Campbell et al v. Facebook Inc.

Filing 109

MOTION for Extension of Time to File Plaintiffs' Motion for Extension of Class Certification and Summary Judgment Deadlines filed by Matthew Campbell, Michael Hurley. (Attachments: # 1 Proposed Order, # 2 Declaration of David Rudolph, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Exhibit 12, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 19, # 22 Exhibit 20, # 23 Exhibit 21)(Sobol, Michael) (Filed on 9/16/2015)

EXHIBIT 9

Joshua A. Jessen
Direct: +1 949.451.4114
Fax: [phone]
[e-mail]

September 14, 2015
VIA ELECTRONIC MAIL
Hank Bates, Esq.
Carney Bates & Pulliam, PLLC
2800 Cantrell Road, Suite 510
Little Rock, AR 72202
Re:

Campbell v. Facebook, Inc., N.D. Cal. Case No. 13-cv-05596-PJH (MEJ)

Dear Hank:
This letter responds to your letters of August 20, 2015 and August 26, 2015.
With respect to the question in your August 20 letter regarding Facebook’s initial decision to
increment the “Like” count on third-party websites based on URL attachments to messages
(among other things), neither of the documents you cite in your letter mentions a specific
document that has yet to be produced, so your suggestion that there are “relevant documents
alluded to, but not yet produced,” is purely speculative. Having said that, our production is
ongoing, and will we continue to produce all relevant, non-privileged documents from the
relevant time period that can be located after a reasonable search.
With respect to your August 26 letter—in which you ask several questions about certain
categories of documents—a cursory search of the documents Facebook has produced thus far
answers several of your questions. Additionally, as noted above, our production is ongoing,
and will we continue to produce all relevant, non-privileged documents from the relevant
time period that can be located after a reasonable search. Furthermore, the questions you
raise in your letters obviously can be explored in Plaintiffs’ upcoming depositions.
Sincerely,

Joshua A. Jessen
JAJ/plm