Campbell et al v. Facebook Inc.

Filing 179

Joint Notice of Refiling of Documents Accompanying Class Certification Briefs and Evidentiary Objections. (Attachments: # 1 Exhibit 1 (Redacted), # 2 Exhibit 2 (Redacted), # 3 Exhibit 3 (Redacted), # 4 Exhibit 4 (Redacted), # 5 Exhibit 5 (Redacted), # 6 Exhibit 6 (Redacted), # 7 Exhibit 7 (Redacted), # 8 Exhibit 8 (Unredacted), # 9 Exhibit 9 (Unredacted), # 10 Exhibit 10 (Redacted), # 11 Exhibit 11 (Redacted), # 12 Exhibit 12 (Redacted), # 13 Exhibit 13 (Redacted), # 14 Exhibit 14 (Redacted), # 15 Exhibit 15 (Redacted), # 16 Exhibit 16 (Redacted), # 17 Exhibit 17 (Redacted), # 18 Exhibit 18 (Redacted), # 19 Exhibit 19 (Unredacted), # 20 Exhibit 20 (Redacted), # 21 Exhibit 21 (Redacted), # 22 Exhibit 22 (Unredacted), # 23 Exhibit 23 (Redacted), # 24 Exhibit 24 (Redacted), # 25 Exhibit 25 (Unredacted))(Chorba, Christopher) (Filed on 3/28/2016) Modified on 3/29/2016 (kcS, COURT STAFF).

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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 and MICHAEL
HURLEY,
Plaintiffs,
v.

Case No. C 13-05996 PJH
JOINT NOTICE OF REFILING OF
DOCUMENTS ACCOMPANYING CLASS
CERTIFICATION BRIEFS AND
EVIDENTIARY OBJECTIONS

FACEBOOK, INC.,
Defendant.

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Crutcher LLP

JOINT NOTICE OF REFILING OF DOCUMENTS ACCOMPANYING CLASS CERTIFICATION BRIEFS AND EVIDENTIARY
OBJECTIONS - Case No. C 13-05996 PJH

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Pursuant to the discussion at the hearing on Plaintiffs’ Motion for Class Certification held on

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March 16, 2016, and this Court’s Minute Order dated March 16, 2016 (Dkt. 174), Plaintiffs and

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Defendant Facebook, Inc. jointly file replacement versions of the following documents

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accompanying their class certification briefs and evidentiary objections:

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(1) Plaintiffs’ Motion for Class Certification (Dkt. 178-1): Exhibits 3, 6-18, 27-30, and 33-

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34 to the Declaration of Melissa Gardner in Support of Plaintiffs’ Motion for Class Certification

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(“Gardner Cert. Declaration”);

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(2) Defendant Facebook, Inc.’s Opposition to Plaintiffs’ Motion for Class Certification

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(Dkt. 178-2): Exhibits A, B, L, N, R, U, BB, CC, DD, FF, II, JJ, KK, and LL to the Declaration of

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Christopher Chorba In Support of Defendant Facebook, Inc.’s Opposition to Plaintiffs’ Motion for

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Class Certification (“Chorba Declaration”); Exhibit NN to the Declaration of Alex Himel In Support
of Defendant Facebook, Inc.’s Opposition to Plaintiffs’ Motion for Class Certification (“Himel
Declaration”); and
(3) Plaintiffs’ Reply in Support of Motion for Class Certification (Dkt. 178-3): Exhibits
2, 6-11, and 14-20 to the Declaration of David Slade in Support of Plaintiffs’ Motion for Class
Certification (“Slade Cert. Declaration”); and the Supplemental Declaration of Melissa Gardner in
Support of Plaintiffs’ Motion for Class Certification (“Supplemental Gardner Cert. Declaration”); and
(4) Defendant Facebook, Inc.’s Objection to and Request to Strike New Evidence and
Misstatements of Fact Contained in Plaintiffs’ Reply in Support of their Motion for Class
Certification (Dkt. 178-4): The Declaration of Dale Harrison In Support of Defendant Facebook,
Inc.’s Objection to and Request to Strike New Evidence and Misstatements of Fact in Plaintiffs’
Reply in Support Of Their Motion For Class Certification (“Harrison Declaration”).
In its Minute Order, this Court ordered that “all of the administrative motions to seal (Dkt.
137, 147, 166, 169 and 171) are denied without prejudice to filing a limited, narrowly tailored request
for sealing as stated on the record.” (Dkt. 174.) The Court also ordered that “[t]he briefs shall be
filed unredacted in the public record by Monday 3/21/16,” and that while a new motion to seal must
be filed “for any request to seal trade secrets,” the Court would “allow redactions of source code,
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JOINT NOTICE OF REFILING OF DOCUMENTS ACCOMPANYING CLASS CERTIFICATION BRIEFS AND EVIDENTIARY
OBJECTIONS - Case No. C 13-05996 PJH

