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Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 1 of 10

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STEVEN A. ELLIS (SBN 171742)


sellis@goodwinlaw.com
SHAUNA E. WOODS (SBN 300339)
swoods@goodwinlaw.com
GOODWIN PROCTER LLP
601 S. Figueroa Street, 41st Floor
Los Angeles, CA 90017
Tel.: 213.426.2500
Fax.: 213.623.1673
GRANT P. FONDO (SBN 181530)
gfondo@goodwinlaw.com
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, CA 94025-1105
Tel.: 650.752.3100
Fax.: 650.853.1038
Attorneys for Proposed Intervenor
COINBASE, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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IN THE MATTER OF THE TAX


LIABILITIES OF:

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JOHN DOES, United States persons who, at


any time during the period January 1, 2013,
through December 31, 2015, conducted
transactions in a convertible virtual currency
as defined in IRS Notice 2014-21.

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Case No. 3:16-cv-06658-JSC


NOTICE OF MOTION AND MOTION OF
PROPOSED INTERVENOR COINBASE
INC. TO INTERVENE; MEMORANDUM
OF POINTS OF AUTHORITIES
Date:
Time:
Courtroom:
Judge:

February 16, 2017


9:00 a.m.
F (15th Floor)
Hon. Jacqueline Scott Corley

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ACTIVE/89292521.1

NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.


TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 2 of 10

NOTICE OF MOTION AND MOTION TO INTERVENE

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that on February 16, 2017 at 9:00 a.m., or as soon thereafter as

the matter may be heard before the Honorable Jacqueline Scott Corley, Magistrate Judge of the

United States District Court for the District of California San Francisco Division, located at 450

Golden Gate Avenue, San Francisco, California, Coinbase, Inc. (Coinbase) will and hereby does

move to intervene as of right (or, in the alternative, permissively) in the above-captioned

proceeding.
The motion to intervene is made on the grounds that Coinbase has an interest in the subject

Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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matter of this proceeding, and that disposition of the action may, as a practical matter, impair or

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impede Coinbases ability to protect that interest. Coinbases interest is not adequately

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represented by the existing parties. Specifically, the IRS has issued an extraordinarily broad John

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Doe summons to Coinbase that seeks (among other categories) information regarding every

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single transaction conducted by every single U.S.-based Coinbase account holder (no matter how

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large or small) for a three-year period. Proposed Intervenor Jeffrey K. Berns (a Coinbase account

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holder) has moved to intervene and to quash the summons on certain grounds, but Coinbase has

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strong arguments regarding why the summons should not be enforced that are separate from and in

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addition to the grounds stated by Mr. Berns. In the event that the motion of Mr. Berns to intervene

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in this proceeding is granted, Coinbase should also be allowed to intervene, and to present its own

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legal and factual arguments in opposition to the summons, before the Court makes its decision

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regarding enforcement and/or quashing the summons.

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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 3 of 10

Coinbases motion to intervene is made pursuant to Federal Rule of Civil Procedure 24 and

Civil Local Rules 7-1 through 7-6. The motion is based on this Notice of Motion and Motion, the

Memorandum of Points and Authorities, the pleadings and records in this action, and such other

materials and arguments as may be presented to the Court at or prior to the hearing.

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Respectfully submitted,

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Dated: January 11, 2017

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By: /s/ Steven A. Ellis


STEVEN A. ELLIS
sellis@goodwinlaw.com
GRANT P. FONDO
gfondo@goodwinlaw.com
SHAUNA E. WOODS
swoods@goodwinlaw.com
GOODWIN PROCTER LLP
Attorneys for Proposed Intervenor
COINBASE, INC.

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Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 4 of 10

MEMORANDUM OF POINTS AND AUTHORITIES

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Proposed Intervenor Coinbase, Inc. (Coinbase) respectfully submits this memorandum of


points and authorities in support of its motion to intervene.
FACTUAL AND PROCEDURAL HISTORY

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offers a range of services that allow account holders (individuals and businesses) to conduct

transactions using digital currencies. Coinbase is registered as a money services business with the

United States Department of the Treasury, Financial Crimes Enforcement Network (known as

FinCEN) and is licensed in 34 states (plus the District of Columbia and Puerto Rico). Coinbase

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is strongly committed both to protecting the important privacy interests of its account holders and

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to cooperating with government entities investigating illegal activities or other abuses of Coinbase

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services.

