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)
1
2
3
4
5
6
7
8
9
10
11
12
13
GIBSON, DUNN & CRUTCHER LLP
JOSHUA A. JESSEN, SBN 222831
JJessen@gibsondunn.com
JEANA BISNAR MAUTE, SBN 290573
JBisnarMaute@gibsondunn.com
PRIYANKA RAJAGOPALAN, SBN 278504
PRajagopalan@gibsondunn.com
ASHLEY M. ROGERS, SBN 286252
ARogers@gibsondunn.com
1881 Page Mill Road
Palo Alto, California 94304
Telephone: (650) 849-5300
Facsimile: (650) 849-5333
GIBSON, DUNN & CRUTCHER LLP
CHRISTOPHER CHORBA, SBN 216692
CChorba@gibsondunn.com
333 South Grand Avenue
Los Angeles, California 90071
Telephone: (213) 229-7000
Facsimile: (213) 229-7520
Attorneys for Defendant
FACEBOOK, INC.
14
UNITED STATES DISTRICT COURT
15
NORTHERN DISTRICT OF CALIFORNIA
16
OAKLAND DIVISON
17
18
19
20
21
22
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
23
24
25
26
27
28
Gibson, Dunn &
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)
1
I, Nikki Stitt Sokol, declare as follows:
2
1.
I am Associate General Counsel for Litigation for Defendant Facebook, Inc.
3
(“Facebook”). Pursuant to Civil Local Rule 79-5(d) and the Amended Stipulated Protective Order
4
entered by the Court on July 1, 2015 (the “Protective Order”) (Dkt. No. 93), I submit this Declaration
5
in support of Plaintiffs’ Administrative Motion to File Under Seal re Plaintiffs’ Motion for Class
6
Certification and Supporting Documents (Dkt. No. 137), which seeks to file under seal (1) designated
7
portions of Plaintiffs’ Motion for Class Certification (Dkt. No. 138); (2) designated portions of the
8
Expert Report of Jennifer Golbeck in support of Plaintiffs’ Motion for Class Certification (“Golbeck
9
Report”), which is Exhibit 2 to the Declaration of Melissa Gardner in support of Plaintiffs’ Motion
10
for Class Certification (“Gardner Cert. Declaration”); (3) designated portions of the Expert Report of
11
Fernando Torres in support of Plaintiffs’ Motion for Class Certification (“Torres Report”), which is
12
13
14
15
16
17
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.
18
19
20
21
22
23
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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
1
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
1
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)
1
legal standard is “good cause,” which Facebook respectfully submits is satisfied. See Kamakana v.
2
City and County of Honolulu, 447 F.3d 1172, 1180 (9th Cir. 2006) (“A ‘good cause’ showing will
3
suffice to seal documents produced in discovery. Fed.R.Civ.P.26(c) (stating that if ‘good cause’ is
4
shown in discovery, a district court may issue ‘any order which justice requires to protect a party or
5
person from annoyance, embarrassment, oppression, or undue burden or expense’).”). For the benefit
6
of the Court, to the extent possible I discuss the documents by category.
7
Plaintiffs’ Motion for Class Certification
8
9
3.
Good cause exists to seal portions of Plaintiffs’ Motion for Class Certification.
Specifically, the following portions contain non-public, confidential, and proprietary Facebook
10
business information that Facebook designated as HIGHLY CONFIDENTIAL – ATTORNEYS’
11
EYES ONLY pursuant to the Protective Order. The public does not have a meaningful interest in
12
obtaining such information, and public disclosure of this information would cause particularized
13
harm to Facebook by allowing its competitors to access sensitive information, which they could use
14
to gain an unfair advantage against Facebook. Such information could also be used by individuals or
15
companies that might seek to compromise the security of Facebook’s messages technology, causing
16
harm to Facebook and the people who use Facebook’s services:
17
18
Sealable Portions
ii:8-9
19
20
21
1:12-13
1:13-15
22
23
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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.”).
