XAVIER BECERRA ENDORSED Attorney General of California I A. AKERS (SBN 21 1222) San Francisco County Superior Court Senior ASS1stant Attorney General STACEY D. SCHESSER (SBN 245735) 6 2019 Supervising Deputy Attorney General ?1 LISA B. KIM (SBN 229369) 0 BK OF THE COUFIT MICAH CE. OSGOOD (SBN 255239) By, GEUCA SUNGA SUSAN SAYLOR (SBN 154592) DeputyClerk MANEESH SHARMA (SBN 280084) Deputy Attorneys General 455 Golden Gate Ave. Suite 11000 San Francisco, CA 94102 Telephone: (415) 510-3500 mike.osgood@doj .ca. gov Attorneys for People ofthe State of Caiifomz'a SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO PEOPLE OF THE STATE OF EXEMPT FROM FILING FEES CALIFORNIA EX REL. XAVIER PER GOV. CODE 6103 BECERRA, ATTORNEY GENERAL, Case No. - PetitionerPETITION TO ENFORCE INVESTIGATIVE SUBPOENA AND FACEBOOK, INC., INVESTIGATIVE INTERROGATORIES Respondent. (GOV. CODE, 11180 et seq.) 1. In 2018, California Attorney General Xavier Becerra launched an investigation into the business practices of acebook Inc, following widespread reports that Facebook allowed third parties to harvest Facebook users? private information. What initially began as an inquiry into the Cambridge Analytica scandal expanded over time to become an investigation into whether Facebook has violated California law by, among other things, deceiving users and ignoring its own policies in allowing third parties broad access to user data. 1 Pet. to Enf. Subp. Early in the investigation, the Attorney General used his pre?litigation investigatory powers granted by section 11180 et? seq. of the Government Code to issue an investigative subpoena requiring Facebook to produce documents relating to the Cambridge Analytica matter. A year passed before Facebook completed its drawn?out response to the subpoena, during which time the Attorney General also issued a first set of investigative interrogatories. 3. On June 17, 2019, the Attorney General served a second set of interrogatories and a further subpoena to delve deeper into matters disclosed in Facebook?s initial responses and later news reports concerning other claims of wrongdoing by Facebook over users? privacy. Facebook?s responses to this second subpoena and set of interrogatories is patently deficient. Despite repeated entreaties, Facebook has provided no answers for nineteen interrogatories and produced no new documents in response to six document requests. Facebook has also wholly refused to search communications involving senior executives for responsive materials. Thus, acebook is not just continuing to drag its feet in response to the Attorney General?s investigation, it is failing to comply with lawfully issued subpoenas and interrogatories. 4. Accordingly, the People of the State of California, acting through Attorney General Xavier Becerra, petition this Court pursuant to section 11188 of the Government Code to enforce compliance with the Attorney General?s investigative subpoena and interrogatories. This investigation involves serious allegations of unlawful business practices by one of the richest companies in the world, prompting inquiries by Congress, European and US. regulators at the state and federal level. Indeed, the Federal Trade Commission recently announced a $5 billion settlement after the company violated an existing consent decree. Facebook?s delays and refusals to comply with the Attorney General?s interrogatories and subpoena should not thwart this important and independent investigation into whether the company violated its users? privacy and California law. THE PARTIES 5. Petitioner Xavier Becerra is the Attorney General of the State of California. He brings this action solely in his official capacity 011 behalf ofthc People ofthc State of California. As the chief law officer of the State ofCalifornia, the Attorney General is responsible for enforcing the 2 Pet. to Enf. Subp. state?s consumer protection laws, among others. In order to carry out these duties effectively, California law gives the Attorney General broad investigative powers. Speci?cally, Government Code sections 11180 et seq. grant the Attorney General, as head of the Department of Justice, the authority to issue subpoenas and promulgate interrogatories. The Attorney General may use these powers for various reasons, including assisting him in considering possible prosecutorial actions, proposing legislation, and formulating enforcement policies with other agencies. These investigative powers are not dependent on the initiation of a civil lawsuit or an administrative proceeding. If a party disobeys a subpoena, the Attorney General may petition the Superior Court for enforcement. 