CLAIM FOR RELIEF

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

(On Behalf of Plaintiffs and the Class)

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

40. During the Class Period, Defendants, acting individually and in concert for profit, 

sold access to or otherwise profited in Illinois from Plaintiffs’ and the Class’s biometric identifiers 

or biometric information included in the Clearview AI Database.

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

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

profit.

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10 

42. At all times mentioned herein, Defendant CDW-G was aware, or at a minimum 

recklessly failed to know, of the provisions of Section 15(c) of BIPA that prohibit a private entity 

in Illinois, such as CDW-G, from selling, leasing, trading, or otherwise profiting from a person’s 

biometric identifier or biometric information.

43. At all times mentioned herein, Defendant Wynndalco was aware, or at a minimum 

recklessly failed to know, of the provisions of Section 15(c) of BIPA that prohibit a private entity 

in Illinois, such as Wynndalco, from selling, leasing, trading, or otherwise profiting from a 

person’s biometric identifier or biometric information.

44. Defendant CDW-G, during the Class Period, intentionally sold access to or 

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

in violation of Section 15(c) of BIPA. 

45. Defendant Wynndalco, during the Class Period, intentionally sold access to or 

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

in violation of Section 15(c) of BIPA. 

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

by Defendants’ violations of Section 15(c) of BIPA.

47. 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 46. 

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, 

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11 

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

Counsel; 

b. Declaring that each Defendants’ actions, as set forth above, violate Section 15(c) 

of BIPA;

c. Declaring that each Defendants’ 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 each 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 each 

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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12 

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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13 

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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