Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 1 of 110
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`PIERCE BAINBRIDGE BECK
`PRICE & HECHT LLP
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`YAVAR BATHAEE (CA 282388)
`yavar@piercebainbridge.com
`MICHAEL POMERANTZ (NY 2920932) (pro hac vice forthcoming)
`mpomerantz@piercebainbridge.com
`DAVID L. HECHT (NY 4695961) (pro hac vice forthcoming)
`dhecht@piercebainbridge.com
`ADAM C. LUDEMANN (NY 5352323) (pro hac vice forthcoming)
`aludemann@piercebainbridge.com
`277 Park Ave. 45th Floor
`New York, NY 10172
`(212) 484-9866
`
`BRIAN J. DUNNE (CA 275689)
`bdunne@piercebainbridge.com
`355 S. Grand Ave. 44th Floor
`Los Angeles, CA 90071
`(213) 262-9333
`
`Attorneys for Plaintiffs
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
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` Case No. 3:20-cv-363
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`CLASS ACTION COMPLAINT
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`REVEAL CHAT HOLDCO LLC, a
`Delaware limited liability company, USA
`TECHNOLOGY AND MANAGEMENT
`SERVICES, INC. (d/b/a Lenddo USA), a
`Delaware corporation, CIR.CL, INC., a
`dissolved Delaware corporation, and
`BEEHIVE BIOMETRIC, INC., a
`dissolved Delaware corporation,
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`Jury Trial Demanded
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`Plaintiffs,
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`v.
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`FACEBOOK, INC., a Delaware
`corporation,
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`Defendant.
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`Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 2 of 110
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`TABLE OF CONTENTS
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`INTRODUCTION ......................................................................................................................... 1
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`PARTIES ....................................................................................................................................... 5
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` I.
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`PLAINTIFFS ..................................................................................................................... 5
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` II. DEFENDANT .................................................................................................................... 7
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`JURISDICTION AND VENUE .................................................................................................... 8
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`FACTS ........................................................................................................................................... 9
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` I.
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`FACEBOOK EMERGES AS THE DOMINANT SOCIAL NETWORK ........................ 9
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`A.
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`B.
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`C.
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`D.
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`The Last Social Network Standing ........................................................................ 9
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`A New Market of Its Own Creation ..................................................................... 11
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`The Social Data Barrier to Entry ......................................................................... 14
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`Google’s Failed Entry into the Social Data Market ............................................. 16
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` II. A THREAT TO FACEBOOK’S MONOPOLY:
`THE RISE OF SMART PHONES AND MOBILE APPS ............................................... 19
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`A.
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`B.
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`C.
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`D.
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`The Mobile App Revolution ................................................................................ 19
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`Facebook Recognizes the Looming Threat Presented by
`Mobile Applications.............................................................................................. 23
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`The Facebook Platform ........................................................................................ 25
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`The Profitable Open Graph Platform and Mobile Install Business ..................... 27
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` III. FACEBOOK WEAPONIZES ITS PLATFORM TO
`DESTROY COMPETITION ........................................................................................... 30
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`A.
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`B.
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`C.
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`D.
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`Facebook Makes Plans to Remove Vital Friends and News Feed APIs and
`Refuses to Sell Social Data to Competing Application Developers .................... 30
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`Facebook’s Social-Data Heist .............................................................................. 32
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`Facebook Targets Its Competitors for Reciprocity or Denial of API Access ...... 37
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`The Decision to Remove Developer Access to the Friends, News
`Feed and Other Crucial APIs Lacked Any Legitimate Justification .................... 41
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`Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 3 of 110
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`TABLE OF CONTENTS
`(continued)
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`E.
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`F.
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`Facebook Prepares to Announce Removal of the APIs ....................................... 46
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`The Announcement at F8 ..................................................................................... 50
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` IV. THE WHITELIST AND DATA SHARING AGREEMENTS ....................................... 51
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` V. THE SURVEILLANCE AND ACQUISITION OF
`COMPETITIVE THREATS ............................................................................................. 55
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`A.
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`B.
