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)
([e-mail])
MATTHEW D. BROWN (196972)
([e-mail])
JEFFREY M. GUTKIN (216083)
([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
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
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2

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Exhibit N
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Exhibit O
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4

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Exhibit P
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Exhibit Q
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Exhibit R
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11] Joe

Michael

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>>>> From: [e-mail]
» » To: theartist11 @hotmail.com
» » CC: [e-mail]
» » 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" <theartist11 @hotmail.com
>>>>>
>>>>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

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>>>>>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
>>>>> <http://www .chrismatyszczyk.com>
>>>>>
>>>>>
>>>>
>>>

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Exhibit S
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Exhibit W
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Exhibit X
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Exhibit Y
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Exhibit AA
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