Goodwin Procter LLP

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601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

Coinbase is an industry-leading financial services company based in San Francisco that

On November 17, 2016, the IRS initiated this proceeding by filing an ex parte petition

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pursuant to 26 U.S.C. 7609(h)(2) for an order permitting the IRS to serve a John Doe

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summons on Coinbase. The summons is extraordinarily broad. For each of the hundreds of

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thousands of Coinbase account holders based in the United States, the IRS seeks all of the

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following information for a period of three years:

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1. Account/wallet/vault registration records for each account/wallet/vault owned or


controlled by the user during the period stated above including, but not limited to,
complete user profile, history of changes to user profile from account inception,
complete user preferences, complete user security settings and history (including
confirmed devices and account activity), complete user payment methods, and any
other information related to the funding sources for the account/wallet/vault, regardless
of date.
2. Any other records of Know-Your-Customer due diligence performed with respect to
the user not included in paragraph 1, above.
3. For any account/wallet/vault with respect to which the registered user gave any thirdparty access, control, or transaction approval authority, all powers of attorney, letters of
wishes, corporate minutes, or other agreements or instructions granting the third party
such access, control, or approval authority.
4. All records of account/wallet/vault activity including transaction logs or other records
identifying the date, amount, and type of transaction (purchase/sale/exchange), the post
transaction balance, the names or other identifiers of counterparties to the transaction;
requests or instructions to send or receive bitcoin; and, where counterparties transact
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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 5 of 10

through their own Coinbase accounts/wallets/vaults, all available information


identifying the users of such accounts and their contact information.

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5. For each merchant user for which you act as Payment Service Provider, records of all
payments processed, including records identifying the user of the wallet charged, if a
Coinbase user, or the address of the wallet charged, if not, the date and amount of the
transaction, and any other information that will enable the merchant to identify the
transaction.

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6. All correspondence between Coinbase and the user or any third party with access to the
account/wallet/vault pertaining to the account/wallet/vault, including but not limited to
letters, memoranda, telegrams, telexes, facsimiles, e-mail, letters of instruction, and
memoranda of telephone or oral instructions received.

7. All periodic statements of account or invoices (or the equivalent).

8. All records of payments to or from the user by checks, wire or other electronic transfer,
ACH transaction, PayPal transfer, credit or debit card transaction, money order,
transfer to or from other digital currency wallet address, or any other method, including
records reflecting the form, manner, nature, and purpose of such payment including,
but not limited to, ABA routing number and other routing information, payment
instructions, and any and all invoices, billing statements, receipts, or other documents
memorializing and describing such transaction.

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9. All exception reports produced by your AML system, and all records of investigation
of such exceptions.

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Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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Dkt. 2. Thus, the IRS is seeking (among other categories) information regarding every single

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transaction conducted by every single U.S.-based Coinbase account holder (no matter how large

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or small) for a three-year period. In its papers, however, the IRS offered only the slimmest of

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support for their expansive request: the IRS submitted a single declaration from an agent who

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described the results of his Google search, offered generalities about the information and

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experience of the IRS, and described three anecdotal situations of alleged failures to report

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income relating to digital currency, two of which involved relatively mundane examples of

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taxpayers improperly claiming personal expenditures as business expenses. Id. The IRS did not

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suggest, and has never suggested, that Coinbase itself has engaged in any wrongdoing of any kind.

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Id.

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Under the provisions of 26 U.S.C. 7609(h)(2), the Court was required to rule on the

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IRSs petition based solely upon the papers submitted in support of the request, without input from

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Coinbase or others. On November 30, 2016, this Court granted the petition. Dkt. 7.