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`Facebook Relies on Onavo’s Surveillance of Facebook’s Competitors, and
`Acquires and Uses Onavo’s Assets ...................................................................... 56
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`Facebook Identifies Instagram as a Threat and
`Acquires the Company ......................................................................................... 60
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`C.
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`Facebook Acquires WhatsApp ............................................................................ 66
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` VI. FACEBOOK’S INTEGRATION OF INSTAGRAM AND WHATSAPP
`WITH ITS FACEBOOK PRODUCT .............................................................................. 71
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` VII. THE RELEVANT MARKETS......................................................................................... 77
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`A.
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`B.
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`C.
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`D.
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`The Social Data Market ....................................................................................... 77
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`The Social Advertising Market ............................................................................ 83
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`Barriers to Entry ................................................................................................... 85
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`Relevant Geographic Markets ............................................................................... 87
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` VIII. HARM TO COMPETITION AND ANTITRUST INJURY ............................................ 88
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`CONCEALMENT AND TOLLING ............................................................................................ 94
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`CLASS ACTION ALLEGATIONS ............................................................................................. 94
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`CLAIMS FOR RELIEF ................................................................................................................ 99
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`PRAYER FOR RELIEF ............................................................................................................. 106
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`JURY DEMAND ........................................................................................................................ 107
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`Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 4 of 110
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`1.
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`Plaintiffs allege the following on behalf of themselves and others similarly situated
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`on information and belief based on the review of only public documents and information. All
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`references to internal Facebook documents are exclusively to those published by news
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`organizations and other public sources, particularly NBC News.1 Neither Plaintiffs nor the
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`undersigned counsel viewed or received, or even had access to, any confidential information about
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`Facebook at the time this complaint was filed.
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`INTRODUCTION
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`2.
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`This action seeks to halt the most brazen, willful anticompetitive scheme in a
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`generation—a scheme that verges on final, irreparable completion as of the date of this Complaint.
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`3.
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`Facebook stands today as a paragon of unbridled market power. A company with
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`unprecedented reach, Facebook collects and monetizes the activity of more than two billion active
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`users around the world. Facebook’s advertising juggernaut produces almost $55 billion in revenue
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`in a year, and its founder and CEO, Mark Zuckerberg, enjoys incontestable control over the
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`company and its board. Facebook owns some of the most valuable social networks other than
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`Facebook itself, including Instagram and WhatsApp. As 2020 begins in earnest, Facebook has no
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`serious rival in its key markets—nor any prospect of one.
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`4.
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`It was not always so. In 2010, when Facebook defeated rivals MySpace and
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`Friendster and emerged as the winner of the social network wars, the company was caught
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`flatfooted by a new technology that threatened its dominance—smartphones.
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`5.
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`Facebook’s dominance had been fortified by powerful network effects—the more
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`data it collected on users, the more attractive its social network became to users. As a result, a
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`social data barrier to entry (“SDBE”) emerged, protecting Facebook’s business. This SDBE
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`
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`1 As of the date of this complaint, NBC’s documents were available at
`https://dataviz.nbcnews.com/projects/20191104-facebook-leaked-documents/as
`https://dataviz.nbcnews.com/projects/20191104-facebook-leaked-documents/assets/facebook-
`exhibits.pdfsets/facebook-sealed-exhibits.pdf; and
`https://dataviz.nbcnews.com/projects/20191104-facebook-leaked-documents/assets/facebook-
`exhibits.pdf.
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`allowed Facebook to fend off a frontal assault by Google’s polished social network, Google+.
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`Google, with its massive resources and user base, failed to penetrate the SDBE, and Google
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`abandoned the project after it was clear that users were not engaging on its platform.
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`6.
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`Smartphones, however, were different. Significant advances in mobile technology
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`allowed users to access the internet from any location, on user interfaces controlled by touch,
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`providing a distinct experience from desktop or laptop computers. Special-purpose apps designed
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`specifically for smart phones could not only access the Internet, but also users’ address books—a
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`ready-made social network from which apps could draw.
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`7.