6. Facebook needs no introduction. The Silicon Valley-based social media giant, which has grown to include the Facebook, WhatsApp, and Instagram platforms, is the fifth largest company in the United States by market capitalization, sixth most profitable, and boasts nearly 40,000 employees. Most adults with internet access use Facebook, many of them to share the intimate details of their lives with friends and family. Facebook gathers and maintains personal information of billions of users throughout the world and millions in Califomia. This data gathering occurs both on Facebook?s own platforms and through widespread surveillance that Facebook conducts on other websites and online activities. The company then monetizes the data through the provision of highly targeted advertisements to customized audiences on acebook?s products, making the company billions in revenue. JURISDICTION AND VENUE 7. Jurisdiction and venue are proper in the Superior Court of the State of Califomia in the City and County of San Francisco under Government Code section 11186. The Attorney General primarily conducts the investigation into Facebool; in the City and County of San Francisco, with some work performed in other parts of the State. BACKGROUND 1. THE FACEBOOK PLATFORM 8. Among other endeavors, acebook operates a social media platform that allows individuals and organizations to create personalized onlinc profile pages about themselves, filled 3 Pet. to Enf. Suhp. with biographical details, photos, and a scrollable record of chronological ?posts? about the user. Facebook also lets users connect with other users as ?Friends,? and as relevant here, purports to allow users to restrict access to their information using various privacy settings. 9. In 2007, Facebook launched a developer portal that let third-party software developers create applications that interacted with Facebook users. These ?Facebook apps,? like apps on a mobile phone, were small programs that operated on Facebook?s website or mobile app. Facebook apps included popular games or quizzes that allowed a user to post serious or humorous results, such as what fictional character a user?s personality resembles. To make them personalized, acebook granted apps the ability to access data about users from Facebook?s database. For example, a horoscope app might capture a user?s birthdate to provide the horoscope. acebook made millions of apps available to users, opening the door for millions of apps to collect user data. 10. acebook also allowed apps to access non?public data??information that users thought they had restricted?about both themselves and their Friends. Some app providers, appear to have exploited this access to collect other user data, build pro?les 011 users, and sell those to third parties. This includes apps af?liated with Cambridge Analytica, which obtained data on 87 million Americans that was allegedly used to conduct election?related disinformation campaigns. Questions have arisen as to what Facebook knew about this conduct, why it failed to prevent app providers from misusing user data, and whether this behavior violated California law. 11. In addition, Facebook told users that the company had safeguards in place to protect their data, and it offered controls that purported to allow users to decide whether and how their data was shared. However, the Cambridge Analytica scandal, combined with reports that Facebook allowed its business partners to access user data, even when those users had opted out of such sharing, suggests that acebook may not have honored its obligations to its users, or complied with California?s privacy or consumer protection laws. 11. THE ATTORNEY INVESTIGATION 12. Califomia law grants the Attorney General the authority to investigate reports of unlawful, unfair, deceptive, or otherwise improper business practices, including 4 misrepresentations to consumers, failures to make adequate disclosures in connection with personal information and online services, and violations of individuals? privacy. Using this authority, the Attorney General initiated an investigation and continues to investigate Facebook?s compliance with California?s privacy and consumer protection laws, including but not limited to the allegations set forth above. 