Case 3:16-cv-03777-LB Document 56-2 Filed 02/08/18 Page 1 of 4
From:

Steven Trieu [/O=THEFACEBOOK/OU=FIRST ADMINISTRATIVE GROUP/CN=RECIPIENTS/CN=STRIEU]

Sent:

6/10/2008 7:00:46 PM

To:

Sheryl Sandberg

Subject:

RE: EU tax discussion

Will do the best I can.
-----orig inal Message----From: Sheryl Sandberg
Sent: Tuesday, June 10, 2008 5:51 PM
To: Steven Trieu
subject: RE: EU tax discussion
Thanks - all mentoring and helping you can do for him this summer will be greatly appreciated by me
-----original Message----From: Steven Trieu
Sent: Tuesday, June 10, 2008 3:10 PM
To: Sheryl Sandberg; Mike Murphy
Cc: Aldo King
subject: RE: EU tax discussion
Thanks Sheryl.

Aldo - let's sync when you are free.

-----original Message----From: Sheryl Sandberg
Sent: Tuesday, June 10, 2008 3:06 PM
To: Steven Trieu; Mike Murphy
Cc: Aldo King
subject: RE: EU tax discussion
Great.
Steve -- Mike and I just discussed this. Aldo King is a summer intern in my office who Mike and I asked
to help with this . He did similar analysis for me at Google and worked in our Dublin office. He is
copied on this email so he can follow up with you.
-----original Message----From: Steven Trieu
sent: Tuesday, June 10, 2008 10:44 AM
To: Sheryl Sandberg; Blake chandlee; Ted Price; Mike Murphy
cc: Gideon Yu; Cipora Herman
subject: RE: EU tax discussion
Hey Everyone,
Ted and I will put our heads together and come back to this group with some preliminary data and a
framework by next week. Just to make sure we are all on the same page , it sounds like we are trying to
answer 2 questions here:
1) If we were to build a European hub, what are the pros and cons of the 2 or 3 most logical locations?
2) If we want to establish localized sales offices in a handful of countries, what are the strategic , tax
or legal considerations?
Not to say these are mutually exclusive, but it probably makes sense to research the 2 independently and
then see if there are any synergies. Let me know if this is inconsistent with this groups understandi ng .
Thanks,
Steve
-----original Message ----From : Sheryl Sandberg
Sent : Saturday, June 07, 2008 3:29 PM
To: Blake chandlee; Ted Price; Mike Murphy; Gideon Yu
cc: Steven Trieu
subject : Re: EU tax discussion
This is not a summer projec. Gideon and I wil figure out how to gwt it done here.

Government
Exhibit
2
_____________

FBI RS002464 76

FBIRS00246476

 Case 3:16-cv-03777-LB Document 56-2 Filed 02/08/18 Page 2 of 4
----- Original Message----From: Blake chandlee
To: Sheryl Sandberg; Ted Price; Mike Murphy; Gideon Yu
Cc: Steven Trieu
Sent: Sat Jun 07 13:48:24 2008
subject: Re: EU tax discussion
Steve,
can you guys help here?
I have an option to bring in an mba from London business school who has approached me if we want someone
to do a bunch of information gathering for analytics?
Let me know if this is of interest for the summer.
Blake
Original Message----From: Sheryl Sandberg
To: Ted Price; Blake Chandlee; Mike Murphy; Gideon Yu
cc: Steven Trieu
Sent: Sat Jun 07 13:21:14 2008
subject: Re: EU tax discussion
If someone can tee up a framework to compare optins, I can help fill in key variables so we can do the
research comprehensively. Key factors will be things like cost of labor, cost of living, and tax
treatment offered.
----- Original Message
From: Ted Price
To: Blake chandlee; Sheryl Sandberg; Mike Murphy; Gideon Yu
Cc: Steven Trieu
Sent: Sat Jun 07 08:43:07 2008
subject: Re: EU tax discussion
Hi everyone,
The timing on setting up a tax structure is that we would ideally do it as part of our EU expansion so we
best match the structure with what works operationally.
It is best to think about the various considerations Blake mentioned as a sliding scale. Certain things
are better fact patterns for tax planning but no one thing is necessarily required. It's all about
assessing tax risks versus what works best operationally. Ireland and Switzerland still generally offer
the most advantages, but there can be flexibility regarding the types of activities needed in country.
I have been gathering info from Blake and others just to evaluate what is possible for us to consider
from the tax side. Gideon and I have not talked about recomendations or preferences yet. We will do that
and can give as much detail as needed to everyone in order to evaluate what makes sense.
Ted

