Campbell et al v. Facebook Inc.

Filing 142

Declaration of Nikki Stitt Sokol in Support of 137 Administrative Motion to File Under Seal re Plaintiffs' Motion for Class Certification filed byFacebook Inc.. (Related document(s) 137 ) (Jessen, Joshua) (Filed on 11/17/2015)

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GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
[e-mail]
JEANA BISNAR MAUTE, SBN 290573
[e-mail]
PRIYANKA RAJAGOPALAN, SBN 278504
[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
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
DECLARATION OF NIKKI STITT
SOKOL IN SUPPORT OF PLAINTIFFS’
ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO.
137

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Crutcher LLP

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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I, Nikki Stitt Sokol, declare as follows:

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1.

I am Associate General Counsel for Litigation for Defendant Facebook, Inc.

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(“Facebook”). Pursuant to Civil Local Rule 79-5(d) and the Amended Stipulated Protective Order

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entered by the Court on July 1, 2015 (the “Protective Order”) (Dkt. No. 93), I submit this Declaration

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in support of Plaintiffs’ Administrative Motion to File Under Seal re Plaintiffs’ Motion for Class

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Certification and Supporting Documents (Dkt. No. 137), which seeks to file under seal (1) designated

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portions of Plaintiffs’ Motion for Class Certification (Dkt. No. 138); (2) designated portions of the

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Expert Report of Jennifer Golbeck in support of Plaintiffs’ Motion for Class Certification (“Golbeck

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Report”), which is Exhibit 2 to the Declaration of Melissa Gardner in support of Plaintiffs’ Motion

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for Class Certification (“Gardner Cert. Declaration”); (3) designated portions of the Expert Report of

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Fernando Torres in support of Plaintiffs’ Motion for Class Certification (“Torres Report”), which is

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Exhibit 33 to the Gardner Cert. Declaration; (4) designated portions of Facebook’s Supplemental
Responses and Objections to Plaintiffs’ Narrowed Second Set of Interrogatories (“Facebook’s
Supplemental Discovery Responses”), which is Exhibit 20 to the Gardner Cert. Declaration; and (5)
Exhibits 3-18, 27-30, and 34-35 to the Gardner Cert. Declaration, in their entirety. Except as
otherwise noted, I have personal knowledge of the facts set forth in this Declaration and, if called and
sworn as a witness, could and would testify competently to them.

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2.

Facebook respectfully requests that the Court allow the below-referenced documents

(or relevant portions of those documents) to be filed under seal due to their confidential nature. As
discussed below, the documents constitute, reflect, contain, or discuss confidential information that is
protectable as a trade secret or otherwise entitled to protection under the law. I respectfully submit
that the presumption of access to judicial records does not apply here because the documents at issue
are being filed in connection with a non-dispositive motion (see In re Midland Nat’l Life Ins. Co.
Annuity Sales Practices Litig., 686 F.3d 1115, 1119 (9th Cir. 2012)1), and therefore the appropriate
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See also In re High-Tech Employee Antitrust Litig., No. 11-CV-02509, 2013 U.S. Dist. LEXIS
6606, at *8 (N.D. Cal. Jan. 15, 2013) (“Plaintiffs’ Motion for Class Certification is a
nondispositive motion. Therefore, the parties need only demonstrate ‘good cause’ in order to
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Footnote continued on next page

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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legal standard is “good cause,” which Facebook respectfully submits is satisfied. See Kamakana v.

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City and County of Honolulu, 447 F.3d 1172, 1180 (9th Cir. 2006) (“A ‘good cause’ showing will

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suffice to seal documents produced in discovery. Fed.R.Civ.P.26(c) (stating that if ‘good cause’ is

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shown in discovery, a district court may issue ‘any order which justice requires to protect a party or

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person from annoyance, embarrassment, oppression, or undue burden or expense’).”). For the benefit

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of the Court, to the extent possible I discuss the documents by category.

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Plaintiffs’ Motion for Class Certification

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3.