13. On June 4, 2018, the Attorney General, acting through officers of the Department of Justice to whom he had delegated investigative authority under section 11182 of the Government Code, served Faeebook with a subpoena for documents based on the allegations involving Faeebook and Cambridge Analytiea. Facebook accepted service of the subpoena and acknowledged its receipt. Facebook made its last production of documents in response to this first subpoena on April 17, 2019, but the company wrote that it planned to make additional productions ?on a rolling basis.? On June 5, 2019, a year and a day after the subpoena issued, aeebook finally admitted that it had actually completed its production of documents. 14. On June 17, 201. 9, the Attorney General, acting through officers of the Department of Justice exercising delegated authority, prOperly served Faeebook with a second set of investigative interrogatories and a second investigative subpoena, requesting additional information and documents. Copies of the investigative interrogatories and subpoena are attached as Exhibit A and and are incorporated into this petition. Faeebook was subpoenaed and required to answer interrogatories in the manner prescribed in section 11180 et seq. of the Government Code. The interrogatories and the subpoena, respectively, provided notice of the time and place for answering the interrogatories and for production of the papers. (Gov. Code, 11187, subd. By agreement, Facebook?s attorneys accepted service of the interrogatories and subpoena. 15. The Attorney General?s interrogatories and subpoena were regularly issued, and they relate to the Attorney General?s ongoing investigation into Facebook?s compliance with consumer protection and privacy laws. The investigatory interrogatories seek the following relevant information: The number of California users and rates at which they activated privacy settings to 5 Pet. to Enf. Subp. prevent apps from accessing data; 0 The effects of the various privacy settings on third parties? access to data, including which apps Facebook granted access to user data despite users restricting access to their information; Infonnation about Facebook?s enforcement of its policies against deveIOpers; 0 An explanation of the technical workings of Facebook?s software that allowed various entities to access user data. The Attorney General?s subpoena seeks the following materials: 0 Communications among executives regarding: 1) any consideration of the need to audit developers? access to user data; 2) third parties granted expanded access to user data; 3) the relationship between ad Spending and access to data; 4) significant privacy-related news stories; and 5) the introduction of new privacy features. 0 Documentation regarding the changes to and user testing of Facebook?s privacy settings; 0 Communications regarding a user?s likely response to privacy settings; 0 Documents regarding Facebook?s privacy program, which was mandated by the Federal Trade Commission in 2012 pursuant to a consent decree, yet failed to prevent the Cambridge Analytica scandal. 1H. FACEBOOK HAS FAILED TO ADEQUATELY AND RESPOND. 16. Facebook broadly refuses to answer the interrogatories or comply with the subpoena as required. Facebook will not provide a direct answer to 19 out of 27 interrogatories (Nos. 26- 37, 40?42, 47-50) and has only provided a partial response to 6 (Nos. 24, 25, 43, 44, 45, 46). Facebook has produced no new documents for six document requests (Nos. 19?21 85 26-28), and appears to have conducted an insufficient search for request no. 25. 17. Facebook has also refused to conduct a complete search for responsive documents. Facebook has, for example, refused to search for communications among senior executives regarding terminating developers? access to user data, various privacy?related news stories, and Facebook?s public responses. 011 information and belief, Facehook has not searched the emails of the company?s Chief Executive and Chief Operating Of? cers for documents responsive to the 6 Pet. to Enf. Subp. 10 11 12 13 14 subpoena. 