In re Facebook, Inc. Consumer Privacy User Profile Litig.
In re Facebook, Inc. Consumer Privacy User Profile Litig.
Case 3:18-md-02843-VC (N.D. Cal. 2022)
June 15, 2022

Garrie, Daniel,  Special Master

Failure to Produce
Inaccessible
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Summary
The court ordered Facebook to provide information about its ESI, including technical details about the process used to identify the Hive tables, descriptions of the tables, and whether its search to identify the tables included searching cold storage. This information is important for the court to determine whether Facebook has complied with its discovery obligations.
Additional Decisions
IN RE: FACEBOOK, INC. CONSUMER PRIVACY USER PROFILE LITIGATION
This document relates to: ALL ACTIONS
MDL NO. 2843 | CASE NO. 3:18-MD-02843-VC-JSC
United States District Court, N.D. California
Signed May 24, 2022
Filed June 15, 2022
Garrie, Daniel, Special Master

ORDER FOLLOWING MAY 17, 2022 HEARING REGARDING PRODUCTION OF NAMED PLAINTIFF DATA

No later than June 2, 2022, Facebook is to submit responses to the following questions and provide the requested additional information.

• How did Facebook identify the Hive tables in Exhibit B to Facebook's April 11 , 2022 submission ("Exhibit B") identified as possibly containing user identifiers? Facebook's answer is to include technical details about the process used to identify the Hive tables.

• Can Facebook provide descriptions for the Hive tables identified in Exhibit B? If so, provide the descriptions.

• How long would it take to extract the column names and data types (schema) for the Hive tables identified in Exhibit B? Facebook's answer is to include a description of the processes and steps it would need to perform to provide the requested data.

• Did Facebook's search to identify the tables set out in Exhibit B include searching cold storage? If not, why not?

• In Exhibit B to Facebook's April 18, 2022 letter submission (Declaration of Mengge Ji), Mengge Ji states ********** Expand on this statement, include descriptions of the ********** databases, and clarify what is meant by "databases" in this context.

• One of Facebook's -responses in their April 11, 2022 letter submission at page 2 states "tables believed to contain data that that is either duplicative or transformed." What does transformed mean in this context? Facebook's answer is to include three examples of "transformation."

• Facebook's April 1], 2022 letter submission at page 2 refers to six categories of tables that were not included in the list in Exhibit B: (l) temporary, test, and en-or tables; (2) tables used to evaluate system performance; (3) tables that contain no data; ( 4) tables related to other Meta products (e.g., Oculus, Instagram, and WhatsApp); (5) tables used for infrastructure, operations, and product testing; and (6) tables believed to contain data that is either duplicative or transformed. Provide a description of each of these six categories of tables.

No later than May 30, 2022, Facebook is to provide the revised proposal they discussed at the hearing.

No later than June 6, 2022, the parties are to submit briefs, not to exceed five (5) pages not including exhibits, on the issues of Hive table selection, production of data related to apps installed by friends of Named Plaintiffs, and whether Facebook should be compelled to search cold storage for Named Plaintiff data.

IT IS SO ORDERED.

Tuesday, May 24, 2022


Daniel Ganie

Discovery Special Master