Geolocation data providers (Office of the Attorney General

13 Communications
3 Files

Communications

From: Beryl Lipton

07/07/2021

Subject: Pennsylvania Right to Know Act Request: Geolocation data providers (Office of the Attorney General - Pennsylvania)

To Whom It May Concern:

The Electronic Frontier Foundation (EFF) seeks records describing the relationship between your agency and third-party providers of geolocation data. In particular, we seek records related to:
• the location data provider Gravy Analytics and its subsidiary Venntel
• Babel Street’s service Locate X.

For the purposes of this request, the term “geolocation data” refers to GPS data acquired from cell phone apps, connected vehicles, or other connected devices, or from third-party aggregators of such data, which pertains to the location of individual persons or devices, whether identified or de-identified.

We request the following records for the period between January 1, 2015 and the present:

- All contracts or written agreements between Office of the Attorney General - Pennsylvania, or consultants thereof, and Gravy Analytics, Venntel, or Babel Street;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with Office of the Attorney General - Pennsylvania relating to the use of geolocation data from Gravy Analytics, Venntel, or Babel Street;
- All technical documentation, guides, presentations, or policies describing access to, storage of, or use of geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All privacy policies, memoranda of understanding, data-sharing agreements, or terms of use applying to geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Office of the Attorney General - Pennsylvania and Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Office of the Attorney General - Pennsylvania and INRIX.

If your office or agency contracts with a company not named here for geolocation data, provision of the alternate organization and equivalent responsive materials would be greatly appreciated.

The requested documents will be made available to the general public. This request is being made in the public interest and 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.

Sincerely,

Beryl Lipton
Investigative Researcher, Electronic Frontier Foundation
beryl.lipton@eff.org

From: Muckrock Staff

07/14/2021

Subject: RE: Pennsylvania Right to Know Act Request: Geolocation data providers (Office of the Attorney General - Pennsylvania)

To Whom It May Concern:

I wanted to follow up on the following Pennsylvania Right to Know Act request, copied below, and originally submitted on July 7, 2021. Please let me know when I can expect to receive a response.

Thanks for your help, and let me know if further clarification is needed.

From: Office of the Attorney General - Pennsylvania

07/16/2021

Subject: RTK 2021-140 Lipton, Beryl Exec Ext

Ms. Lipton,

Please see attached.

Thank you.

Right to Know Law Office
Pennsylvania Office of Attorney General

The information transmitted is intended only for the person or entity to whom it is addressed and may contain confidential and/or privileged material. Any use of this information other than by the intended recipient is prohibited. If you receive this message in error, please send a reply e-mail to the sender and delete the material from any and all computers. Unintended transmissions shall not constitute waiver of any applicable attorney-client or any other applicable privilege. PA-OAG

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From: Office of the Attorney General - Pennsylvania

07/20/2021

Subject: RTK 2021-140, Lipton, Beryl

Ms. Lipton:

I have reviewed your request and have some follow-up questions. We can also have a call to discuss if you'd like. Your preference.

Our office does not have records concerning any of the named companies in your request. To that end, in request No. 6, you only seek written communications, emails, and attachments between our office and INRIX (as opposed to Requests 1-5 in which you seek many different things for the 3 other companies, Gravy Analytics, Venntel and Babel Street). In request No. 7, you seek any company not named within the request, for geolocation data, and "equivalent responsive materials.." Because you want different types of records in Request 1-5 vs. 6., I need you to clarify for me, what "equivalent responsive materials" you would like, with respect to Request No. 7.

Again, if you would like to have a call, I am happy to discuss. Otherwise, you may respond to this email.

Thank you.

Elizabeth K. Spangenberg
Deputy Attorney General
Legal Review Section
Office of Attorney General
717-497-7209

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From: Office of the Attorney General - Pennsylvania

07/22/2021

Subject: RE: RTK 2021-140, Lipton, Beryl

Ms. Lipton-

I received your voicemail message.

I am available late morning and all afternoon tomorrow. Please let me know a time to call you.

Thanks.

Elizabeth K. Spangenberg
Deputy Attorney General
Legal Review Section
Office of Attorney General
717-497-7209

From: Office of the Attorney General - Pennsylvania

07/30/2021

Subject: RE: RTK 2021-140, Lipton, Beryl

Ms. Lipton,

Please advise when you are available for a call to discuss the parameters of your request.

Thank you.

From: Office of the Attorney General - Pennsylvania

08/03/2021

Subject: RTL 2021-140 Lipton, Beryl

Hi Beryl-

Thanks for the call yesterday to help clarify your request.

We discussed that your request seeks information related to Geolocation Data companies that the OAG has contracted with. Although you stated you are interested in specifically the procurement or bidding process with these companies, we discussed that we will have to tackle that "procurement/bidding" topic in another right to know due to those items not being requested in the instant request.

We did discuss that perhaps those items may be revealed when our RTK team receives its documents to review and we can go from there with whether they fit within the parameters of your current RTK.

You also indicated you would be interested in some communications of companies that the OAG may use for geolocation data tracking, but not all communications. We discussed that the subjective nature of this requirement would be difficult to apply as the RTK team conducts an objective review of the records in OAG's possession; there is no way for us to parse out what you may be interested in and may not be.

Once the review is complete we will either touch base with you, or provide you with our final response.

Thanks for your time.

Liz

Elizabeth K. Spangenberg
Deputy Attorney General
Legal Review Section
Office of Attorney General
717-497-7209

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LIPTON 2021-140 PA RTK Req: Geolocation data providers
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From: Beryl Lipton

08/03/2021

Subject: RE: Pennsylvania Right to Know Act Request #2021-140

Hello, Liz —

Thank you so much for this follow up on our phone call. I really appreciate your office's diligence and communication as you process this request, and I hope you'll let me know if there are any other clarifications that I can provide. Best of luck on the rest of your week, and I'll look forward to hearing from you again.

Warmly,
Beryl

From: Office of the Attorney General - Pennsylvania

08/05/2021

Subject: RE: [ EXTERNAL ] RE: Pennsylvania Right to Know Act Request #2021-140

Hi Beryl,

Can you give me a call at your earliest convenience?

We need to discuss the parameters of your request at the earliest time possible.

I am generally available to take your call.

Thanks.

Liz
717-497-7209

From: Office of the Attorney General - Pennsylvania

08/16/2021

Subject: Re: [ EXTERNAL ] RE: Pennsylvania Right to Know Act Request #2021-140

Hi Beryl,

I am sorry we have not been able to connect.

I called you 8/6 to discuss narrowing the search terms and have not heard back; your current request has flagged over 60,000 records. Our office is going to need additional time to process this.

Would you consider withdrawing the current right-to-know request? We can start over, as we discussed earlier this month, with a new Request that is more detailed and targeted?

Please let me by reply to this email, whether you would like to withdraw the current request.

Otherwise, we need to discuss the parameters of this request and need additional time.

Thank you!

Elizabeth Spangenberg
Deputy Attorney General
Legal Review Section
717-497-7209

From: Office of the Attorney General - Pennsylvania

09/15/2021

Subject: RTK 2021-140, Lipton, Beryl Exec Response

Ms. Lipton,

Please see attached.

Thank you,

Right to Know Law Office
Pennsylvania Office of Attorney General

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07/16/2021

LIPTON, BERYL 2021-140 Exec Extension
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08/03/2021

LIPTON 2021-140 PA RTK Req: Geolocation data providers
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09/15/2021

LIPTON BERYL 2021-140 Exec Response
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