18. This lack of cooperation, particularly with respect to communications among senior executives, is not unique to the Attorney General?s investigation. A member of the Federal Trade Commission recently wrote to express serious conceins over Facebook?s candor with federal regulators: Based on the material presented to me, I was very concerned about Facebook?s cooperation and candor in its dealings with the Commission and its staff. In my View, there were multiple inconsistencies and deficienci es in Facebook?s responses to questions. I questioned whether the company?s document productions were truly complete. lbelieve that Facebook struggled to answer many requests for data, and I ascertained that the company was resistant to providing documents from Zuckerberg?s ?les. (Dissenting Statement of Commissioner Rohit Chopra, re Facebook, Inc, Federal Trade Commission File No. 1823109, July 24, 2019, at page 6.) Pet. to 1711f. Subp. PRAYER FOR RELIEF Pursuant to Government Code sections 11186-1 1188, the Attorney General prays that this Court: 1. Issue an order directing Respondent to appear before this Court and to show cause why it has refused to comply with the Subpoena and lnterrogatories, and, upon Respondent?s failure to show cause; 2. Enter an order directing Respondent to provide full responses to lnterrogaton'es Nos. 26 37, 40 42, and 47?50; complete its response to Interrogatories Nos. 24, 25, 43, 44, 45, 46; and produce documents for Requests for Production Nos. 19?21 and 25-28; and 3. All other relief to which the people are legally entitled. Dated: November 6, 2019 Respectfully Submitted, XAVIER BECERRA Attorney General of California NICKLAS A. AKERS Senior Assistant Attorney General STACEY D. SCHESSER Supervising Deputy Attorney General I - f? MICAH C. E. 056001) LISA B. KIM SUSAN SAYLOR MANEESH SHARMA Deputy Attorneys General Attorneysfor the People oft/1e State ofCaszorm'a SF2018400570/14237593docx Pet. to En?f. Subp. EXHIBIT A 'XAVIER BECERRA (SBN 1 18517) Attorney General of California NICKLAS A. AKERS (SBN 211222) Senior Assistant Attorney General STACEY D. SCHESSER (SBN 24573 5) Supervising Deputy Attorney General LISA 13. KIM (SBN 229369) SUSAN SAYLOR (SEN 154592) MICAH C.E. (SBN 25 5239) MANEESH SHARMA (SBN 280084) Deputy Attorneys General 300 South Spring Street, Suite 1702 Los Angeles, CA 90013 Telephone: (213) 269?6369 lisa.kim@doj.ca.gov BEFORE THE DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL STATE OF CALIFORNIA. In the Matter of the Investigation of: FACEBOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS oovfcooa? 11180, ET SEQ. NOTICE to Benjamin A. Powell, Esq.: You are hereby served on behalf ofFaeehook, Inc. pursuant to your agreement to accept service on your client?s behalf. 1 FACEBOOK, INCI INVESTIGATIVE SUBPOENA FOR DOCUMENTS Pursuant to the powers conferred by Article 2 of Chapter 2 of Division 3 of Title 2 of the Government Code of California (Cal. Gov. Code, 11180 et seq.) on the Attorney General, as head of the California Department of Justice, which powers and authority to conduct the above entitled investigation have been delegated to the undersigned, an of?cer-0f that Department, FACEBOOK, INC. . (hereinafter IS HEREBY COMMANDED to produce the documents, books, records, papers and other items (collectively ?Items?) described in Attachment A to this Investigative Subpoena which are in custody, possessionor control, or the custody, possession or control of subsidiaries, affiliates, parents, predecessors, successor,s employees, pa1tners, officers, agents or representatix es, whether or not the present location of any of the Items designated is in California, at the California Department of Justice, Office of the Attorney General, 1300 Street, Sacramento, CA 95814-2919, ATTN: Deputy Attorney General Lisa B. Kim, within thirty days of service hereof. INSTRUCTIONS FOR-COMPLIANCE 1. If ACBBOOK claims that an item or a portion of an item is privileged and FACEBOOK withholds it from production for that reason, FACEBOOK must create and submit a privilege log which lists: (1) the authors and their capacities; (2) the recipients (including 00?s and bcc?s) and their capacities; (3) other individuals with access to the document and their capacities; (4) the type of document; (5) the subject matter of the document; (6) the purpose(s) for the creation of the document; (7) the date on the document; and (8) a detailed explanation setting forth the factual and legal basis for your claim that the document is privileged or otherwise immune from production. 