----- original Message----From: Blake chandlee
To: Sheryl Sandberg; Mike Murphy; Gideon Yu
cc: Ted Price; Steven Trieu
Sent: Sat Jun 07 07:27:52 2008
subject: Re: EU tax discussion
Agree on all points sheryl,
Especially on ISO front, putting team centrally and all in-country folks are direct sales.
Will wait to hear back on timing.
Just want to let everyone know that we are getting more and more inquiries from EU as audiences reach
scale and that I think we can accelerate revenue growth if we can get the timing right to maximize.
Blake

FBIRS00246477

FBIRS00246476

 Case 3:16-cv-03777-LB Document 56-2 Filed 02/08/18 Page 3 of 4
----- Original Message----From: Sheryl Sandberg
To: Blake chandlee; Mike Murphy; Gideon Yu
cc: Ted Price; Steven Trieu
sent: Sat Jun 07 07:12:46 2008
subject : Re: EU ta x discussion
The main issue between dublin and geneva is cost of hiring people.
I thin k that if we are going to do a centralized headquarters, iso will need to be done from there. What
we will do is put only functions that need to meet face-to-face with customers (direct sales) in country
and everything else in hq. You need to do this because if not, you don't have enough heads in the
headquarters to justify the tax benefits.
Gideon - how quickly are we actually going to decide this? Do we have more detailed info on tax
differences? I know they say dublin is changing in this regard but is it really true?
Blake - if the decision is fast, we can build iso there . If not , we can hire to small numbers in the uk
as long as you hire people that can move up to direct sales.
----- original Message----From: Blake chandlee
To: Mike Murphy; Sheryl Sandberg
cc: Ted Price; Steven Trieu
sent : sat Jun 07 05:41:27 2008
subject: EU tax discussion
pursuant to Mike's request I had a long chat with Ted Price yesterday about EU, structure, investment,
revenue assumptions and obvious location needs for in-country headcount. below are a few of the key
points coming out of that
1. ted views tax considerations on three levels; e xecutive management location, server locations, and
feet on the ground people requirements
2. two location considerations at this point are Dublin and Geneva
3. many companies moving to geneva due to e xpiration of Dublin tax shelter and adjustment to regulations
and guidelines
4. do we need corporate entity in country to validate business commercially for clients / agencies ?
5. typically uses 10 heads as benchmark / guideline for entity in market
6. where we do not need to have a coprorate entity for above reasons we should not create local entity
key inputs back on my end
1. we can create centralized HQ in either Dublin or Geneva ( need to understand what these implications
and requirements are)
a. there are sufficient talent pools in either location
b . geneva is a little more central for traveling and lifestyle may be better
2.
have no visibility today into where server decisions are and if we are leaning towards Dublin
versus Geneva. this is a key influence
3. we need more visibility into other functional areas EU headcount investment (ad product marketing,
public policy, legal, tech, finance, HR, PR, etc)
a. these can all be centralized within the HQ location of course
4. ISO UK manager has been hired, Josh Smith, visited PA last week and starts in London Monday to build
UK team. this will be a relatively small team of 5 and should stay in London with UK sales org.
5. EU ISO team (multiple country) , can be centralized.
6. Corporate entities will be required in Germany and france to build strong businesses in these key
markets. other markets can roll directly into EU
7. suggested headcount in two additional markets to cover Nordic region ( norway, sweden, finland,
belgium) and southern EU ( spain, italy , portugal, greece).
8. Am reviewing turkey as multiple EU agency heads have indicated strong media market and our large
consumer presence.
These thoughts are consistent with the plan sent to mike monday and I will create a slide to include in
that presentation .
Ted, if there are additional thoughts or considerations to above please feel free to input .
Have a good weekend everybody.
Blake
Blake chandlee
facebook
18 Soho Square, WlD 3QL

FBIRS00246478

FBIRS00246476

 Case 3:16-cv-03777-LB Document 56-2 Filed 02/08/18 Page 4 of 4