In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 177

Administrative Motion to File Under Seal Stipulation and [Proposed] Order Requesting Limited Redaction of November 16, 2017 Hearing Transcript filed by Facebook Inc.. (Attachments: #1 Declaration of Kyle C. Wong in Support of Stipulation, #2 Exhibit A, #3 Exhibit B)(Brown, Matthew) (Filed on 12/13/2017)

1

6

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]

7

Attorneys for Defendant FACEBOOK, INC.

2
3
4
5

8
9
10

UNITED STATES DISTRICT COURT

11

NORTHERN DISTRICT OF CALIFORNIA

12

SAN JOSE DIVISION

13
14

In re: Facebook Internet Tracking Litigation

Case No. 12-md-02314 EJD
DECLARATION OF KYLE C. WONG IN
SUPPORT OF STIPULATION AND
[PROPOSED] ORDER REQUESTING
LIMITED REDACTION OF NOVEMBER 16,
2017 HEARING TRANSCRIPT

15
16
17

JUDGE:
COURTROOM:

18
19

Hon. Edward J. Davila
4

20
21
22
23
24
25
26

I, Kyle C. Wong, declare as follows:
1.

I am an attorney licensed to practice law in the state of California and am

associated with the law firm of Cooley LLP, counsel of record for defendant Facebook, Inc. I
have personal knowledge of the facts below and could and would testify competently to them if
called as a witness. I submit this declaration in support of the parties’ Stipulation and [Proposed]
Order Requesting Limited Redaction of November 16, 2017 Hearing Transcript.

27
28
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

156980068

1.

WONG DECL. I/S/O REQUEST TO REDACT
NOV 16, 2017 HEARING TRANSCRIPT
CASE NO. 12-MD-02314 EJD

1

2.

Redacted and highlighted copies of the transcript from the November 16, 2017

2

hearing with redactions narrowly tailored to protect Facebook’s confidential information are

3

attached to this declaration as Exhibit A (redacted) and Exhibit B (highlighted).

4

I declare under penalty of perjury that the foregoing is true and correct.

5
6

Executed on December 13, 2017 in San Francisco, California.

7
8

/s/ Kyle C. Wong
Kyle C. Wong

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

156980068

WONG DECL. I/S/O REQUEST TO REDACT
NOV 16, 2017 HEARING TRANSCRIPT
CASE NO. 12-MD-02314 EJD

1
2

ATTESTATION PURSUANT TO CIV. L.R. 5-1(i)(3)
I, Matthew D. Brown, attest that concurrence in the filing of this DECLARATION OF KYLE

3

C. WONG

4

REDACTION

5

signatory. I declare under penalty of perjury under the laws of the United States of America that

6

the foregoing is true and correct. Executed this 13th day of December, 2017, at San Francisco,

7

California.

IN

SUPPORT

OF

OF

STIPULATION

AND

[PROPOSED] ORDER REQUESTING LIMITED

NOVEMBER 16, 2017 HEARING TRANSCRIPT has been obtained from the

8
9

/s/ Matthew D. Brown
Matthew D. Brown

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

156980068

WONG DECL. I/S/O REQUEST TO REDACT
NOV 16, 2017 HEARING TRANSCRIPT
CASE NO. 12-MD-02314 EJD