TIKTOK INC. et al v. TRUMP et al

Filing 15

MOTION for Preliminary Injunction MOTION to Expedite by BYTEDANCE LTD., TIKTOK INC. (Attachments: #1 Memorandum in Support, #2 Declaration, #3 Declaration, #4 Declaration, #5 Declaration, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit, #17 Exhibit, #18 Exhibit, #19 Exhibit, #20 Exhibit, #21 Exhibit, #22 Exhibit, #23 Exhibit, #24 Exhibit, #25 Exhibit, #26 Exhibit, #27 Exhibit, #28 Exhibit, #29 Exhibit, #30 Exhibit, #31 Exhibit, #32 Exhibit, #33 Exhibit, #34 Exhibit, #35 Exhibit, #36 Exhibit, #37 Exhibit, #38 Exhibit, #39 Exhibit, #40 Exhibit, #41 Exhibit, #42 Exhibit, #43 Text of Proposed Order)(Hall, John). Added MOTION to Expedite on 9/24/2020 (zeg).

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Case 1:20-cv-02658-CJN Document 15-9 Filed 09/23/20 Page 1 of 4 EXHIBIT 3 Case 1:20-cv-02658-CJN Document 15-9 Filed 09/23/20 Page 2 of 4 Statement on the Administration's Executive Order - Newsroom | TikTok All News Product Community Safety Company United States Company 8/7/2020 9/22/20, 4(12 PM Share this post Statement on the Administration's Executive Order TikTok is a community full of creativity and passion, a home that brings joy to families and meaningful careers to creators. And we are building this platform for the long term. TikTok will be here for many years to come. We are shocked by the recent Executive Order, which was issued without any due process. For nearly a year, we have sought to engage with the US government in good faith to provide a constructive solution to the concerns that have been expressed. What we encountered instead was that the Administration paid no attention to facts, dictated terms of an agreement without going through standard legal processes, and tried to insert itself into negotiations between private businesses. We made clear our intentions to work with the appropriate officials to devise a solution to benefit our users, creators, partners, employees, and the broader community in the United States. There has been, and continues to be, no due process or adherence to the law. The text of the decision makes it plain that there has been a reliance on unnamed "reports" with no citations, fears that the app "may be" used for misinformation campaigns with no substantiation of such fears, and concerns about the collection of data that is industry standard for thousands of mobile apps around the world. We have made clear that TikTok has never shared user data with the Chinese government, nor censored content at its request. In fact, we make our moderation guidelines and algorithm source code available in our Transparency Center, which is a level of accountability no peer company has committed to. We even expressed our willingness to pursue a full sale of the US business to an American company. This Executive Order risks undermining global businesses' trust in the United States' commitment to the rule of law, which has served as a magnet for investment and spurred decades of American economic growth. And it sets a dangerous precedent for the concept of free expression and open markets. We will pursue all remedies available to us in order to ensure that the rule of law is not discarded and that our company and our users are treated fairly – if not by the Administration, then by the US courts. We want the 100 million Americans who love our platform because it is your home for expression, entertainment, and connection to know: TikTok has never, and will never, waver in our commitment to you. We prioritize your safety, security, and the trust of our community – always. As TikTok users, creators, partners, and family, you have the right to express your opinions to your elected representatives, including the White House. You have the right to be heard. https://newsroom.tiktok.com/en-us/tiktok-responds Page 1 of 3 Case 1:20-cv-02658-CJN Document 15-9 Filed 09/23/20 Page 3 of 4 Statement on the Administration's Executive Order - Newsroom | TikTok Company 9/22/20, 4(12 PM 9/22/2020 Our H1 2020 Transparency Report By Michael Beckerman, VP, Head of US Public Policy & Eric Han, Head of Safety, TikTok US Today we released our global Transparency Report for the first six months of 2020. This report provides insight Safety 9/22/2020 TikTok proposes global coalition to protect against harmful content By Cormac Keenan, Trust & Safety, EMEA; Arjun Narayan Bettadapur Manjunath, Trust & Safety, APAC; Jeff Collins, Trust & Safety, Americas Earlier today we released our global Transparency Report for th Company 9/19/2020 An update for our TikTok family By Vanessa Pappas, Interim Head of TikTok When I joined TikTok nearly two years ago, few Americans had heard of it. The marketplace of online social platforms had remained virtually unchanged for a de Download now QR CODE Company Programs Resources Legal About TikTok TikTok for Good Help Center Cookies Policy Newsroom TikTok for Developers Safety Center Privacy Policy for Younger Store Advertise on TikTok Community Guidelines Users Transparency Intellectual Property Policy Contact Careers https://newsroom.tiktok.com/en-us/tiktok-responds Law Enforcement Page 2 of 3 Case 1:20-cv-02658-CJN Document 15-9 Filed 09/23/20 Page 4 of 4 Statement on the Administration's Executive Order - Newsroom | TikTok 9/22/20, 4(12 PM Careers Law Enforcement ByteDance Privacy Policy Creator Directory Terms of Service © 2020 TikTok https://newsroom.tiktok.com/en-us/tiktok-responds Page 3 of 3

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