Diamond. Joshua From: Sent To: Cc: Subject: Kia Floyd Friday, October 11, 2019 4:44 PM Donovan, Thomas Diamond, Joshua; Sudbay, William; Meeting in Burlington- Facebook Dear Attorney General Donovan: I want to personally thank yOu, Josh Diamond, and Will Sudbay for meeting with me in Burlington last week. I want to reiterate my appreciation for your office?s collaborative approach to working with stakeholders last session and express my hope that this continues into the next session and beyond. We look forward to working proactively with your office on initiatives that aim to protect Vermonters while encouraging tech industry innovation. If you have any ideas that you?d like to run by us, please do not hesitate to reach out to me, or to our Vermont lobbyists Clare Buckley and Maggie Lenz at Leonin'e Public Affairs. Facebook values our relationship with the AGO and the state of Vermont and we look forward to continuing to work together. Thank you. Sincerely, Kia Floyd Head of Public Policy, Northeast facebook 202.368.7469 Ryan From: Curtis, Christopher Sent: Thursday, October 10, 2019 11:16 AM To: Will Castleberry; Kriger, Ryan Cc: Aaron Ting; Jess Leinwand Subject: RE: Vermont Data Broker Registry Hi Will, Thank you for getting back to us. And, sorry for the delay on my end in responding to the information below. I expect that Facebook will continue to monitor its practices with respect to third party data it possesses (to the extent that you have explored, or may explore in the future) certain uses of that data. Should Facebook trigger the definition of ?data broker? pursuant to Vermont law we would reasonably anticipate compliance with the law by simply making the required filing with the Vermont Secretary of State. Thank you for your time and consideration. Best, Christopher Christopher]. Curtis Chief, Public Protection Division Office of the Attorney General State of Vermont 109 State Street Montpelier, VT 05609 802-828-5586 PRIVILEGED CONFIDENTIAL COMMUNICATION: This communication may contain information that is privileged, confidential, and exempt from disclosure under applicable law. DO NOT read, copy or disseminate this communication unless you are the intended addressee. If you are not the intended recipient (or have received this E-mail in error) please notify the sender immediately and destroy this E-mail. Please consider the environment before printing this e-mail. From: Will Castleberry Sent: Wednesday, September 18, 2019 12:26 PM To: Kriger, Ryan Curtis, Christopher Cc: Aaron Ting Jess Leinwand Subject: RE: Vermont Data Broker Registry Chris and Ryan, Sorry for taking a bit to get back to you about if and how we share a non-FB user?s personal information with third parties for advertising purposes. In short, we don?t currently but have explored this in the past. Even in these instances, we would only report to third parties aggregate analytics that might encompass non?FB user data. Here is how it worked. . We tested ads on third party websites that were viewable by non?FB users. We measured the effectiveness of these ads impressions) and provided some of this information in aggregate form to our advertisers (via surfaces like our Ads Manager dashboard). These analytics do not provide individual user-level granularity and our aggregation methodology prevents reporting on an individual or even a group of individuals below a certain minimum threshold. We no longer display these ads to non-users but don?t believe those practices would require us to register as a Data Broker in VT. Thanks again for your time and please let me know if you have any questions. Thanks, Will 202.4200173 From: Kriger, Ryan Sent: Tuesday, August 20, 2019 12:31 PM To: Will Castleberry Curtis, Christopher Cc: Aaron Ting Jess Leinwand Subject: RE: Vermont Data Broker Registry Will, We are pretty open Wednesday through Friday of this week. Any time except Wednesday 1-2 PM or Thursday 2?3 PM EST should work. ?Ryan Ryan G. Kriger Assistant Attorney General Vermont Office of the Attorney General Public Protection Division 