In Re FACEBOOK INTERNET TRACKING LITIGATION

Filing 58

Declaration of Kyle C. Wong in Support of # 56 Request for Judicial Notice, # 55 Reply to Opposition/Response filed byFacebook Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C)(Related document(s) # 56 , # 55 ) (Brown, Matthew) (Filed on 8/22/2012)

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1 2 3 4 5 6 7 COOLEY LLP MICHAEL G. RHODES (116127) (rhodesmg@cooley.com) MATTHEW D. BROWN (196972) (brownmd@cooley.com) JEFFREY M. GUTKIN (216083) (jgutkin@cooley.com) 101 California Street, 5th Floor San Francisco, CA 94111-5800 Telephone: (415) 693-2000 Facsimile: (415) 693-2222 Attorneys for Defendant FACEBOOK, INC. 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 13 Case No. 5:12-md-02314 EJD In re: Facebook Internet Tracking Litigation DECLARATION OF KYLE C. WONG 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)) 14 15 16 17 18 19 DATE: TIME: COURTROOM: JUDGE: TRIAL DATE: 20 21 October 5, 2012 9:00 a.m. 4 Edward J. Davila None Set 22 23 24 25 26 27 I, Kyle C. Wong, hereby declare as follows: 1. I am an attorney licensed to practice law in the state of California and a partner of 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. 28 COOLEY LLP ATTORNEYS AT LAW SAN FRANCISCO 1. WONG DECLARATION I/S/O REPLY I/S/O DEF. FACEBOOK’S MOTION TO DISMISS CASE NO. 5:12-MD-02314 EJD 1 2. Attached hereto as Exhibit A is a true and correct copy of the California Senate 2 Judiciary Committee’s Analysis of Senate Bill No. 1016 (1996-1996 Reg. Sess.) as amended May 3 9, 1995. 4 5 6 3. Attached hereto as Exhibit B is a true and correct copy of California Senate Bill No. 1016 (1996-1996 Reg. Sess.) as chaptered. 4. Attached hereto as Exhibit C is a true and correct copy of the California Senate 7 Committee on Public Safety’s Analysis of Senate Bill No. 1428 (2009-2010 Reg. Sess.) as 8 introduced. 9 10 5. I declare under penalty of perjury that the foregoing is true and correct. Executed on August 22, 2012 at San Francisco, California. 11 12 /s/ Kyle C. Wong Kyle C. Wong 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COOLEY LLP ATTORNEYS AT LAW SAN FRANCISCO 2. WONG DECLARATION I/S/O REPLY I/S/O DEF. FACEBOOK’S MOTION TO DISMISS CASE NO. 5:12-MD-02314 EJD 1 2 ATTESTATION In accordance with Northern District of California Civil Local Rule 5-1(i)(3), I hereby 3 attest that I have obtained concurrence in the filing of this document from each of the other 4 signatories. 5 6 /s/ Matthew D. Brown MATTHEW D. BROWN 7 8 2637984/ST 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 3. WONG 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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