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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
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Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 6 of 10

On December 13, 2016, proposed intervenor Mr. Jeffrey K. Berns filed a motion to

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intervene and to quash the summons, or in the alternative for a protective order, or in the

alternative for an order scheduling an evidentiary hearing and permitting limited discovery (the

Berns Motion). Dkt. 9. As a procedural matter, Mr. Berns argued that he should be permitted

to intervene in this proceeding. Id. As a substantive matter, he argued that the summons should

be quashed (or, in the alternative, that he should be entitled to discovery and/or an evidentiary

hearing to resolve potentially disputed facts relating to his motion to quash). Id.
On December 27, 2016, the IRS filed an opposition to the Berns Motion. Dkt. 15. In the

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opposition, the IRS argued that the Berns Motion should be denied on both procedural and

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substantive grounds. Id. On the same day, and in an effort to moot the Berns Motion, the IRS

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sent a letter to Coinbases counsel stating that it was withdrawing the request for the production of

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records relating to transactions by Mr. Berns. Dkt. 16.


Mr. Berns filed his reply brief on January 3, 2017. Dkt. 17. The hearing on the Berns

Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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Motion is currently scheduled for January 19, 2017. Concurrently with this motion to intervene,

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Coinbase is filing a motion to change the time for the hearing on the Berns Motion until late

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March (or such other time as the Court may set).


ARGUMENT

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I.

COINBASE MAY INTERVENE AS A MATTER OF RIGHT UNDER RULE 24(A).


A proposed intervenor may intervene as a matter of right under Federal Rule of Civil

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Procedure Rule 24(a) when: (1) the application for intervention is timely; (2) the applicant has a

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significantly protectable interest that may, as a practical matter, be impair[ed] or impede[d]

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by the disposition of the action; and (3) the applicants interest is not adequately represented by

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the existing parties in the lawsuit. Southwest Center for Biological Diversity v. Berg, 268 F.3d

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810, 817-18 (9th Cir. 2001) (citing Northwest Forest Resource Council v. Glickman, 82 F.3d 825,

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836 (9th Cir. 1996)). Courts must construe Rule 24(a) liberally in favor of potential intervenors.

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Id. at 818 (citing Forest Conservation Council v. United States Forest Serv., 66 F.3d 1489, 1493

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(9th Cir. 1995).) Coinbase easily meets each of these requirements and so may intervene as of

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right under Rule 24(a).


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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
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Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 7 of 10

A.

Three factors must be weighed to determine whether a motion to intervene is timely:

(1) the stage of the proceeding at which an applicant seeks to intervene; (2) the prejudice to other

parties; and (3) the reason for the length of the delay. See United States v. Oregon, 745 F.2d 550,

552 (9th Cir. 1984). The standard for determining what constitute timeliness under Rule 24 is

determined by considering all of the relevant facts and circumstances. See id.

Here, there is no question that Coinbases application is timely. This proceeding is

incipient, and Coinbase has not delayed in filing this motion to intervene. No party will be

unfairly prejudiced by Coinbases participation: the IRS has not yet moved to enforce the

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summons, and the account records of Mr. Berns (which the IRS no longer seeks) will not be

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produced pending the resolution of this proceeding. Thus, Coinbases application for intervention

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is timely.

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B.

Goodwin Procter LLP

COINBASE POSSESSES A SIGNIFICANT INTEREST THAT MAY BE IMPAIRED BY


RESOLUTION OF THIS ACTION.

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601 S Figueroa Street, 41st Floor
Los Angeles, CA 90017

COINBASES APPLICATION FOR INTERVENTION IS TIMELY.

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Rule 24(a)s interest requirement is a practical, threshold inquiry and [n]o specific legal

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or equitable interest need to be established. Greene v. United States, 996 F.2d 973, 976 (9th Cir.

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1993). [A] party has a sufficient interest for intervention purposes if it will suffer a practical

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impairment of its interests as a result of the pending litigation. California ex rel. Lockyer v.

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United States, 450 F.3d 436, 441 (9th Cir. 2006); Berg, 268 F.3d at 822 (We follow the guidance

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of Rule 24 advisory committee notes that state that [i]f an absentee would be substantially

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affected in a practical sense by the determination made in an action, he should, as a general rule,

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be entitled to intervene.).

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In this matter, if Mr. Berns is permitted to intervene, the resolution of his challenges to the

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IRS summons may, as a practical matter, impair Coinbases ability to protect its own interests.

