In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 158

OPPOSITION/RESPONSE (re #156 Administrative Motion to File Under Seal Portions of the Third Amended Consolidated Complaint ) Defendant Facebook, Inc.s Response to Plaintiffs Administrative Motion to File Under Seal filed byFacebook Inc.. (Attachments: #1 Proposed Order, #2 Declaration Naugle Declaration in Support)(Brown, Matthew) (Filed on 8/29/2017)

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COOLEY LLP
MICHAEL G. RHODES (116127)
([e-mail])
MATTHEW D. BROWN (196972)
([e-mail])
KYLE C. WONG (224021)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant FACEBOOK, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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In re: Facebook Internet Tracking Litigation

Case No. 12-md-02314 EJD
[PROPOSED] ORDER GRANTING IN PART
PLAINTIFFS’ ADMINISTRATIVE MOTION
TO FILE UNDER SEAL

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JUDGE:
COURTROOM:
TRIAL DATE:

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Edward J. Davila
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Not Yet Set

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

150022168

[PROPOSED] ORDER RE
MOTION TO FILE UNDER SEAL
CASE NO. 12-MD-02314 EJD

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THIS MATTER, having come before the Court on Plaintiffs’ Administrative Motion to
File Portions of Third Amended Consolidated Complaint Under Seal, filed on August 25, 2017
(Dkt. No. 156-157) (“Plaintiffs’ Administrative Motion”) and the Court having considered
Plaintiffs’ Administrative Motion and the Declaration of David A. Straite (the “Straite
Declaration”) filed contemporaneously therewith, Facebook’s Response to Plaintiffs’
Administrative Motion, and the Declaration of Natalie Naugle filed contemporaneously
therewith:
The Court finds that compelling reasons have been shown to support the filing under seal
of the documents and portions of documents described herein. Accordingly,
IT IS ORDERED that the following documents shall be filed under seal and sealed from
the public record:
1.

Exhibit U to the Third Amended Consolidated Complaint (the “Amended

Complaint”) (also filed as part of Exhibit 2 to the Straite Declaration);
2.

Exhibit V to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
3.

Exhibit W to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
4.

Exhibit X to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
5.

Exhibit Y to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
6.

Exhibit Z to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
7.

Exhibit AA to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);
8.

Exhibit BB to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

150022168

1

[PROPOSED] ORDER RE
MOTION TO FILE UNDER SEAL
CASE NO. 12-MD-02314 EJD

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9.
Declaration);

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Exhibit LL to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit II to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit HH to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit GG to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit FF to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit DD to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

Declaration);

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Exhibit CC to the Amended Complaint (also filed as part of Exhibit 2 to the Straite

16.

Exhibit 4 to the Straite Declaration (also filed as the Amended Complaint) with the

redacted version lodged with the Court by Facebook on August 29, 2017 filed in the public
record.

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Document

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Exhibit U to the Amended
Complaint
Exhibit V to the Amended
Complaint
Exhibit W to the Amended
Complaint
Exhibit X to the Amended
Complaint
Exhibit Y to the Amended
Complaint
Exhibit Z to the Amended
Complaint
Exhibit AA to the Amended
Complaint

Paragraph or Page/Line

Ruling

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

150022168

2.

[PROPOSED] ORDER RE
MOTION TO FILE UNDER SEAL
CASE NO. 12-MD-02314 EJD

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Document
Exhibit BB to the Amended
Complaint
Exhibit CC to the Amended
Complaint
Exhibit DD to the Amended
Complaint
Exhibit FF to the Amended
Complaint
Exhibit GG to the Amended
Complaint
Exhibit HH to the Amended
Complaint
Exhibit II to the Amended
Complaint
Exhibit LL to the Amended
Complaint
Exhibit 4 to the Straite
Declaration

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Paragraph or Page/Line

Ruling

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Sealed entirely.

Granted.

Page 8, lines 4, 10, 20-21
Granted.
Page 9, lines 5, 9-11, 18-26
Page 13, lines 10-12, 14-16, 1922, 26-27
Page 16, lines 9-11, 14-15, 17-18,
20-28
Page 17, lines 1-4, 6-10, 12-13,
15-18, 20-25, 27
Page 18, lines 1-5
Page 19, lines 18-19, 23-25
Page 20, lines 1, 10-11, 16
Page 21, lines 8-9, 12-27
Page 22, lines 1, 4-10

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Dated: __________________
__________________________________________
Hon. Edward J. Davila
U.S. District Court, Northern District of California

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

150022168

3.

[PROPOSED] ORDER RE
MOTION TO FILE UNDER SEAL
CASE NO. 12-MD-02314 EJD