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names, addresses and phone numbers without a Court order.” (Id.) There are three filings to comply

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with the Court’s Minute Order:

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(1) Briefing: On March 21, 2016, the parties filed a joint notice containing replacement

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versions of their class certification briefs and evidentiary objections that contained corrected

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redactions consistent with the Court’s Minute Order (i.e., redactions the Court authorized to be made

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without a Court Order). (See Dkt. 178.) In that joint notice, the parties notified the Court in their

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filing that they were in the process of conferring about filing a joint administrative motion to seal

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limited portions of the documents accompanying their class certification briefs and evidentiary

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objections that would be consistent with the Court’s Order, and that they would file that motion by

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March 28, 2016. (Id.)

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(2) Evidence with Approved Redactions: This joint notice contains replacement versions of

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the documents accompanying the parties’ class certification briefs and evidentiary objections that

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contain corrected redactions (if any) consistent with the Court’s Minute Order (i.e., redactions the

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Court authorized to be made without a Court Order). 1

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(3) Evidence with New Motion to Seal: Concurrently with the filing of this joint notice, the

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parties have filed a joint administrative motion to seal limited portions of certain documents

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accompanying the parties’ briefs reflecting redactions that require the Court’s approval (i.e., not fully

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in the categories mentioned in the Court’s Minute Order).

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Plaintiffs’ Motion for Class Certification (Dkt. 178-1)

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Attached as Exhibit 1 is a true and correct copy of a redacted version of Exhibit 3 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-12 and 138-4. The only redactions in Exhibit

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1 are by Facebook, and they are of names of non-parties (specifically, Facebook employees) (see pp.

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8:9; 8:10; 8:12; 8:13; 8:14; 8:15; 8:16; 8:17; 8:19; 8:20; 8:22; 8:23; 9:18; 9:19; 9:21: 9:22; 9:23; 9:24;

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9:25; 9:26; 10:1; 10:2; 10:4; 10:5; 10:6; 10:7; 10:9; 10:10; 10:11; 10:12; 10:14; 10:15; 10:17; 10:18;

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As with the parties’ filing of March 21, 2016, the courtesy copies of this filing will also include
copies of all Exhibits with highlighting that reflects the redactions in the as-filed versions of the
exhibits. For the Court’s convenience, Plaintiffs’ redactions will appear in yellow highlighting,
and Facebook’s redactions will appear in blue highlighting.
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10:20; 10:21; 10:23; 10:24; 11:1; 11:2; 11:4; 11:5; 11:7; 11:8; 11:10; 11:11; 11:13; 11:14; 11:16;

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11:17; 11:19; 11:20; 11:22; 11:23).

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Attached as Exhibit 2 is a true and correct copy of a redacted version of Exhibit 6 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-15 and 138-4. The only redactions in Exhibit

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2 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 3 is a true and correct copy of a redacted version of Exhibit 7 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-16 and 138-4. The only redactions in Exhibit

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3 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 4 is a true and correct copy of a redacted version of Exhibit 8 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-17 and 138-4. The only redactions in Exhibit

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4 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 5 is a true and correct copy of a redacted version of Exhibit 9 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-18 and 138-4. The only redactions in Exhibit

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5 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 6 is a true and correct copy of a redacted version of Exhibit 10 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-19 and 138-4. The only redactions in Exhibit

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6 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 7 is a true and correct copy of a redacted version of Exhibit 11 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-20 and 138-4. The only redactions in Exhibit

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7 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 8 is a true and correct copy of Exhibit 12 to the Gardner Cert.
Declaration, originally filed Dkt. 137-21 and 138-4. Exhibit 8 contains no redactions.
Attached as Exhibit 9 is a true and correct copy of Exhibit 13 to the Gardner Cert.
Declaration, originally filed Dkt. 137-22 and 138-4. Exhibit 9 contains no redactions.
Attached as Exhibit 10 is a true and correct copy of a redacted version of Exhibit 14 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-23 and 138-4. The only redactions in Exhibit 11

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 11 is a true and correct copy of a redacted version of Exhibit 15 to the
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JOINT NOTICE OF REFILING OF DOCUMENTS ACCOMPANYING CLASS CERTIFICATION BRIEFS AND EVIDENTIARY
OBJECTIONS - Case No. C 13-05996 PJH

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Gardner Cert. Declaration, originally filed Dkt. 137-24 and 138-4. The only redactions in Exhibit 11

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 12 is a true and correct copy of a redacted version of Exhibit 16 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-25 and 138-4. The only redactions in Exhibit 12