2. I To the extent responsive items exist in an electronic or computerized format, please contact the officer issuing this subpoena to discuss the manner and format in which the items are to be produced so as to facilitate the production of full and complete copies in a usable format. In the absence of an agreement regarding the manner and format of production, the following instructions shall apply: 2 FACEBOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS U1 ?x?lOThe information shall be provided in accordance with the California Attorney General?s Office Production Format as outlined in Attachment below. . b. The response shall. include all DOCUMENTS and computer programs necessary to the accurate conversion, analysis, and review of the electronic data, including but not limited to operating instructions, manuals and user guides, keys, legends, and codes for systems, programs, files, and data ?elds. 3. This Investigative Subpoena has been issued in connection with an investigation within the scope of section 131 of the California Penal Code. 4. No item requested herein shall be destroyed or discarded by FACEBOOK until the Attorney General has made a written determination that the item in question is not necessary for furtherance of this investigation. 5. When producing items, identify by number the request(s) to which the Item is responsive. 6. As used herein, the past tense includes the present and future tenses, the present tense includes the past and future tenses, and the future tense includes the past and present tenses; tenses must be construed in the manner that would include, rather than exclude, information. 7. As'used herein, the singular includes the plural and the plural includes the singular, and must be construed in the manner that would include, rather than exclude, information. DEFINITIONS For purposes of this investigative subpbena, the terms set forth below are de?ned as follows: 1. OTHERS means the setting used to limit data SHARED through FRIENDS with THIRD PARTY APPLICA IONS as set out on page 19 et seq. of the March 15, 2019 letter from Benjamin A Powell to Stacey D. Schesser and Lisa B. Kim 2. means every disclosure, transfer, exchange, OR transmission of information, ?whether oral, written, OR electronic, and whether face-to?face, by telecommunications, telephone, computer, mail, e-mail, text message, instant message, 3 FACEBOOK, INC. SUBPOENA FOR DOCUMENTS .28? FACEBOOK Messenger, screenshot, picture, facsimile (fax) machine, OR otherwise, including - any and all attachn1ent(s). 3. means the settings that a user can alte1 or accept to limit the sharing of USER INFORMATION 1with thi1d pa1ties, including audience selectors, GRANULAR .DATA PERWSSIONS, PLATFORM OPT OUT, APPS OTHERS USE, and-the like. I 4. - means any natural or corporate person that develops an application, software experience, game, or website, that accesses information from APIs or other FACEB OOK software. 5. I means a ?writing? as defined in section 250 of the California Evidence Code, and includes COMMUNICATIONS, e-mails, voicemails, computer files, text messages, instant messages, word processing documents, spreadsheets, databases, calendars, and all other forms of ?electronically stored information? as defined 1n section 2016.020 of the California Code of 11 Procedure. 6. API ACCESS means the entity or entities with whom FACEBOOK partnered with for EXTENDED API ACCESS PARTNERSHIPS. 7. API ACCESS means a partnership formed by agreement between FACEBOOK and a DEVELOPER that allowed the DEVELOPER access to certain FACEBOOK APIs on terms speci?ed within the agreement, such as 0002916, and beyond those terms offered to typical THIRD PARTY APPLICATIONS on the FACEBOOK Platform. This de?nition includes agreements performing the same general function, even if not titled as an ?EXtended API Addendum.? I 8. means the social networking online service operated by FACEBOOK, Inc. Where USERS access content, including THIRD PARTY APPLICATIONS, websites, and games. For purposes of this subpoena, FACEBOOK PRODUCT means content accessed online at and mobile application, but does not. include acquired properties, such as Instagram and WhatsApp. 