'not known to Plaintiffs'
Impressive, they claim to know what they don't know. You'd think the judge, based on experience here also with his son, might have spotted that one, too.
Obviously there will be some quantity of unknown 'perps' which means the number will be higher but given that they've obviously been tracking the listed perps for a while they can't claim to know that the unknown number will be 'substantially' higher of large-scale naughty folk, as you'd think they would have blipped across their spying radar simply due to the volume of their activity.
And yes, I too would think that 'unverified' would be a reasonable cause for complaint. This judge has a strong whiff of
backhander bias about him.