Springfield Police - Clearview

To Whom It May Concern:

Pursuant to the Illinois Freedom of Information Act., I hereby request the following records:

Clearview is a facial recognition vendor which used scraped social media photographs for a facial recognition database (source: https://www.nytimes.com/2020/01/18/technology/clearview-privacy-facial-recognition.html ). In the report by the New York Times, a legal opinion paid for Clearview stated that it "do[es] not violate the federal Constitution or relevant existing state biometric and privacy laws when using Clearview for its intended purpose.”

Separately, at least one detective at Springfield Illinois, April Smiddy (April's email is april.smiddy@springfield.il.us) emailed at least one detective in Gainsville Florida (email address ferraranj@cityofgainsville.org) on November 6th, 2019th with the subject like "Question". Therefore, Pursuant to Illinois FOIA, I request the following records:

- Any invoices with Clearview AI, procurement contracts or other payment between Springfield IL and Clearview. I further request all discussion about the purposes of purchasing, testing or evaluating Clearview.
- All discussion between April Smiddy and any other police officers with the keyword "Clearview". I have identified at least one email to search but *do not limit your search to just that email*. Please search all other emails, inboxes, documents, police reports and other similar locations where records may be reasonably located.
- Documents sufficient to show any investigations where Clearview may have been used to identify a suspect or a lead.

Illinois is subject to the Biometric Information Privacy Act, which includes a private cause of action for violating it, as recently decided by the Illinois Supreme Court. The privacy cause of action also includes the non-consensual collection by private actors. Therefore, the records in question are clearly in the public interest and the burden on the public body would be outweighed by the public interest in the information.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 5 business days, as the statute requires.

Sincerely,

Freddy Martinez