Good cause exists to seal portions of Plaintiffs’ Motion for Class Certification.

Specifically, the following portions contain non-public, confidential, and proprietary Facebook

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business information that Facebook designated as HIGHLY CONFIDENTIAL – ATTORNEYS’

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EYES ONLY pursuant to the Protective Order. The public does not have a meaningful interest in

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obtaining such information, and public disclosure of this information would cause particularized

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harm to Facebook by allowing its competitors to access sensitive information, which they could use

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to gain an unfair advantage against Facebook. Such information could also be used by individuals or

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companies that might seek to compromise the security of Facebook’s messages technology, causing

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harm to Facebook and the people who use Facebook’s services:

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Sealable Portions
ii:8-9

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1:12-13
1:13-15

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1:16-17
1:18-19

Reason for Confidentiality
This information concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
This information concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
This information concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
This information concerns the internal processes and functionality of

Footnote continued from previous page
support their requests to seal.”); In re NCAA Student-Athlete Name & Likeness Licensing Litig.,
No. 09-cv-01967, 2013 U.S. Dist. LEXIS 85375, at *11 (N.D. Cal. June 17, 2013) (“Courts in
this district have generally considered motions for class certification nondispositive.”).
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
2:2-3
2:5-6

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2:8-10
3:11-12

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3:17-18

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4:8-9
4:9-14

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4:15-22

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5:1-3

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5:3-6
5:6-8

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5:10-12

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5:12-14
5:14-15

Reason for Confidentiality
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is from the Declaration of Dale
Harrison on Behalf of Defendant Facebook, Inc. (“Harrison Declaration”)
and does not need to be sealed, per the Magistrate Judge’s previous order
regarding the parties’ Administrative Motions to Seal (Dkt. No. 131).
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
Only the text following “Once a URL has been detected” needs to be
sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law
Only the text following “Facebook detects” needs to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
Only the text between “did not need to” and “to process or send the
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions

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5:15-16

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5:18

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fn. 14 at 5:27-28
6:4-6

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6:6-9

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6:10-12

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6:20-21

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7:1-2

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7:3-4
7:4-14
7:15-16

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7:19-21

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7:22
fn. 22 at 7:23-24

Reason for Confidentiality
message, and” needs to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is from the Harrison Declaration
and does not need to be sealed, per the Court’s previous order regarding
the parties’ Administrative Motions to Seal (Dkt. No. 131).
The information redacted by Plaintiffs is from the Harrison Declaration
and does not need to be sealed, per the Court’s previous order regarding
the parties’ Administrative Motions to Seal (Dkt. No. 131).
The information redacted by Plaintiffs is from the Harrison Declaration
and does not need to be sealed, per the Court’s previous order regarding
the parties’ Administrative Motions to Seal (Dkt. No. 131).
The information redacted by Plaintiffs is the deposition testimony of a
Facebook employee and concerns the internal processes and functionality
of Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
fn. 23 at 7:24-25
fn. 23 at 7:25-26

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fn. 24 at 7:26-28

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8:1-9
8:9-10

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8:14

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8:16-17

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8:21-23
fn. 26 at 8:24

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fn. 26 at 8:24-25

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9:4-7
9:10
9:10-11
9:12-13
9:15-16

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fn. 31 at 9:17-18

Reason for Confidentiality
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law. .
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is the deposition testimony of a
Facebook employee and concerns the internal processes and functionality
of Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
fn. 31 at 9:19

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fn. 31 at 9:19-20
fn. 32 at 9:21-23

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7

fn. 33 at 9:24-25

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fn. 37 at 9:28-10:21

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10:2

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10:3-5

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10:6
10:7
10:8

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10:9-10
10:10-11
fn. 38 at 10:21-24