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Although there is some overlap in the arguments that Mr. Berns makes in support of his motion to

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quash the IRS summons and those that Coinbase would make in this proceeding, Coinbase has

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strong arguments regarding why the summons should not be enforced that are separate from and in

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addition to the grounds stated by Mr. Berns. Coinbase would like to present the Court with
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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 8 of 10

additional arguments (including regarding the scope of the summons and the burden it would

place on Coinbase), as well as additional authorities, to show that the IRS summons should not be

enforced. In the event that the motion of Mr. Berns to intervene in this proceeding is granted,

Coinbase should also be allowed to intervene, and to present its own legal and factual arguments

in opposition to the summons, before the Court makes its decision regarding enforcement and/or

quashing the summons. If Coinbase is barred from intervening, and in connection with the Berns

Motion the Court makes a ruling regarding the scope of the summons, Coinbases ability to

protect its own interests may, as a practical matter, be impaired.

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Thus, Coinbase has a sufficient interest in this proceeding to intervene as of right under
Rule 24.
C.

BERNS.

Goodwin Procter LLP

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601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

COINBASE IS NOT ADEQUATELY REPRESENTED BY EITHER PETITIONER OR

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The final requirement under Rule 24(a) is the minimal burden of establishing that

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Coinbases interest may be inadequately represented by the existing parties. Trbovich v. United

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Mine Workers of Am., 404 U.S. 528, 538 n.10 (1972). In analyzing the adequacy of existing

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parties in representing the proposed intervenors interests, the Ninth Circuit considers several

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factors, including [1] whether [existing parties] will undoubtedly make all of the intervenors

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arguments, [2] whether [existing parties are] capable of and willing to make such arguments, and

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[3] whether the intervenor offers a necessary element to the proceedings that would be neglected.

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Sagebrush Rebellion, Inc. v. Watt, 713 F.2d 525, 528 (9th Cir. 1983).

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Here, Coinbase will not be adequately represented by either the IRS or Mr. Berns. The

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IRS has issued a summons to Coinbase and so is plainly not in a position to represent Coinbases

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interests. Moreover, although Mr. Berns, as an account holder, may share with Coinbase an

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interest in challenging the IRS summons, Coinbase has independent interests (including, for

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example, with regard to the scope of the summons and the burden that it would place on Coinbase)

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that Mr. Berns is not able to represent.

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Accordingly, neither the IRS nor Mr. Berns will adequately represent the interests of
Coinbase in this proceeding.
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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 9 of 10

Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

II.

COINBASE IS ALSO ENTITLED TO INTERVENE BECAUSE IT SATISFIES THE

REQUIREMENTS FOR PERMISSIVE INTERVENTION UNDER RULE 24(B).

Independently, and in the alternative, Coinbase should also be allowed to intervene under

the permissive intervention provisions of Federal Rule of Civil Procedure Rule 24(b). Rule 24(b)

provides that upon timely application the court may permit anyone to intervene who ... has a

claim or defense that shares with the main action a common question of law or fact. FED. R. CIV.

P. 24(b)(1)(B). In exercising its discretion the court must consider whether the intervention will

unduly delay or prejudice the adjudication of the original parties rights. FED. R. CIV. P. 24(b)(3).

As discussed above, Coinbases application for intervention is timely and intervention will

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not unduly delay or prejudice the adjudication of the rights of any party. The proceeding involves

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a summons that the IRS has issued to Coinbase, and Coinbase has defenses to enforcement that

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share common questions of law and fact with the challenges asserted by Mr. Berns. Thus, as an

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alternative to intervention under Rule 24(a), Coinbase requests that the Court exercise its

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discretion and permit the Coinbase to intervene is this case under Rule 24(b).
CONCLUSION

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For the foregoing reasons, Coinbase respectfully requests that the Court grant its motion to
intervene in this action.

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Respectfully submitted,

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Dated: January 11, 2017

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By: /s/ Steven A. Ellis


STEVEN A. ELLIS
sellis@goodwinlaw.com
GRANT P. FONDO
gfondo@goodwinlaw.com
SHAUNA E. WOODS
swoods@goodwinlaw.com
GOODWIN PROCTER LLP
Attorneys for Proposed Intervenor
COINBASE, INC.

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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19 Filed 01/11/17 Page 10 of 10

CERTIFICATE OF SERVICE

In the Matter of the Tax Liabilities of John Does etc.


