In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 57

Declaration of Sandeep Solanki in Support of # 56 Request for Judicial Notice, # 55 Reply to Opposition/Response filed byFacebook Inc.. (Attachments: # 1 Exhibit A)(Related document(s) # 56 , # 55 ) (Brown, Matthew) (Filed on 8/22/2012)

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COOLEY LLP
MICHAEL G. RHODES (116127)
([e-mail])
MATTHEW D. BROWN (196972)
([e-mail])
JEFFREY M. GUTKIN (216083)
([e-mail])
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
[phone]
Facsimile:
[phone]
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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Case No. 5:12-md-02314 EJD

In re: Facebook Internet Tracking Litigation

DECLARATION OF SANDEEP SOLANKI IN
SUPPORT OF DEFENDANT FACEBOOK,
INC.’S REPLY IN SUPPORT OF ITS
MOTION TO DISMISS PLAINTIFFS’
CORRECTED FIRST AMENDED
CONSOLIDATED CLASS ACTION
COMPLAINT (FED. R. CIV. P. 12(b)(1) &
12(b)(6))

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DATE:
TIME:
COURTROOM:
JUDGE:
TRIAL DATE:

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October 5, 2012
9:00 a.m.
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Edward J. Davila
None Set

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I, Sandeep Solanki, hereby declare as follows:
1.

I am an attorney employed as Lead Litigation Counsel by Defendant Facebook,

Inc. (“Facebook”). Except as otherwise noted, I have personal knowledge of the following facts
and if called to testify could and would testify competently thereto.

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

1.

SOLANKI DECLARATION I/S/O REPLY I/S/O
DEF. FACEBOOK’S MOTION TO DISMISS
CASE NO. 5:12-MD-02314 EJD

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2.

Facebook’s Privacy Policy (also known as Facebook’s “Data Use Policy” as of

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September 23, 2011) discloses, among other things, what information Facebook receives and how

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that information is used. The Privacy Policy is posted on the Facebook website, and can be

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found, among other ways, by clicking on a link titled “Privacy Policy” in the SRR, and by

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clicking on a link titled “Privacy” at the bottom of most pages on the Facebook website. Users

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must acknowledge that they have read Facebook’s Privacy Policy when registering for the site.

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Attached as Exhibit A is a true and correct copy of Facebook’s Privacy Policy that was effective

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as of December 22, 2010 (this Privacy Policy indicates, “Date of last revision: December 22,

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2010”).

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3.

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Executed on August 22, 2012 at Menlo Park, California.

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

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/s/ Sandeep Solanki
Sandeep Solanki

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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SOLANKI DECLARATION I/S/O REPLY I/S/O
DEF. FACEBOOK’S MOTION TO DISMISS
CASE NO. 5:12-MD-02314 EJD

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ATTESTATION
In accordance with Northern District of California Civil Local Rule 5-1(i)(3), I hereby

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attest that I have obtained concurrence in the filing of this document from each of the other

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signatories.

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/s/ Matthew D. Brown
MATTHEW D. BROWN

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2637330/ST

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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO

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SOLANKI DECLARATION I/S/O REPLY I/S/O
DEF. FACEBOOK’S MOTION TO DISMISS
CASE NO. 5:12-MD-02314 EJD