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 13 is a true and correct copy of a redacted version of Exhibit 17 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-26 and 138-4. The only redactions in Exhibit 13

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 14 is a true and correct copy of a redacted version of Exhibit 18 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-27 and 138-4. The only redactions in Exhibit

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Attached as Exhibit 15 is a true and correct copy of a redacted version of Exhibit 27 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-28 and 138-4. The only redactions in Exhibit 15

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 16 is a true and correct copy of a redacted version of Exhibit 28 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-29 and 138-4. The only redactions in Exhibit 16

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 17 is a true and correct copy of a redacted version of Exhibit 29 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-30 and 138-4. The only redactions in Exhibit 17

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 18 is a true and correct copy of a redacted version of Exhibit 30 to the

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Gardner Cert. Declaration, originally filed at Dkt. 137-31 and 138-4. The only redactions in Exhibit

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18 are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 19 is a true and correct copy of Exhibit 33 to the Gardner Cert.
Declaration, originally filed Dkt. 137-8 and 138-4. Exhibit 19 contains no redactions.
Attached as Exhibit 20 is a true and correct copy of a redacted version of Exhibit 34 to the

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Gardner Cert. Declaration, originally filed Dkt. 137-32 and 138-4. The only redactions in Exhibit 20

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are by Facebook, and they are of names of non-parties (specifically, Facebook employees).

Gibson, Dunn &
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OBJECTIONS - Case No. C 13-05996 PJH

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Defendant Facebook’s Opposition to Plaintiffs’ Motion for Class Certification (Dkt. 178-2):

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Attached as Exhibit 21 is a true and correct copy of a redacted version of Exhibit A to the

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Chorba Declaration, originally filed at Dkt. 150-5 and 158-1. The only redactions in Exhibit 21 are

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by Plaintiffs, and they are of names of non-parties (specifically, absent putative class members).

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Attached as Exhibit 22 is a true and correct copy of Exhibit B to the Chorba Declaration,
originally filed at Dkt. 150-5 and 158-2. Exhibit 22 contains no redactions.

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Attached as Exhibit 23 is a true and correct copy of a redacted version of Exhibit L to the

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Chorba Declaration, originally filed at Dkt. 150-9 and 159-1. The only redactions in Exhibit 23 are

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by Plaintiffs, and they are of names of non-parties (specifically, absent putative class members).

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Attached as Exhibit 24 is a true and correct copy of a redacted version of Exhibit N to the

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Chorba Declaration, originally filed at Dkt. 1501-1 and 159-3. The only redactions in Exhibit 24 are

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by Plaintiffs, and they are of names of non-parties (specifically, absent putative class members).

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Attached as Exhibit 25 is a true and correct copy of Exhibit R to the Chorba Declaration,
originally filed at Dkt. 147-8 and 159-7. Exhibit 25 contains no redactions.

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Attached as Exhibit 26 is a true and correct copy of Exhibit U to the Chorba Declaration,
originally filed at Dkt. 151-6 and 159-10. Exhibit 26 contains no redactions.

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Attached as Exhibit 27 is a true and correct copy of a redacted version of Exhibit BB to the

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Chorba Declaration, originally filed at Dkt. 148-2 and 160-4. The only redactions in Exhibit 27 are

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by Facebook, and they are of the email address of a non-party (specifically, a Facebook employee)

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(see pp. 50:20) and the names of non-parties (specifically, Facebook employees) (see Errata pages 1-

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2).

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Attached as Exhibit 28 is a true and correct copy of a redacted version of Exhibit CC to the

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Chorba Declaration, originally filed at Dkt. 148-4 and 160-5. The only redactions in Exhibit 28 are

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by Facebook, and they are of the names of non-parties (specifically, Facebook employees) (see Errata

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p. 2) and of source code (see Errata pp. 3-4).

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Attached as Exhibit 29 is a true and correct copy of Exhibit DD to the Chorba Declaration,
originally filed at Dkt. 148-6 and 160-6. Exhibit 29 contains no redactions.
Attached as Exhibit 30 is a true and correct copy of a redacted version of Exhibit FF to the
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JOINT NOTICE OF REFILING OF DOCUMENTS ACCOMPANYING CLASS CERTIFICATION BRIEFS AND EVIDENTIARY
OBJECTIONS - Case No. C 13-05996 PJH

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Chorba Declaration, originally filed at Dkt. 150-8 and 160-8. The only redactions in Exhibit 30 are

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by Plaintiffs, and they are of a name of a non-party (specifically, an absent putative class member).

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Attached as Exhibit 31 is a true and correct copy of a redacted version of Exhibit II to the

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Chorba Declaration, originally filed at Dkt. 150-1 and 160-11. The only redactions in Exhibit 31 are

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by Facebook, and they are of source code and source code file names (see pp. 43:10-11; 43:14; 83:5;

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83:10-11; and Errata pp. 2-9).