N.D. Cal Case No. 3:16-cv-06658-JSC

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I, Steven A. Ellis, hereby certify that a copy of the foregoing document, filed through the

CM/ECF system, will be sent electronically to the registered participants as identified on the

Notice of Electronic Filing (NEF) and paper copies shall be served by first class mail postage

prepaid on all counsel who are not served through the CM/ECF system on January 11, 2017.

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/s/
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Steven A. Ellis
STEVEN A. ELLIS

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Goodwin Procter LLP

601 S Figueroa Street, 41st Floor


Los Angeles, CA 90017

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NOTICE OF MOTION AND MOTION OF PROPOSED INTERVENOR COINBASE INC.
TO INTERVENE; MEMORANDUM OF POINTS OF AUTHORITIES
Case No. 3:16-CV-06658-JSC
ACTIVE/89292521.1

Case 3:16-cv-06658-JSC Document 19-1 Filed 01/11/17 Page 1 of 3

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STEVEN A. ELLIS (SBN 171742)


sellis@goodwinlaw.com
SHAUNA E. WOODS (SBN 300339)
swoods@goodwinlaw.com
GOODWIN PROCTER LLP
601 S. Figueroa Street, 41st Floor
Los Angeles, CA 90017
Tel.: 213.426.2500
Fax.: 213.623.1673
GRANT P. FONDO (SBN 181530)
gfondo@goodwinlaw.com
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, CA 94025-1105
Tel.: 650.752.3100
Fax.: 650.853.1038
Attorneys for Proposed Intervenor
COINBASE, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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IN THE MATTER OF THE TAX


LIABILITIES OF:

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JOHN DOES, United States persons who, at


any time during the period January 1, 2013,
through December 31, 2015, conducted
transactions in a convertible virtual currency
as defined in IRS Notice 2014-21.

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Case No. 3:16-cv-06658-JSC


[PROPOSED] ORDER GRANTING
MOTION OF PROPOSED INTERVENOR
COINBASE INC. TO INTERVENE
Date:
Time:
Courtroom:
Judge:

February 16, 2017


9:00 a.m.
F (15th Floor)
Hon. Jacqueline Scott Corley

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ACTIVE/89335472.1

ORDER GRANTING MOTION OF


PROPOSED INTERVENOR COINBASE INC. TO INTERVENE

Case No. 3:16-CV-06658-JSC

Case 3:16-cv-06658-JSC Document 19-1 Filed 01/11/17 Page 2 of 3

[PROPOSED] ORDER GRANTING PROPOSED INTERVENOR COINBASE INC.S

MOTION TO MOTION TO INTERVENE

The Motion to Intervene (Motion) by proposed intervenor Coinbase, Inc. (Coinbase)

came on for hearing on February 16, 2017, the Honorable Jacqueline Scott Corley presiding.

Appearances by the parties were as noted on the record.

The Court, having reviewed the papers filed in support of, and in opposition to, the

Motion, having considered all of the evidence, and for good cause shown, hereby orders as

follows:

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Coinbases Motion to Intervene is GRANTED.

IT IS SO ORDERED.

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Dated: ________________________, 2017


HON. JACQUELINE SCOTT CORLEY
UNITED STATES MAGISTRATE JUDGE

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ORDER GRANTING MOTION OF
PROPOSED INTERVENOR COINBASE INC. TO INTERVENE
ACTIVE/89335472.1

Case No. 3:16-CV-06658-JSC

Case 3:16-cv-06658-JSC Document 19-1 Filed 01/11/17 Page 3 of 3

CERTIFICATE OF SERVICE

In the Matter of the Tax Liabilities of John Does etc.


N.D. Cal Case No. 3:16-cv-06658-JSC

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I, Steven A. Ellis, hereby certify that a copy of the foregoing document, filed through the

CM/ECF system, will be sent electronically to the registered participants as identified on the

Notice of Electronic Filing (NEF) and paper copies shall be served by first class mail postage

prepaid on all counsel who are not served through the CM/ECF system on January 11, 2017.

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/s/
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Steven A. Ellis
_
STEVEN A. ELLIS

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ORDER GRANTING MOTION OF
PROPOSED INTERVENOR COINBASE INC. TO INTERVENE
ACTIVE/89335472.1

Case No. 3:16-CV-06658-JSC