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fn. 40 at 10:26-27

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11:17
fn. 43 at 11:25-26

Reason for Confidentiality
is entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed, per the
Court’s previous order regarding the parties’ Administrative Motions to
Seal (Dkt. No. 131).
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the technical aspects of Facebook’s targeted advertising
functionality that is protectable as a trade secret or otherwise entitled to
protection under the law
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
13:20
15:7
15:9
fn. 48 at 15:24

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fn. 48 at 15:25-26

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fn. 48 at 15:27
fn. 49 at 15:27-28
17:3
17:5-6
17:15
fn. 51 at 17:25-26

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fn. 52 at 17:26-28

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19:23-24

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20:13-16

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20:17-19

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20:20-22
20:23-25

Reason for Confidentiality
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is the deposition testimony of a
Facebook employee and concerns the internal processes and functionality
of Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
fn. 57 at 23:20-22

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fn. 57 at 23:22-23
fn. 57 at 23:23
fn. 57 at 23:23-25

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The Golbeck Report
4.

Facebook designated as HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY or HIGHLY
CONFIDENTIAL – SOURCE CODE pursuant to the Protective Order. The public does not have a
meaningful interest in obtaining such information, and public disclosure of this information would
cause particularized harm to Facebook by allowing its competitors to access sensitive information,
which they could use to gain an unfair advantage against Facebook. Such information could also be
used by individuals or companies that might seek to compromise the security of Facebook’s
messages technology, causing harm to Facebook and the people who use Facebook’s services.
Sealable Portions
i:8
i:10-11

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23

i:12
i:13-14
i:15

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4:19-21

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Good cause exists to seal portions of the Golbeck Report. Specifically, the following

portions contain non-public, confidential, and proprietary Facebook business information that

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Reason for Confidentiality
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.
The information redacted by Plaintiffs is a Facebook internal discussion of
business and engineering decisions regarding Facebook’s technology that
is entitled to protection under the law.

5:7-18
5:20-21

Reason for Confidentiality
The information redacted by Plaintiffs concerns the internal processes
and functionality of Facebook’s messages technology that is protectable
as a trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes
and functionality of Facebook’s messages technology that is protectable
as a trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes
and functionality of Facebook’s messages technology that is protectable
as a trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the internal processes
and functionality of Facebook’s messages technology that is protectable
as a trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the internal processes
and functionality of Facebook’s messages technology that is protectable
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
5:23-6:2

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5
6
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6:10-13

8
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6:14-24

10
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7:1-5
7:6-8

12
13

7:9-16

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7:18-19
fn. 10 at 7:26

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8:1-12
8:14-15
8:15-17

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8:18-20

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8:21-22

Reason for Confidentiality
as a trade secret or otherwise entitled to protection under the law.
This information redacted by Plaintiffs contains portions of Facebook’s
Supplemental Responses and Objections to Plaintiffs’ First Set of
Interrogatories, and there is good cause for this information to be sealed,
per the Court’s previous order regarding the parties’ Administrative
Motions to Seal (Dkt. No. 131). The referenced portion of Facebook’s
discovery responses concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law. This
information also contains portions of Facebook’s Supplemental
Responses and Objections to Plaintiffs’ First Set of Interrogatories, and
there is good cause for this information to be sealed, per the Court’s
previous order regarding the parties’ Administrative Motions to Seal
(Dkt. No. 131). The referenced portion of Facebook’s discovery
responses concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
9

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2
3
4

Sealable Portions
8:24
8:25

5
6

9:3-12

7
8

9:13-14

9
10

9:14-15

11
12
13
14

9:16
9:24-25
9:25

15
16

9:25-10:1

17
18

fn. 15 at 9:26-27

19
20

10:1-2

21
22
23
24
25

10:2-3
10:5-6
10:07

26
27
28
Gibson, Dunn &
Crutcher LLP

10:7-8

Reason for Confidentiality
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
10