109 State Street Montpelier, VT 05609-1001 ph: (802) 828-3170 ryan.kriger@vermont.gov From: Will Castleberry Sent: Tuesday, August 20, 2019 12:01 PM To: Curtis, Christopher Kriger, Ryan Cc: Aaron Ting Jess Leinwand Subject: RE: Vermont Data Broker Registry Thank Christopher, Sorry about the confusion but, yes, we do not believe we qualify as a data broker under the law. Can you give us a few date which may work for a call? Thanks, Will 202.4200173 ph: (802) 828?3170 gan.kriger@vermont.gov From: Will Castleberry Sent: Tuesday, August 20, 2019 12:01 PM To: Curtis, Christopher Kriger, Ryan Cc: Aaron Ting Jess Leinwand Subject: RE: Vermont Data Broker Registry Thank Christopher, Sorry about the confusion but, yes, we do not believe we qualify as a data broker under the law. Can you give us a few date which may work for a call? Thanks, Will 202.4200173 From: Curtis, Christopher Sent: Tuesday, August 20, 2019 9:41 AM To: Kriger, Ryan Will Castleberry Subject: RE: Vermont Data Broker Registry Hi Will, What would be great is a conference call, assuming the company?s position is that the new law does not apply to it, so that we can have a conversation about how, or if, the law does in fact apply. I realize there has been a great deal of reporting on the issue of third party data brokers and Vermont?s new law. And, despite our efforts at outreach (publicity, letters, etc. to reach a wide audience) and offering a guidance there may still be confusion about whether, or if, the law applies to a particular entity. We know Maggie, of course, and she is welcome to participate in a conference call. But, we also thought it might serve to have counsel participate since this really is about the legal de?nition set out in the new statute. As always, happy to continue the conversation so if additional context helps before setting up a call feel free to call me or Ryan directly. Thanks, and hope you' re enjoying summer. Best, Christopher Christopher J. Curtis Chief, Public Protection Division Of?ce of the Attorney General State of Vermont 109 State Street Montpelier, VT 05609 802-828-5586 PRIVILEGED CONFIDENTIAL COMMUNICATION: This communication may contain information that is privileged, con?dential, and exempt from disclosure under applicable law. DO NOT read, copy or disseminate this communication unless you are the intended addressee. If you are not the intended recipient (or have received this E-mail in error) please notify the sender immediately and destroy this E-mail. Please consider the environment before printing this e-mail. .K_ri2er, Ryan From: Kriger, Ryan Sent: Tuesday, August 20,2019 9:34 AM To: wcastleberry@fb.com Cc: Curtis, Christopher Subject: Vermont Data Broker Registry Will, I would like to speak with Facebook?s counsel about its failure to register with Vermont?s Data Broker Registry. I wrote to Facebook in late May about this issue and have spoken about it to Facebook?s local representative, Maggie Lenz. The penalty for failure to register is $50/day, up to $10,000 per year. So far, no one has responded to my inquiries. It is now over 200 days past the January 31, 2019 deadline to register, which means the penalty has maxed out at $10,000 for this year. Please have someone from your counsel?s office contact me as soon as possible. Thank you, ?Ryan Ryan G. Kriger Assistant Attorney General Vermont Office of the Attorney General Public Protection Division 109 State Street Montpelier, VT 05609-1001 ph: (802) 828-3170 ryan.kriger@vermont.gov 42 9:00 AM 10:30 AM 12:00 PM 1:00 PM 10 min. after Floor Fridav, Mav 10, 2019 9:00 AM 9:30 AM 10 min. after Floor 12:00 PM 1:00 PM Liz First Raddock S. 162 - An act relating to promoting economic development David Hall, Legislative Counsel, Of?ce of Legislative Council - Invited TBA Lunch House Floor TBA Committee Discussion House Floor TBA Lunch TBA Legislative Committee Assistant House Commerce and Economic Development Committee 802-828-2255 Iraddock@leg.state.vt.us From: Michael Marcotte Sent: Monday, May 06, 2019 3:23 PM To: Maggie Lenz Rvan.Kriger@vermont.gov; Liz