IN
THE
UNITED
STATES
DISTRICT
COURTFOR
THE
SOUTHERN
DISTRICT
OF
ILLINOIS JOHN E. REDSTONE, KARL H.SCHULZ, and DEAN M. BASTILLA,individually, and on behalf of all otherssimilarly situated,Plaintiffs,vs.GOOGLE, INC.,Defendant. )))))))))))))) Cause No: 3:10-cv-00400-JPG -DGWCLASS ACTIONCOMPLAINT
COME NOW Plaintiffs, individually, and on behalf of all others similarly situated
,
byand through their undersigned counsel, on information and belief, and for their Complaintagainst Defendant GOOGLE INC. state as follows:
1.
Over the course of the last four years, Defendant has unlawfully interceptedprivate electronic communications while it engaged in a photographic survey of publicroadways. This practice violates federal law.
PARTIES, JURISDICTION AND VENUE
2.
John E. Redstone is a natural person and citizen and resident of the SouthernDistrict of Illinois.3.
Karl H. Schulz is a natural person and citizen and resident of the Southern Districtof Illinois.
24.
Dean M. Bastilla is a natural person and citizen and resident of the SouthernDistrict of Illinois.5.
All references to “Plaintiff(s)” throughout this Complaint are made on behalf of the named Plaintiffs and the proposed plaintiff class(es), and vice versa.6.
The amount in controversy in this action, as defined by 28 U.S.C. § 1332(d)(6),exceeds $5,000,000 exclusive of costs and interest.7.
Defendant is a citizen of California and Delaware as defined by 28 U.S.C. §1332(c) as it is a Delaware company with its principal place of business in California.8.
Defendant operates a number of interactive websites, such as Google Maps(maps.google.com), from datacenters located throughout the Country.9.
Defendant is a resident of the Southern District of Illinois as it is has ongoing andsystematic contacts with residents of the Southern District of Illinois. Defendant has, at allmaterial times, conducted business, including the operation of interactive websites with and thesale of advertising to residents of the Southern District of Illinois. Moreover, Defendant hassufficient minimum contacts with the State of Illinois such that the assumption of jurisdictionwill not offend traditional notions of fair play and substantial justice.10.
When reference in this Complaint is made to any act or omission of Defendant, itshould be deemed to mean that the officers, directors, agents, employees, or representatives of Defendant committed or authorized such act or omission, or failed to adequately supervise orproperly control or direct their employees while engaged in the management, direction,operation, or control of the affairs of Defendant, and did so while acting within the scope of theiremployment or agency.
3
STATEMENT OF FACTS
11.
Google Street View is a feature of Google Maps and Google Earth that providesphotographic views from various positions along many streets, roads and pathways throughoutthe world.12.
Google Street View displays images taken from a fleet of specially adapted cars.On each of these cars there are nine directional cameras for 360° views at a height of about 2.5meters, GPS units for positioning, three laser range scanners for the measuring of up to 50meters 180° in the front of the vehicle.13.
By December 9, 2008, Street View contained photographic coverage of all largeand most medium-sized urban areas and most major highways and connecting arteriesthroughout the 48 contiguous states.14.
From its beginning, Street View has drawn the scrutiny of privacy advocates. In2007, privacy advocates objected to Street View as it contained photographs of men leaving stripclubs, protesters at an abortion clinic, sunbathers in bikinis, and people engaging in activities thatalthough visible from public property in which they would objectively not wish to be accessibleto anyone with an internet connection.15.
Google countered these criticisms by arguing that as the photos taken from publicproperty the subjects of those pictures had no reasonable expectation of privacy. However,following the objections of privacy advocates, Google implemented policies meant to preventidentification of individuals and property photographed by its Street View vehicles.16.
In April 2010, however, Germany’s Federal Commissioner for Data Protection,Peter Schaar, discovered that Google’s Street View vehicles were collecting much more thanphotographs.
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Redstone v Google Complaint
Another class action lawsuit over the Google Street View capturing of wi-fi "payload" data
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