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2

Sealable Portions
10:8

3
4
5

10:8-12
10:13-26

6
7

11:1-12

8
9

11:14

10
11

11:14-15
11:19

12
13

11:20

14
15

11:21-22

16
17

fn. 19 at 11:25-26

18
19

fn. 19 at 11:26

20
21

fn. 19 at 11:27-28

22
23
24

12:1-2

25
26

12:3

27
28
Gibson, Dunn &
Crutcher LLP

12:5-7

Reason for Confidentiality
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs contains portions of Facebook’s
Second Supplemental Responses and Objections to Plaintiffs’ Narrowed
Second Set of Interrogatories. The referenced portion of Facebook’s
discovery responses concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
11

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2
3
4

Sealable Portions
12:9-10
12:12

5
6

12:13-15

7
8
9
10
11

12:16
12:18-19
12:20-22

12
13

12:22-23

14
15
16
17

12:23-25
12:26-27

18
19
20
21
22

fn. 22 at 12:28
13:1
13:2

23
24
25

13:3-4

26
27
28
Gibson, Dunn &
Crutcher LLP

13:5

Reason for Confidentiality
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
12

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2
3

Sealable Portions
13:6-8

4
5

13:9

6
7
8

13:9-11
13:11-13

9
10
11

13:14

12
13

13:15

14
15

13:16-18

16
17
18
19

13:19-21
13:22-23

20
21

14:1

22
23

14:1-2

24
25
26
27
28
Gibson, Dunn &
Crutcher LLP

14:03
14:04

Reason for Confidentiality
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
13

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1

Sealable Portions
14:05

2
3
4

14:6-9

5
6

14:10-11

7
8

14:12-14

9
10

14:19-21

11
12
13
14
15

14:22
14:23-28
15:1

16
17

15:2-7

18
19
20
21
22

15:8-11
15:13-14
15:15-18

23
24

15:19-20

25
26
27
28
Gibson, Dunn &
Crutcher LLP

15:21-25
15:26-27

Reason for Confidentiality
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
14

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2
3
4

Sealable Portions
16:1-5
16:6-9

5
6

16:10-14

7
8
9
10
11

16:15-16
16:17-19
16:20-21

12
13
14

16:22-27

15
16

17:1-3

17
18

17:5

19
20
21

17:5-6

22
23

17:6-11

24
25
26
27
28
Gibson, Dunn &
Crutcher LLP

17:12-14
17:15-18

Reason for Confidentiality
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs testimony is deposition testimony
of a Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
15

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1

Sealable Portions
18:1-11

2
3
4

18:13-17

5
6

18:18-22

7
8

18:23-19:7

9
10
11

19:8-9

12
13

19:10-16

14
15

19:17-20

16
17
18
19
20
21
22

19:21-24
19:25-28
20:2-22
20:23-24
21:11-17
21:18-24

23
24

22:1-4

25
26
27
28
Gibson, Dunn &
Crutcher LLP

22:5-15

Reason for Confidentiality
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
16

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1

Sealable Portions
22:16-25

2
3
4
5

23:8-26
24:1-14

6
7

24:15-20

8
9

24:21-25:2

10
11

25:3-6

12
13
14

25:7-12

15
16

25:14-17

17
18

25:18

19
20

25:19-22

21
22

25:24-26:2

23
24

26:3-7

25
26
27
28
Gibson, Dunn &
Crutcher LLP

26:8-13

Reason for Confidentiality
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns business and
engineering decisions regarding Facebook’s messages technology that is
entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs concerns business and
engineering decisions regarding Facebook’s messages technology that is
entitled to protection under the law.
The information redacted by Plaintiffs concerns a Facebook internal
discussion of the processes and functionality of Facebook’s messages
technology that is protectable as a trade secret or otherwise entitled to
protection under the law.
17

