42.  Proposed Class Definition:  Plaintiff Calderon brings this action pursuant to  Federal Rules of Civil Procedure 23(b)(2) and 23(b)(3) on behalf of a class of similarly situated  individuals, defined as follows (the “Class”):  All Google Photos users located in Illinois for whom Google created  and stored a face template after May 28, 2015.   43.  Numerosity:  The number of persons within the Class is substantial, believed to  amount to millions of persons.  It is, therefore, impractical to join each member of the Class as a  named plaintiff.  Further, the size and relatively modest value of the claims of the individual  members of the Class renders joinder impractical.  Accordingly, utilization of the class action  mechanism is the most economically feasible means of determining and adjudicating the merits of  this litigation.   47.  Plaintiff incorporates the foregoing allegations as if fully set forth herein.   48.  The BIPA makes it unlawful for any private entity to, among other things, “collect,  capture, purchase, receive through trade, or otherwise obtain a person’s or a customer’s biometric  identifiers or biometric information, unless it first: (1) informs the subject . . . in writing that a  biometric identifier or biometric information is being collected or stored; (2) informs the subject . .  . in writing of the specific purpose and length of term for which a biometric identifier or biometric  information is being collected, stored, and used; and (3) receives a written release executed by the  subject of the biometric identifier or biometric information . . . .”  740 ILCS 14/15(b).   49.  Google is a corporation and thus qualifies as a “private entity” under the BIPA.  See  I.  Biometric Technology Implicates Consumer Privacy Concerns   Violation of 740 ILCS 14/1, et seq.  (On Behalf of Plaintiff and the Class)  