In Re FACEBOOK INTERNET TRACKING LITIGATION
Filing
95
REDACTION DECLARATION of Natalie Naugle in support of response REDACTED Version of Exhibit 2 re: #92 filed by Facebook Inc.. (Attachments: #1 UNREDACTED Version of Exhibit 2, #2 REDACTED Version of Exhibit 3, #3 UNREDACTED Version of Exhibit 3)(Related document(s) #92 , #90 ) (Gutkin, Jeffrey) (Filed on 12/4/2015) Modified on 12/7/2015 (cv, COURT STAFF).
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COOLEY LLP
MICHAEL G. RHODES (116127)
(rhodesmg@cooley.com)
MATTHEW D. BROWN (196972)
(brownmd@cooley.com)
JEFFREY M. GUTKIN (216083)
(jgutkin@cooley.com)
KYLE C. WONG (224021)
(kwong@cooley.com)
101 California Street, 5th Floor
San Francisco, CA 94111-5800
Telephone:
(415) 693-2000
Facsimile:
(415) 693-2222
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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
DECLARATION OF NATALIE NAUGLE IN
SUPPORT OF DEFENDANT FACEBOOK,
INC.’S RESPONSE TO 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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REDACTED
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Exhibit 2
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COOLEY LLP
ATTORNEYS AT LAW
SAN FRANCISCO
124812067
NAUGLE DECL. I/S/O RESPONSE
TO MOTION TO FILE UNDER SEAL
CASE NO. 12-MD-02314 EJD
Exhibit M
FILED UNDER SEAL
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FB_MDL_00005356
2
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FB_MDL_00005357
Exhibit N
FILED UNDER SEAL
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FB_MDL_00007340
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FB_MDL_00007341
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FB_MDL_00007342
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FB_MDL_00007343
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FB_MDL_00007344
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FB_MDL_00007353
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FB_MDL_00007355
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FB_MDL_00007356
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FB_MDL_00007357
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Highly Confidential
FB_MDL_00007358
Exhibit O
FILED UNDER SEAL
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FB_MDL_00005391
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FB_MDL_00005392
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FB_MDL_00005393
4
Highly Confidential
FB_MDL_00005394
Exhibit P
FILED UNDER SEAL
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FB_MDL_00002730
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FB_MDL_00002731
Exhibit Q
FILED UNDER SEAL
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FB_MDL_00008271
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FB_MDL_00008272
Exhibit R
FILED UNDER SEAL
11] Joe
Michael
REDACTED
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FB_MDL_00007468
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>>>> From: noyes@facebook.com
» » To: theartist11 @hotmail.com
» » CC: barry@facebook.com
» » Date: Fri, 4 Jun 2010 11 :07:13 -0700
»»Subject: Re: URGENT INQUIRY RE: PRIVACY FROM CNET NEWS
>>>>
>>>> Hi Chris >>>>
» » We can put you on the phone with Bret Taylor at 130p PT. Dial-in
>>>>below/
>>>>
»»Dial: 866-503-7933
>>>>Guestcode: 1041065919
>>>>
>>>> -Andrew
>>>>
» » On Jun 4, 2010, at 12:18 AM, "Chris Matyszczyk" >>>>
>>>>wrote:
>>>>
>>>>>Hi, Andrew,
>>>>>
>>>>> I tried to contact Barry, but perhaps you can help me with this
>>>>> important
>>>>>question.
>>>>>
»»>Here's the thing. While everyone has Uustifiably, it seems to me)
>>>>> wondered
>>>>>about Facebook forcing people's data into the public domain, I
>>>>> have been
>>>>> alerted to perhaps an even bigger privacy question with respect to
>>>>>the
>>>>>Activity Feed.
>>>>>
>>>>> It seems to me that when you visit any page that has a like
>>>>>button, your
>>>>> browser send a request back to Facebook. This means your Facebook
>>>>> cookie can
Highly Confidential
FB_MDL_00007472
>>>>>connect you, personally, to your web activity. It doesn't matter
>>>>> if you have
»»> logged on to that page or clicked on it. Or have even interacted
>>>>> with it in
>>>>>any way.
>>>>>
>>>>> The only way to disable this is to remove your Facebook cookie.
>>>>> After logging
>>>>> out. Every time.
>>>>>
>>>>>Essentially, unlike DoubleCiick or an ISP, it seems that you have
>>>>> anointed
>>>>> yourselves with the power to link every Facebook member's web
>>>>> activity with
>>>>>their real personas. Which is a first. And, perhaps, rather scary.
>>>>>
>>>>>As long as I use the same browser for my Facebook account as I do
>>>>> for other
»»>Web activity, Facebook is picking up EVERYTHING about my movements
>>>>> around the
>>>>>web. This seems a very serious state of affairs.
>>>>>
>>>>> I would like your comment on this analysis, please.
>>>>>
>>>>>And what, if anything, can users do to opt-out of this data being
>>>>> collected
>>>>> by Facebook? And how can you prove that you have ceased to collect
>>>>>it?
>>>>>
>>>>>best,
>>>>>
>>>>>Chris
>>>>>
>>>>>
»»> Chris Matyszczyk 415-233 2001 (cell) www .chrismatyszczyk.com
>>>>>
>>>>>
>>>>>
>>>>
>>>
Highly Confidential
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Exhibit S
FILED UNDER SEAL
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FB_MDL_00000734
Exhibit T
FILED UNDER SEAL
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FB_MDL_00005470
Exhibit U
FILED UNDER SEAL
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FB_MDL_00002992
Exhibit V
FILED UNDER SEAL
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FB_MDL_00005416
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Exhibit W
FILED UNDER SEAL
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FB_MDL_00000622
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Exhibit X
FILED UNDER SEAL
Highly Confidential
FB_MDL_00000771
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FB_MDL_00000772
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FB_MDL_00000773
Exhibit Y
FILED UNDER SEAL
Highly Confidential
FB_MDL_00005501
Highly Confidential
FB_MDL_00005502
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FB_MDL_00005503
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FB_MDL_00005504
Exhibit AA
FILED UNDER SEAL
Highly Confidential
FB_MDL_00005237
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