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2

Sealable Portions
26:15-16
26:17-19

3
4
5

26:20
26:21-22

6
7

26:24-26

8
9

26:27

10
11

27:1-3

12
13

27:4-8

14
15
16

27:9-11
27:13

17
18
19

27:14-15
27:16-25

20
21

28:1-3

22
23
24

28:4-10

25
26

28:11-13

27
28
Gibson, Dunn &
Crutcher LLP

28:20-21

Reason for Confidentiality
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
The information redacted by Plaintiffs concerns Facebook’s internal
documentation of the processes and functionality of Facebook’s
messages technology that is protectable as a trade secret or otherwise
entitled to protection under the law.
This information contains the Facebook identification information of a
named Plaintiff, and the Court previously found there is good cause to
seal information showing Facebook identifications. (Dkt. No. 131).
The information redacted by Plaintiffs concerns the processes and
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
28:24-26
28:27

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29:2

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29:3 (from beginning
of line to “If so”)
29:3 (between “If so,
the” and “Facebook
user’s ID could be
selected”)
29:4-9
29:11
29:12-13
29:16
29:17
29:18
29:19
30:4
30:7-14

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30:15-22

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30:24

Reason for Confidentiality
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
This information contains portions of Facebook’s Second Supplemental
Responses and Objections to Plaintiffs’ Narrowed Second Set of
Interrogatories. The referenced portion of Facebook’s discovery
responses concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
This information contains portions of Facebook’s Second Supplemental
Responses and Objections to Plaintiffs’ Narrowed Second Set of
Interrogatories. The referenced portion of Facebook’s discovery
responses concerns the internal processes and functionality of
Facebook’s messages technology that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
30:25

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31:1
31:3-4

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31:8-10

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31:11-13

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31:14-19

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32:16

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32:17-18
32:20
32:21-22

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fn. 50 at 32:26-27

Reason for Confidentiality
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
20

DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Sealable Portions
33:1-2
33:3-4

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33:4

7
8

fn. 53 at 33:27-28

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Reason for Confidentiality
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs concerns the processes and
functionality of Facebook’s source code that is protectable as a trade
secret or otherwise entitled to protection under the law.
The information redacted by Plaintiffs is deposition testimony of a
Facebook employee and concerns the internal processes and
functionality of Facebook’s messages technology that is protectable as a
trade secret or otherwise entitled to protection under the law.

The Torres Report
5.

Good cause exists to seal portions of the Torres Report. Specifically, the following

portions contain non-public, confidential, and proprietary Facebook business information that
Facebook designated as HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY pursuant to the
Protective Order. The public does not have a meaningful interest in obtaining such information, and
public disclosure of this information would cause particularized harm to Facebook by allowing its
competitors to access sensitive information, which they could use to gain an unfair advantage against
Facebook. Such information could also be used by individuals or companies that might seek to
compromise the security of Facebook’s messages technology, causing harm to Facebook and the
people who use Facebook’s services.

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Sealable Portions
3:7-9
3:13-14

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12:1-9
12:11-12

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fn. 54 at 12:22-23

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fn. 55 at 12:24

Text
The information redacted by Plaintiffs does not need to be sealed.
This information concerns the processes and functionality of Facebook’s
source code that is protectable as a trade secret or otherwise entitled to
protection under the law.
The information redacted by Plaintiffs does not need to be sealed.
The information concerns a Facebook internal discussion regarding
Facebook’s social plugin tools that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information concerns a Facebook internal discussion regarding
Facebook’s social plugin tools that is protectable as a trade secret or
otherwise entitled to protection under the law.
The information concerns a Facebook internal discussion regarding
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1
2
3
4

Sealable Portions
13:5-8
fn. 83 at 18:23-25

5

The information concerns a Facebook internal discussion regarding
Facebook’s social plugin tools that is protectable as a trade secret or
otherwise entitled to protection under the law.

6
7
8
9

Text
Facebook’s social plugin tools that is protectable as a trade secret or
otherwise entitled to protection under the law.
This information concerns the processes and functionality of Facebook’s
source code that is protectable as a trade secret or otherwise entitled to
protection under the law.
Only the text following “From the document production” needs to be
redacted.

Facebook’s Supplemental Discovery Responses
6.