4 FACEBOOK, INC. INVESTIGATIVE SUBPOENA-EOR DOCUMENTS 9. I means a USER who is connected to another USER on the FACEBOOK PRODUCT. 10. DATA refers to the setting used to limit data SHARED with THIRD PARTY APPLICATIONS as set out at page 4 ct seq. of the March 15, 2019 letter from Benjamin A. Powell to Stacey D. Schesser and Lisa B. Kim. l. PERSONALIZAT means the product that FACEBOOK offered that used FACEBOOK USER INF provide personalized experiences on select partners? websites, as described by FACEBOOK in its December 18, 2018 Newsroom post found online at 12. PERSONALIZATION means the entity or entities with whom FACEBOOK partnered for INSTANT PERSONALIZATION. l3. PERSONALIZATION means the relationship FACEBOOK had with INSTANT PERSONALIZATION PARTNERS. l4. . means the entity or entities with whom FACEBOOK has an INTEGRATION PARTNERSHIP. 15. - means the relationship FACEBOOK has with companies that built integrationsfor a variety of devices, operating systems, and other products, as described by FACEBOOK in Appendix A of the July 20, 2018 letter Anjan Sahni . sent to Stacey D. Schesser and Lisa B. Kim. 16. OPT means the setting used to disable platform as set out at page 10 et seq. of the March 15, 2019 letter from Benjamin A. Powell to Stacey D. Schesser and Lisa B. Kim. 17. or mean any formal or informal policy, procedure, rule, guideline, collaborative document, directive, instruction, OR practice, whether written or unwritten, that YOU expect YOUR employees to follow in performing their jobs. 18. means the settings that control what information in a pro?le is SHARED with other USERS through audience selectors, such as phone number, email, current city, birthday, relationship status, work, and education. .J FACEBOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS 19. or or or means to provide, communicate, transfer, release, disclose, disseminate, sell, rent, trade, OR otherwise make aCcessible or?available in writing, electronically, or by other means. 20. PARTY shall have the same meaning as the terms ?Platform Application(s), ?application(s), and ?app? used 111 FACEBOOK policies produced to the California Attorney General bearing the Bates Labels through I 21. . means the individuals who maintain an account and can generally access the typical FACEBOOK experience via website or mobile application in a personal I capacity. I 22. I means any information related to the FACEBOOK PRODUCT that identi?es, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, the following information: name; physical address, including street name and name of a city or town; telephone number; email address;_online contact information, including a screen name, useriiame, or social network profile that functions as online contact information; user account credentials; a persistent identi?er such as a user number held in a cookie or a processor serial number; a unique device identifier or a universally unique identi?er, including geolocation information, including GPS-based location information and network-basedor cell-based location information;longitude and latitude data; education; employment; employment history; and any other social media content generated by OR associated with a particular individual, including status updates, likes, OR group af?liations. 23. or or means FACEBOOK, Inc. and its past or present officers, agents, employees, attorneys, predecessors, af?liates, subsidiaries, parent 6 FACEBOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS companies, former business names, and dbas, and anyone acting on YOUR behalf or at YOUR direction. FAILURE TO COMPLY WITH THIS SUBPOENA WILL SUBIECT YOU TO THE PROCEEDINGS AND PENALTIES PROVIDED BY LAW. Dated: June 17,2019 SF2017402454 13730166_docx 7 XAVIER BECERRA Attorney General of California NICKLAS A. AKERS Senior Assistant Attorney General STACEY D. SCHESSER Supervising Deputy Attorney General LISA B. KIM SUSAN SAYLOR MICAH CE. MANEESH SHARMA Deputy Attorneys General LISA B. KIM Deputy Attorney General FACEB OOK, INC. ENVESTIGATIVE SUBPOENA FOR DOCUMENTS ATTACHMENT A 18. Records tracking the USER DATA access permissions granted to DEVELOPERS pursuant to an EXTENDED API ACCESS PARTNERSHIP. 