On September 26, 2022, the U.S. District Court for the Northern District of Illinois issued one of the first decisions to date on a motion in limine filed in Illinois Biometric Information Privacy Act ("BIPA") class action litigation in Rogers v. BNSF Ry. Co., No. 19 CV 3083, 2022 U.S. Dist. LEXIS 173322 (N.D. Ill. Sept. 26, 2022).