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It seems the claims are the same as in that lawsuit, but specifically takes aim at the activities in the Massachusetts Apple Stores. According to the lawsuit, Bah received a learner's permit for driving in New York state in March 2018, which took the form of a printout that contained details of his height, weight, date of birth, and eye colour, but not his photograph.

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Bah lost his temporary permit within the following two months but had received a permanent plastic version with his photograph. The missing temporary permit is alleged to have been used by someone else as identification for an Apple Store theft in Greenwich, Connecticut in April 2018. The man is said to have not resembled Bah at all, aside from being Black, such as being 6 foot 1 inch tall when Bah is 5 foot 7 inches. Bah said Apple and SIS created a record for Bah as the thief in the video and published the information to both SIS agents and Apple Stores in the US.

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