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Attached as Exhibit 32 is a true and correct copy of a redacted version of Exhibit KK to the

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Chorba Declaration, originally filed at Dkt. 152-1 and 160-13. The only redactions in Exhibit 32 are

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by Facebook, and they are of the names of non-parties (specifically, Facebook employees).

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Attached as Exhibit 33 is a true and correct copy of Exhibit LL to the Chorba Declaration,
originally filed at Dkt. 152-2 and 160-14. Exhibit 33 contains no redactions.
Attached as Exhibit 34 is a true and correct copy of a redacted version of Exhibit NN to the

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Himel Declaration, originally filed at Dkt. 152-8 and 161-2. The only redactions in Exhibit 34 are by

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Facebook, and they are of names of non-parties (specifically, Facebook employees).

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Plaintiffs’ Reply in Support of Motion for Class Certification (Dkt. 178-3)

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Attached as Exhibit 35 is a true and correct copy of Exhibit 2 to the Slade Cert. Declaration,
originally filed at Dkt. 166-8 and 167-1. Exhibit 35 contains no redactions.
Attached as Exhibit 36 is a true and correct copy of Exhibit 6 to the Slade Cert. Declaration,
originally filed at Dkt. 166-14 and 167-1. Exhibit 36 contains no redactions.
Attached as Exhibit 37 is a true and correct copy of a redacted version of Exhibit 7 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-15 and 167-1. Redactions in Exhibit 37 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 38 is a true and correct copy of Exhibit 8 to the Slade Cert. Declaration,
originally filed at Dkt. 166-16 and 167-1. Exhibit 38 contains no redactions.
Attached as Exhibit 39 is a true and correct copy of Exhibit 9 to the Slade Cert. Declaration,
originally filed at Dkt. 166-12 and 167-1. Exhibit 39 contains no redactions.
Attached as Exhibit 40 is a true and correct copy of Exhibit 10 to the Slade Cert. Declaration,
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OBJECTIONS - Case No. C 13-05996 PJH

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originally filed at Dkt. 166-17 and 167-1. Exhibit 40 contains no redactions.
Attached as Exhibit 41 is a true and correct copy of Exhibit 11 to the Slade Cert. Declaration,
originally filed at Dkt. 166-18 and 167-1. Exhibit 41 contains no redactions.

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Attached as Exhibit 42 is a true and correct copy of a redacted version of Exhibit 14 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-20 and 167-1. Redactions in Exhibit 42 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 43 is a true and correct copy of a redacted version of Exhibit 15 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-21 and 167-1. Redactions in Exhibit 43 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 44 is a true and correct copy of a redacted version of Exhibit 16 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-22 and 167-1. Redactions in Exhibit 44 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 45 is a true and correct copy of a redacted version of Exhibit 17 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-23 and 167-1. Redactions in Exhibit 45 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 46 is a true and correct copy of a redacted version of Exhibit 18 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-24 and 167-1. Redactions in Exhibit 46 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 47 is a true and correct copy of a redacted version of Exhibit 19 to the

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Slade Cert. Declaration, originally filed at Dkt. 166-25 and 167-1. Redactions in Exhibit 47 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 48 is a true and correct copy of a redacted version of Exhibit 20 to the
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JOINT NOTICE OF REFILING OF DOCUMENTS ACCOMPANYING CLASS CERTIFICATION BRIEFS AND EVIDENTIARY
OBJECTIONS - Case No. C 13-05996 PJH

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Slade Cert. Declaration, originally filed at Dkt. 166-26 and 167-1. Redactions in Exhibit 48 are by

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both Facebook and Plaintiffs, and they are of the names, email addresses, and Facebook IDs of one of

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the Plaintiffs and one or more non-parties (specifically, absent putative class members).

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Attached as Exhibit 49 is a true and correct copy of the Supplemental Gardner Cert.

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Declaration, originally filed at Dkt. 166-10 and 167-2. Exhibit 49 contains no redactions.

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Defendant Facebook’s Objection/Request to Strike New Evidence and Misstatements of Fact
Contained in Plaintiffs’ Reply in Support of their Motion for Class Certification (Dkt. 178-4):

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Attached as Exhibit 50 is a true and correct copy of the Harrison Declaration, originally filed
at Dkt. 169-9 and 170-2. Exhibit 50 contains no redactions.
Dated: March 28, 2016

Respectfully submitted,
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
/s/
Michael W. Sobol
Attorneys for Plaintiffs
By:

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GIBSON, DUNN & CRUTCHER LLP

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By:

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/s/
Christopher Chorba

Attorneys for Defendant FACEBOOK, INC.

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