Good cause exists to seal the information redacted by Plaintiffs within the columns

10

entitled “To,” “From,” “Date,” “URL” in Exhibit 1 to Facebook’s Supplemental Discovery

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Responses, as the Court previously held that there was good cause to seal the identifying information

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about the senders and recipients on the messages included in Exhibit 1, as well as the time and date of

13

the messages, and the URL contained in the messages. (Dkt. No. 131.) As the Magistrate Judge

14

noted in her prior order, the exposure of the redacted information in Exhibit 1 to Facebook’s

15

Supplemental Discovery Responses “risks subjecting the persons identified in this document to

16

annoyance, embarrassment, or other significant harm, and the public has no meaningful need to

17

obtain this information at this time.” Id.

18

Exhibits to the Gardner Cert. Declaration

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7.

Good cause exists to seal Exhibits 4-18, 27-30, and 34-35 to the Gardner Cert.

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Declaration (Exhibits I through DD to the Gardner Declaration in support of Plaintiffs’ motion to

21

seal) under seal in their entirety for the reasons specified below. Specifically, the Exhibits contain

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non-public, confidential, and proprietary Facebook business information that Facebook designated as

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HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY pursuant to the Protective Order. The

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public does not have a meaningful interest in obtaining such information, and public disclosure of

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this information would cause particularized harm to Facebook by allowing its competitors to access

26

sensitive information, which they could use to gain an unfair advantage against Facebook. Such

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information could also be used by individuals or companies that might seek to compromise the

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Crutcher LLP

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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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security of Facebook’s messages technology, causing harm to Facebook and the people who use

2

Facebook’s services.

3

8.

Plaintiffs also proposed to file Exhibit 3 to the Gardner Cert. Declaration—Facebook’s

4

Supplemental Responses and Objections to Plaintiffs’ First Set of Interrogatories (Exhibit H to the

5

Gardner Declaration in support of Plaintiffs’ motion to seal)—under seal in its entirety, but the

6

Magistrate Judge previously held that there was good cause to seal only certain portions of Exhibit 3,

7

as those portions contain potential trade secrets or otherwise protectable information relating to

8

Facebook’s internal processes and tools that risk particularized harm to Facebook if revealed, and

9

which the public does not at this time have a particular interest in obtaining. (Dkt. No. 131.)

10

Accordingly, in conformity with the Court’s prior order, good cause exists to seal only the following

11

portions of Exhibit 3 to the Gardner Cert. Declaration: 3:23-24; 5:24 (the text following “defenses in

12

this action”)-27; 8:9-25; 9:18-11:24; 12:26-16:13; 17:9-20:24; 21:24-25:11; 26:7-29:22; 30:23-33:4;

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33:27-36:15; 37:15-38:18; 39:15-40:18; 41:15-42:18; 43:13-44:16; 45:16-21; and 46:18-23.

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Document to Be Sealed
Exhibit J
(Gardner Cert. Decl. Exhibit 4—
FB000005502-R)

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Exhibit K
(Gardner Cert. Decl. Exhibit 5—
He Deposition Transcript)

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Exhibit L
(Gardner Cert. Decl. Exhibit 6—
FB000008489)

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Exhibit M

Reasons for Confidentiality
This document contains detailed technical information about
the functionality of Facebook’s messages products and
internal tools that is protectable as a trade secret or otherwise
entitled to protection under the law. The document also
contains information about a named Plaintiff’s Facebook
message, including the time and date of the message, as the
URL contained in that message. As the Court noted in its
prior order, the exposure of such information “risks subjecting
the persons identified in this document to annoyance,
embarrassment, or other significant harm, and the public has
no meaningful need to obtain this information at this time.”
(Dkt. No. 131).
This document contains the deposition testimony of a
Facebook employee that concerns the processes and
functionality of Facebook’s source code and that is protectable
as a trade secret or otherwise entitled to protection under the
law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
technology and the internal processes and functionality of
Facebook’s messages technology that is entitled to protection
under the law.
This document contains a Facebook internal discussion of
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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Document to Be Sealed
(Gardner Cert. Decl. Exhibit 7—
FB000003118)