Raddock Subject: Re: 5.110 150 I'm fine with 24 hours longer. Mike From: Maggie Lenz Sent: Monday, May 6, 2019 3:19:31 PM To: Ryan.Kriger@vermont.gov; Michael Marcotte Subject: 5.110 Assistant Attorney General Kriger and Chair Marcotte, Facebook along with the SPSC are working on providing language for the PH data breach notice provision that would be agreeable to all parties. We know this is extremely last minute and I sincerely apologize for the headaches this has caused. if possible, we would respectfully request 24 additional hours to ?nish this negotiation and come to a resolution before finalizing and voting 8.110 out of committee. Please let me know if this is possible. I really appreciate the time you have both put into this and I know we are very nearly at the ?nish line. Thank you for your consideration, Maggie Maggie Lenz Leonine Public Affairs 802.279.4262 (0) 802.229.4900 x. 126 leoninepublicaffairs.com 151 .K_ri2er, Ryan From: Sent: To: Cc: Subject: Yes that works. Ryan G. Kriger Assistant Attorney General Kriger, Ryan Monday, May 6, 2019 3:44 PM Maggie Lenz; Liz Raddock Michael Marcotte RE: 5.110 Vermont Of?ce of the Attorney General Public Protection Division 109 State Street Montpelier, VT 05609-1001 ph: (802) 828?3170 ryan.kriger@vermont.gov From: Maggie Lenz Sent: Monday, May 6, 2019 3:36 PM To: Liz Raddock Cc: Michael Marcotte Kriger, Ryan Subject: Re: 5.110 That works for me if it works for everyone else. Sent from my iPhone On May 6, 2019, at 3:25 PM, Liz Raddock wrote: 0k? Cancel 5.110, 9:30 am. Tues. and move to Wed. at 9:30 am? Tuesday, May 07, 2019 9:00 AM S. 131 - An act relating to insurance and securities House Ways and Means Amendment Rep. Scott Beck 9:30 AM S. 110 - An act relating to data privacy and consumer ?protection Mark-up David Hall, Legislative Counsel, Of?ce of Legislative Council Ryan Kriger, Assistant Attorney General, Attorney General's Of?ce Maggie Lenz, Lobbyist, FaceBook - Invited 152 10:00 AM House Floor and Caucus 10 min. after Caucus TBA 12:00 PM Lunch 1:00 PM TBA Wednesday, May 08,2019 9:00 AM S. 108 An act relating to employee misclassification Damien Leonard, Legislative Counsel, Of?ce of Legislative Council Joshua Diamond, Deputy Attorney General, Attorney General's Of?ce - Invited David Mickenberg, Lobbyist, Vermont Association for Justice Cameron Wood, Director, Unemployment Insurance Division, Department of Labor Dirk Anderson, General Counsel, Department of Labor 10:30 AM House Floor 10 min. after Floor TBA 12:00 PM Lunch 1:00 PM TBA Thursday, May 09, 2019 9:00 AM S. 162 - An act relating to promoting economic development David Hall, Legislative Counsel, Of?ce of Legislative Council - Invited 10:30 AM TBA 12:00 PM Lunch 153 1:00 PM House Floor 10 min. after Floor TBA Friday. Mav 10, 2019 9:00 AM Committee Discussion 9:30 AM House Floor 10 min. after Floor TBA 12:00 PM Lunch 1:00 PM TBA Liz First Raddock Legislative Committee Assistant House Commerce and Economic Development Committee 802-828-2255 lraddock@leg.state.vt.us From: Michael Marcotte Sent: Monday, May 06, 2019 3:23 PM To: Maggie Lenz Rvan.Kriger@vermont.gov; Liz Raddock Subject: Re: 5.110 I'm fine with 24 hours longer. Mike From: Maggie Lenz Sent: Monday, May 6, 2019 3:19:31 PM To: Ryan.Kriger@vermont.gov; Michael Marcotte Subject: 5.110 Assistant Attorney General Kriger and Chair Marcotte, 154 Facebook along with the SPSC are working on providing language for the PH data breach notice provision thatwould be agreeable to all parties. We know this is extremely last minute and I sincerely apologize for the headaches this has caused. if possible. we would respectfully request 24 additional hours to finish this negotiation and come to a resolution before finalizing and voting 8.110 out of committee. Please let me know if this is possible. I really appreciate the time you have both put into this and I know we are very nearly at the finish line. Thank you for your consideration. Maggie Maggie Lenz Leonine Public Affairs 802.279.4262 802.229.9900 x. 126 leoninepublicaffairs.com 155