Public Records Request

Mr. Hoover,

Pursuant to Tennessee law and Departmental rules, our Office requires proof of Tennessee citizenship prior to providing copies or inspection of public records. Proof can be furnished by one of the following:

1. Presentation of a valid Tennessee driver's license, or other state issued photographic ID that includes the your Tennessee address at the time of the request;

2. Submission of a request on business letterhead with the business' address in Tennessee. Records will be sent to the Tennessee address on the letterhead and not to any other address; or

3. Presentation of a valid Tennessee driver license or other state issued photographic ID that includes your Tennessee address prior to the inspection of records or you obtaining the records in person.

If you do not wish to provide proof in one of the methods mentioned above, you can also allow our office to verify your Tennessee citizenship in our driver license system. You will need to provide your driver license number to do this.

Please provide this information so that we may proceed with your request.

Mr. Hoover,

Under Tennessee law, our Department has 7 business days to furnish a response to your request. We are in the process of retrieving and reviewing possible records, which will need to be redacted prior to release. We will be in touch on or before the 7th business day, February 8, regarding the availability and accessibility of the responsive records.
[cid:image001.png@01D93648.B22DC6F0]
Tennessee Tower, 25th Floor
312 Rosa L. Parks Avenue, Nashville, TN 37243
tn.gov/safety

This e-mail message and any attachment contain information that may be legally privileged and confidential from the Legal Office of the Department of Safety. If you are not the intended recipient, you must not review, transmit, convert to hard copy, use or disseminate this e-mail or any attachments to it. If you have received this email in error, please immediately notify me by return e-mail or by telephone at 615-251-5285 and delete this message. Receipt by anyone other than the intended recipient is not a waiver of the attorney- client or work product privilege.

Good morning,

A response to each part of your request is highlighted below.

1. All communications, including financial and legal documents, between representatives of
the department and representatives of a company providing or discussing providing facial
recognition services to the department. Such companies may include but are not limited
to Clearview AI, Vigilant Solutions, Motorola, Amazon Rekognition, RealNetworks /
RealPlayer, Ever AI / Paravision, and Toshiba. Responsive records may include but are
not limited to invoices, expenditures, purchase, trials, licenses, contracts, MOUs, memos,
reports, and electronic communications. Do not limit your search to just emails. Please be
aware that Motorola recently acquired Vigilant Solutions so you may find records co-
mingled in that search.

This portion of your request must be denied on the grounds that this Department is not the custodian of any records. Please contact the Department of General Services for the documentation you seek. Further, any legal communications are protected by the attorney-client privilege and are considered attorney work product and are not subject to release.

2. All internal records mentioning facial recognition or companies providing those services
(such as the ones listed above). Responsive documents may include, but are not limited
to, training materials, manuals, policies, procedures, presentations, reports, memos,
electronic data processing records, and electronic communications. Please do not limit
your search to just emails.

This portion of your request must be denied on the grounds that any responsive records are confidential pursuant to Tennessee Code Annotated section 10-7-504(i) as release of the records and information contained therein poses a risk to operational vulnerabilities of the Department.

3. All communications between the police department and other law enforcement agencies
that mention facial recognition, facial recognition systems, or companies providing facial
recognition services. Examples of such records may include, but are not limited to,
agreements between departments or agencies for the sharing of facial recognition
technologies or databases. Responsive records may include but are not limited to
invoices, expenditures, purchase, trials, licenses, contracts, MOUs, memos, reports, and
electronic communications. Do not limit your search to just emails.
At minimum, in your search for records, you should search between the police
department and any fusion centers across the country. Further, we are aware that Clearview AI
has a policy of handing out free “demo” accounts which any police office may register for. Such
emails come in from a “@clearview.ai” email address but may also come from
richard@clearview.ai<mailto:richard@clearview.ai>, hoan@clearview.ai<mailto:hoan@clearview.ai>, jessica@clearview.ai<mailto:jessica@clearview.ai>, Marko@clearview.ai<mailto:Marko@clearview.ai>,
douglas@clearview.ai<mailto:douglas@clearview.ai>, help@clearview.ai<mailto:help@clearview.ai> or info@clearview.ai<mailto:info@clearview.ai>. Please search your email
systems for these domain names and, if possible, have your technical team do a “wildcard”
search for the domain i.e. *@clearview.ai<mailto:*@clearview.ai> in fulfilling this request.

This portion of your request must be denied because no responsive records exist.

Sincerely,
Casey Goggin