19. All YOUR internal COMMUNICATIONS from 2013 to 2018 re?ecting the contemplation, planning, or performance of a general audit of access to USER INFORMATION, including through THIRD PARTY APPLICATIONS, INTEGRATION PARTNERSHIPS, INSTANT PERSONALIZATIONPARTNERSHIPS, and EXTENDED API ACCESS PARTNERSHIPS. I - 20. All COMMUNICATIONS concerning the negotiation of, entrance into, or termination of, an EXTENDED API ACCESS PARTNERSHIP. 21. All COMMUNICATIONS from 2012 to 2015 regarding conditioning access to USER INFORMATION on advertising spending or other payment. 22. All DOCUMENTS that support YOUR contention that FACEBOOK ?never implemented, let alone seriously considered? (emphasis in the original) ?charging developers for access to user data,? as stated on page 6 of the April 17, 2019 letter from Benjamin A. Powell to Stacey D. Schesser and Lisa B. Kim. - 23. All DOCUMENTS re?ecting the study, testing, or analysis of a understanding of, or reaction to, a DATA CONTROL in effect during 2013 to present, or any proposed change to a DATA CONTROLS during that time frame, including any testing, or studies on user experience or usability of DATA CONTROLS. 24. All COMMUNICATIONS regarding a potential reaction to or understanding of DATA CONTROLS. - 25. All YOUR internal COMMUNICATIONS, involving a Director, Vice President, or above, about the development of the ?privacy tour,? ?privacy basics,? or ?privacy check?up,? as those terms were used by in the March 15, 2019 letter from Benjamin A. Powell to Stacey D. Schesser andLisa B. Kim. I 26. I All YOUR internal COMMUNICATIONS, involving a Director, Vice President, or above, about the termination of a access to USER INFORMATION. 8. FACEBOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS .27 27. All YOUR internal COMMUNICATIONS, involving a Director, Vice President, or above, that occurred within one week of a request for comment regarding, or the publication of, the following news reports: 28. The Guardian ?3 reporting on December 11, 2015, that ?Ted Cruz us[ed] firm that harvested data on millions of unwitting Pacebook users?; Various news outlets reporting on March 17, 2018, about Facebook and Cambridge Analytica; The New York Times reporting on June 3, 2018,'that ?Facebook gave device makers deep access to data on users and friends?; The Wall Street Journal reporting on November 28, 2018, that ?Facebook considered charging for access to user data?; The Washington Post reporting on December 5, 2018, that ?Eacebook [allegedly] offered advertisers special access to users? data and activities?; and The New York Times reporting on December 18, 2018, that ?Pacebook gave some of the world?s largest technology companies more intrusive access to users? pcrsonal data.? All YOUR internal COMMUNICATIONS, involving a Director, Vice President, or above, regarding approval of the following Facebook Newsroom items: 29. Why We Disagree with the New York Times, dated June 3, 2018; Response to Six4Three Documents, dated December 5, 2018 Let?s Clear Up a Few Things About Facebook?s Partners, dated December 18, 2018. . 5 Facts About acebook?s Messaging Partnerships, dated December 19, 2018; Cracking Down on Platform Abuse, dated March 21, 2018; - - All YOUR internal POLICIES on the enforcement of Platform Policy, Data Policy, Terms of Service, or Statement of Rights and Responsibilities, on THIRD PARTY APPLICATIONS, INTEGRATION PARTNERSHIPS, INSTANT PERSONALIZATION PARTNERSHIPS, and EXTENDED API ACCESS PARTNERSHIPS. 30. All ?Enforcement Rubricls]? used by PACEBOOK, as that term is used on page 4 of the April 17, 2019 letter from Benjamin A. Powell to Stacey D. Schesser and Lisa B. Kim. 31. All ?cease and desist letters? sent by FACEBOOK to DEVELOPERS, between January 1, 2013, and March 1, 2018, as that term is used on page 12 ofthe July 20, 2018 letter from Anj an Salini to Stacey D. Schesser and Lisa B. Kim. 9 FACE-BOOK, INC. INVESTIGATIVE SUBPOENA FOR DOCUMENTS TW 4:32. A?ll ?letter agreements? resolving an enforcement concern as that term is used on page 12 of the July 20, 2018 letter from Anjan Sahni to Stacey D. Schesser and Lisa 13. Kim. 33. ACEBOOK logs documenting any code changes made to DATA CONTROLS sometimes referred to as ?Commit Logs.? 34. All ?Privacy Risk and notes or agenda relating to ?focused subject?matter-speci?c meetings,? ?weekly intra- and. inter?team meetings,? and ?Privacy as detailed in ?Pacebool