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Exhibit N
(Gardner Cert. Decl. Exhibit 8—
FB000014365)
Exhibit O
(Gardner Cert. Decl. Exhibit 9—
FB000003335)
Exhibit P
(Gardner Cert. Decl. Exhibit
10—
FB000004996)
Exhibit Q
(Gardner Cert. Decl. Exhibit
11—
FB000012539)
Exhibit R
(Gardner Cert. Decl. Exhibit
12—
FB000008268)
Exhibit S
(Gardner Cert. Decl. Exhibit
13—
FB000008722)
Exhibit T
(Gardner Cert. Decl. Exhibit
14—
FB000000594)
Exhibit U
(Gardner Cert. Decl. Exhibit
15—
FB000008304)
Exhibit V
(Gardner Cert. Decl. Exhibit
16—FB000001265)
Exhibit W
(Gardner Cert. Decl. Exhibit
17—
FB000006429)
Exhibit X
(Gardner Cert. Decl. Exhibit
18—
FB000008271)

Reasons for Confidentiality
business and engineering decisions regarding Facebook’s
technology and the internal processes and functionality of
Facebook’s messages technology that is entitled to protection
under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
technology that is entitled to protection under the law.
This document contains a Facebook internal discussion of
engineering decisions regarding Facebook’s social plugin
technology that is entitled to protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin technology that is entitled to protection under the
law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and other technology that is entitled to protection
under the law.
This document contains Facebook’s internal documentation of
the technical aspects of Facebook’s targeted advertising
functionality that is protectable as a trade secret or otherwise
entitled to protection under the law.
This document does not need to be sealed.

This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin technology that is entitled to protection under the
law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

1

Document to Be Sealed

Reasons for Confidentiality

Exhibit Y
(Gardner Cert. Decl. Exhibit
27—FB000006435)

This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains a Facebook internal discussion of
business and engineering decisions regarding Facebook’s
social plugin and messages technology that is entitled to
protection under the law.
This document contains detailed technical information about
the functionality of Facebook’s messages products and
internal tools that is protectable as a trade secret or otherwise
entitled to protection under the law. The document also
contains information about a named Plaintiff’s Facebook
message, including the time and date of the message, as the
URL contained in that message. As the Court noted in its
prior order, the exposure of such information “risks subjecting
the persons identified in this document to annoyance,
embarrassment, or other significant harm, and the public has
no meaningful need to obtain this information at this time.”
(Dkt. No. 131).

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Exhibit Z
(Gardner Cert. Decl. Exhibit
28—FB000004406)
Exhibit AA
(Gardner Cert. Decl. Exhibit
29—
FB000007924)
Exhibit BB
(Gardner Cert. Decl. Exhibit
30—
FB000000502)
Exhibit CC
(Gardner Cert. Decl. Exhibit
34—FB00000802)
Exhibit DD
(Gardner Cert. Decl. Exhibit
35—FB000005802-R)

I declare under penalty of perjury under the laws of the United States of America and the
State of California that the foregoing is true and correct, and that I executed this Declaration in Menlo
Park, California on November 17, 2015.
/s/ Nikki Stitt Sokol
Nikki Stitt Sokol

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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)

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ATTORNEY ATTESTATION
I, Joshua A. Jessen, attest that concurrence in the filing of this Declaration of Nikki Stitt Sokol
has been obtained from the signatory. I declare under penalty of perjury under the laws of the United
States of America that the foregoing is true and correct. Executed this 17th day of November 2015,
in Irvine, California.
Dated: November 17, 2015

/s/ Joshua A. Jessen
Joshua A. Jessen

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DECLARATION OF NIKKI STITT SOKOL IN SUPPORT OF PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE
DOCUMENTS UNDER SEAL – DKT. NO. 137
Case No. C 13-05996 PJH (MEJ)