The Legal Aid Society filed this amicus brief in support of plaintiff private for-hire-vehicle (FHV) companies challenging the rules of the Taxi and Limousine Commission (TLC) for violating the privacy of their clients. The TLC is a city agency which collects data from all FHV companies, including taxis, Uber, Lyft, etc., including pick-up and drop-off location and time data for each ride. This data collection gives the government much more granular information about passengers and drivers, far more than necessary for the stated purposes, including ensuring fair working conditions. Because the TLC is a city agency, this data is subject to disclosure through FOIL, and people have shown how such a vast amount of surveillance can lead to serious privacy concerns, allowing anyone interested to piece together certain characteristics, habits, and even the identities of anyone involved. Ride data can reveal that a person visited a strip club, religious service, abortion clinic, or protest, and more intrusive patterns of their behavior over time, all without the person even knowing they are being tracked. The Legal Aid Society initially submitted a brief to the District Court in support of plaintiffs, seeking these TLC reporting requirements to be found unconstitutional in violation of the Fourth Amendment’s privacy guarantee. This brief supports the plaintiffs and urges the Second Circuit to reverse the District Court’s dismissal.