Campbell et al v. Facebook Inc.

Filing 125

Administrative Motion to File Under Seal Portions of the Declaration of Dale Harrison filed by Facebook Inc.. (Attachments: # 1 Declaration of Nikki Sokol In Support of Administrative Motion to File Under Seal, # 2 Exhibit A - Unredacted Version of Declaration of Dale Harrison, # 3 Exhibit B - Redacted Version of Declaration of Dale Harrison, # 4 Proposed Order Granting Administrative Motion to File Under Seal, # 5 Certificate/Proof of Service by Email)(Jessen, Joshua) (Filed on 10/6/2015)

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GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
[e-mail]
JEANA BISNAR MAUTE, SBN 290573
[e-mail]
ASHLEY M. ROGERS, SBN 286252
[e-mail]
1881 Page Mill Road
Palo Alto, California 94304
Telephone: [phone]
Facsimile: [phone]
GIBSON, DUNN & CRUTCHER LLP
GAIL E. LEES, SBN 90363
[e-mail]
CHRISTOPHER CHORBA, SBN 216692
[e-mail]
333 South Grand Avenue
Los Angeles, California 90071
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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OAKLAND DIVISON

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MATTHEW CAMPBELL, MICHAEL
HURLEY, and DAVID SHADPOUR,
Plaintiffs,
v.
FACEBOOK, INC.,
Defendant.

Case No. C 13-05996 PJH (MEJ)
PUTATIVE CLASS ACTION
[PROPOSED] ORDER GRANTING
FACEBOOK, INC.’S ADMINISTRATIVE
MOTION TO FILE PORTIONS OF THE
DECLARATION OF DALE HARRISON
ON BEHALF OF DEFENDANT
FACEBOOK, INC. UNDER SEAL

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Gibson, Dunn &
Crutcher LLP

[PROPOSED] ORDER GRANTING FACEBOOK, INC.’S ADMINISTRATIVE MOTION TO FILE PORTIONS OF THE
DECLARATION OF DALE HARRISON ON BEHALF OF DEFENDANT FACEBOOK, INC. UNDER SEAL
Case No. C 13-05996 PJH (MEJ)

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On October 6, 2015, Defendant Facebook, Inc. filed an administrative motion to file under
seal portions of the Declaration of Dale Harrison on Behalf of Defendant Facebook, Inc. (“Harrison
Declaration”). Defendant Facebook, Inc. also submitted a declaration in support of that
administrative motion. The Court finds that Defendant Facebook, Inc.’s sealing request is narrowly
tailored and justified. Good cause having been shown, IT IS HEREBY ORDERED that the
following portions of the Harrison Declaration may be filed under seal:

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Gibson, Dunn &
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Text
Text between “The information I extracted included:” and “…which would be responsive
to Plaintiffs’ request for information…”
Text between “…already produced to Plaintiffs—” and “—are the only Objects created in
connection with sharing URLs in messages.”
Text between “…information I located through my extensive searching—specifically…”
and “…for the 16 messages I located.”
Text between “…that may have been created in connection with these 16 messages” and
“Similarly, I am not aware of any automated…”
Text between “…billions of pieces of data per day” and “In my experience, developing
such functionality…”
Text between “…I was required to write new software code using…” and “…to find
information about the messages in Facebook’s internal system.”
Text between “I understand that this information, referred to as…” and “…was produced
to Plaintiffs.”
Text between “…I understand that Plaintiffs were unable to provide…” and “Without this
data, I could not locate the message.”
Text between “selected by Plaintiffs.” and “Using this process…”
Text between “…locate, extract, and provide…” and “…relating to 9 of the 16 messages.”
Text between “I understand that this information, referred to as…” and “…was produced
to Plaintiffs.”
Text between “7 of the 16 messages did not have a…” and “Using this process, I was able
to locate, extract, and provide information…”
Text between “…and provide information relating to the 9 URLs in the 9…” and “I
understand that this information…”
Text between “I understand that this information referred to as…” and “…was produced
to Plaintiffs.”
Text between “At the request of Facebook’s counsel, after providing the above
information…” and “Using this process, I was able to locate…”
Text between “I understand that this information, referred to as…” and “…was produced
to Plaintiffs.”
Text between “This is likely impossible. If ordered to do so…” and “…it could take
hundreds of man hours to do so.”
Text between “…that can use the Objects and Associations for each of these messages.”
and “However, the abstract hypothetical questions to all possible uses…”
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[PROPOSED] ORDER GRANTING FACEBOOK, INC.’S ADMINISTRATIVE MOTION TO FILE PORTIONS OF THE
DECLARATION OF DALE HARRISON ON BEHALF OF DEFENDANT FACEBOOK, INC. UNDER SEAL
Case No. C 13-05996 PJH (MEJ)

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Text
Text between “The…” and “…documentation that Facebook has already produced…”
Text between “…Facebook has already produced to Plaintiffs…” and “This information
should help Plaintiffs conduct…”
Text between “I understand that Plaintiffs have also asked Facebook to produce…” and
“…for the 16 historical messages I extracted.”
Text between “…for the 16 historical messages I extracted” and “I declare under penalty
of perjury…”

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IT IS SO ORDERED.

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Dated: __________

_____________________________________
MARIA-ELENA JAMES
United States Magistrate Judge

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[PROPOSED] ORDER GRANTING FACEBOOK, INC.’S ADMINISTRATIVE MOTION TO FILE PORTIONS OF THE
DECLARATION OF DALE HARRISON ON BEHALF OF DEFENDANT FACEBOOK, INC. UNDER SEAL
Case No. C 13-05996 PJH (MEJ)