The parties ask the Court to resolve a dispute concerning whether Meta has produced all responsive named plaintiffs data.[1] Dkt. No. 698. The Court held a hearing on this dispute on January 15, 2025. Dkt. No. 774.

In the discovery dispute letter, plaintiffs contend that Meta has not produced all responsive named plaintiffs data, and that Meta has preserved undisclosed sources of named plaintiffs data that it refuses to search for responsive data. Plaintiffs ask the Court to “order Meta to tell Plaintiffs what other responsive data it preserved for the Named Plaintiffs and either produce the data or explain why it objects to producing it.” Dkt. No. 698 at 1; see also id. at 1-3, 5. Meta responds that it has already produced responsive named plaintiffs data and class-wide data, and that the parties are engaged in a process (i.e. the September 9, 2024 protocol) to identify all remaining potential sources of such data. Meta further responds that it is not withholding from production responsive data from an undisclosed data source.

It is not clear from plaintiffs’ portion of the discovery dispute letter what data it believes is missing from Meta’s production. While plaintiffs acknowledge the parties’ ongoing efforts to identify relevant data sources using the September 9, 2024 protocol, they suggest that if Meta has preserved data via an undisclosed [REDACTED] the protocol and other discovery efforts will not identify this data. Id. at 2.

During the hearing, the Court asked plaintiffs to identify what data they believe is missing from Meta’s production. Based on that colloquy, the Court understands that plaintiffs believe Meta has not produced named plaintiffs data corresponding [REDACTED], such as the labels and categories generated using the [REDACTED] system or [REDACTED] reflected in the Meta document excerpted at page 2 of the discovery dispute letter. In particular, plaintiffs believe that the results of Meta’s processing for [REDACTED] to multiple unknown tables or other data sources, which are then used in targeted advertising and other aspects of Meta’s business.

With respect to [REDACTED] information, Meta responds that it has “already agreed to produce a significant amount of information about such classifications.” Id. at 8 (citing Dkt. No. 694). Indeed, the Court has already ordered Meta to produce this information to the extent it is responsive to plaintiffs’ RFPs 163 and 164. See Dkt. No. 733. Meta has produced [REDACTED] from its [REDACTED] table, which the parties appear to agree contains the kinds of [REDACTED] data plaintiffs seek, although not for the entire time period plaintiffs believe is relevant. Beyond that, Meta argues that it does not know what specific information plaintiffs want.

The Court does not have sufficient information to resolve this dispute and therefore orders further proceedings as follows:

1. By no later than January 22, 2025, plaintiffs shall specifically describe in writing the relevant [REDACTED] information they want Meta produce. It will not be sufficient for plaintiffs to demand, for example, “all native data, appended data, behavioral data, and location data” for the named plaintiffs. If plaintiffs have examples of the kinds of [REDACTED] information they seek, they should provide those examples to Meta.

2. Meta must investigate whether it maintains the information plaintiffs describe for the named plaintiffs for a time period before the implementation of Core Setup in February 2024,[2] and must advise plaintiffs of the results of its investigation by no later than February 5, 2025.

3. The parties must file a status report regarding this dispute by February 12, 2025.

IT IS SO ORDERED.