2
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
2:2-3
2:5-6
5
6
7
8
2:8-10
3:11-12
9
10
3:17-18
11
12
13
14
4:8-9
4:9-14
15
16
17
4:15-22
18
19
20
5:1-3
21
22
23
5:3-6
5:6-8
24
25
5:10-12
26
27
28
Gibson, Dunn &
Crutcher LLP
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
3
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
2
3
4
5:15-16
5
6
5:18
7
8
9
fn. 14 at 5:27-28
6:4-6
10
11
6:6-9
12
13
6:10-12
14
15
6:20-21
16
17
7:1-2
18
19
20
21
22
7:3-4
7:4-14
7:15-16
23
24
7:19-21
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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
4
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
fn. 23 at 7:24-25
fn. 23 at 7:25-26
5
6
fn. 24 at 7:26-28
7
8
9
8:1-9
8:9-10
10
11
8:14
12
13
8:16-17
14
15
16
8:21-23
fn. 26 at 8:24
17
18
fn. 26 at 8:24-25
19
20
21
22
23
24
25
9:4-7
9:10
9:10-11
9:12-13
9:15-16
26
27
28
Gibson, Dunn &
Crutcher LLP
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
5
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
fn. 31 at 9:19
3
4
5
fn. 31 at 9:19-20
fn. 32 at 9:21-23
6
7
fn. 33 at 9:24-25
8
9
fn. 37 at 9:28-10:21
10
11
10:2
12
13
10:3-5
14
15
16
17
10:6
10:7
10:8
18
19
20
21
10:9-10
10:10-11
fn. 38 at 10:21-24
22
23
fn. 40 at 10:26-27
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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.
6
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
13:20
15:7
15:9
fn. 48 at 15:24
5
6
fn. 48 at 15:25-26
7
8
9
10
11
12
13
14
15
fn. 48 at 15:27
fn. 49 at 15:27-28
17:3
17:5-6
17:15
fn. 51 at 17:25-26
16
17
fn. 52 at 17:26-28
18
19
19:23-24
20
21
20:13-16
22
23
20:17-19
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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.
7
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
fn. 57 at 23:20-22
2
3
4
5
fn. 57 at 23:22-23
fn. 57 at 23:23
fn. 57 at 23:23-25
6
7
8
9
10
11
12
13
14
15
16
17
18
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
21
22
23
i:12
i:13-14
i:15
24
25
4:19-21
26
27
28
Gibson, Dunn &
Crutcher LLP
Good cause exists to seal portions of the Golbeck Report. Specifically, the following
portions contain non-public, confidential, and proprietary Facebook business information that
19
20
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
8
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
5:23-6:2
3
4
5
6
7
6:10-13
8
9
6:14-24
10
11
7:1-5
7:6-8
12
13
7:9-16
14
15
7:18-19
fn. 10 at 7:26
16
17
18
19
20
8:1-12
8:14-15
8:15-17
21
22
23
24
25
26
8:18-20
27
28
Gibson, Dunn &
Crutcher LLP
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
18
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
28:24-26
28:27
5
6
29:2
7
8
9
10
11
12
13
14
15
16
17
18
19
20
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
21
22
23
24
30:15-22
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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
19
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
30:25
3
4
5
31:1
31:3-4
6
7
31:8-10
8
9
10
31:11-13
11
12
31:14-19
13
14
31:20-23
15
16
17
31:24-32:2
18
19
32:3-7
20
21
32:16
22
23
24
25
32:17-18
32:20
32:21-22
26
27
28
Gibson, Dunn &
Crutcher LLP
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)
1
2
3
4
Sealable Portions
33:1-2
33:3-4
5
6
33:4
7
8
fn. 53 at 33:27-28
9
10
11
12
13
14
15
16
17
18
19
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.
20
21
22
Sealable Portions
3:7-9
3:13-14
23
24
12:1-9
12:11-12
25
26
fn. 54 at 12:22-23
27
28
Gibson, Dunn &
Crutcher LLP
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
21
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
11
Responses, as the Court previously held that there was good cause to seal the identifying information
12
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
19
7.
Good cause exists to seal Exhibits 4-18, 27-30, and 34-35 to the Gardner Cert.
20
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
22
non-public, confidential, and proprietary Facebook business information that Facebook designated as
23
HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY pursuant to the Protective Order. The
24
public does not have a meaningful interest in obtaining such information, and public disclosure of
25
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
27
information could also be used by individuals or companies that might seek to compromise the
28
Gibson, Dunn &
Crutcher LLP
22
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
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;
13
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.
14
15
16
Document to Be Sealed
Exhibit J
(Gardner Cert. Decl. Exhibit 4—
FB000005502-R)
17
18
19
20
21
22
23
Exhibit K
(Gardner Cert. Decl. Exhibit 5—
He Deposition Transcript)
24
25
26
Exhibit L
(Gardner Cert. Decl. Exhibit 6—
FB000008489)
27
28
Gibson, Dunn &
Crutcher LLP
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
23
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
Document to Be Sealed
(Gardner Cert. Decl. Exhibit 7—
FB000003118)
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
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.
24
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).
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
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
25
26
27
28
Gibson, Dunn &
Crutcher LLP
25
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
5
6
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
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Gibson, Dunn &
Crutcher LLP
26
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)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?