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`These apps had become direct competitors to Facebook, providing overlapping
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`functionality such as messaging, photo sharing, dating, check-ins, and payments. Facebook failed
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`to create its own viable mobile app, and by 2011, found its dominance threatened. Zuckerberg
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`told Fortune, “[i]t was probably one of the biggest mistakes we've ever made.” Facebook’s own
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`mobile app was buggy and slow, garnering one-star ratings in the Apple App Store and crashing
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`more often than it worked.
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`8.
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`This existential threat to Facebook’s monopoly in social data and social advertising
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`came as the company was barreling towards an initial public offering (“IPO”) worth billions.
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`Facebook had successfully built a developer platform upon which third-party developers could
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`build social applications, driving engagement on Facebook’s Platform and thereby Facebook’s
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`revenue. It was clear, however, that the very same Platform was providing Facebook’s competitors
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`with access to Facebook’s network of users. Third-party developers began using Facebook’s
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`Platform in more novel and creative ways than Facebook itself was doing. Facebook found itself
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`lagging behind these third-party social applications in the mobile arena.
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`9.
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`With its market dominance in imminent danger, Facebook moved to extinguish the
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`mobile threat, to obtain a sustaining foothold in the Social Data and Social Advertising Markets,2
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`2 Defined terms are set forth elsewhere in the body of the Complaint.
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`and to prevent any newcomers from building rival social networks. To do so, Zuckerberg and
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`Facebook’s most senior executives hatched an anticompetitive scheme of unprecedented scale.
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`10.
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`11.
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`The scheme spanned several fronts:
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`First, Facebook moved to crush or co-opt competition that existed on its own
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`Platform. Facebook identified and categorized potential market threats, then extinguished those
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`threats by cutting them off from key application program interfaces (“APIs”) in Facebook’s
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`Platform—functionality that provided social applications with user data that fueled their growth.
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`As Facebook’s own executives and engineers acknowledged, the company’s decision to remove
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`core functionality from its Platform not only lacked any legitimate or technical justification, but
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`Facebook sacrificed massive amounts of additional social data, engagement, and advertising that
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`it received from its Platform to do it.
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`12.
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`Second, Facebook collected valuable user data from competing platforms, growing
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`its own mobile footprint and constraining the growth of rivals. Facebook accomplished this with a
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`network of Whitelist and Data Sharing agreements with direct competitors, including rival social
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`networks (such as Pinterest and Foursquare) and apps that generated large amounts of user data
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`from engagement (such as Tinder). Facebook coerced these competitors into handing over their
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`central assets—their social data—by again leveraging its Platform, threatening the apps with
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`extinction by starving them of access to core Platform APIs if they did not join Facebook’s so-
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`called “reciprocity” scheme. Those who did join received not only access to social data, but the
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`data of others that had joined Facebook’s scheme, with Facebook acting as a hub for the exchange
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`of user data among competitors.
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`13.
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`Third, Facebook moved aggressively to shut out entirely direct competitors that
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`had built independent social networks of their own and did not rely on Facebook for their social
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`data and user base. Facebook revoked the ability of competitors, such as WeChat and Line, to use
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`Facebook’s Platform, and even banned them from buying Facebook’s social data through
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`advertising, forgoing significant profits to do so.
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`14.
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`Fourth, Facebook monitored the market for nascent threats to its business, and then
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`extinguished these threats through anticompetitive conduct or by targeted acquisition. Facebook
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`did so using mobile surveillance technology it acquired from Onavo, a company that cloaked
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`spyware in legitimate-looking utility apps. For example, in 2012-13, Facebook’s surveillance
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`warned it that both Instagram and WhatsApp were imminent threats to Facebook’s core business,
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`with each app having accumulated staggering user bases and levels of engagement while directly
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`competing with Facebook. Facebook moved forcibly to acquire both companies, and with each
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`acquisition, it dramatically increased its share of the Social Data and Social Advertising markets—
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`not only maintaining its market power and the SDBE but, expanding and strengthening them.
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`15.
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`Today, Facebook is rapidly working to integrate the backends of its acquired
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`WhatsApp and Instagram assets in the face of regulatory concern over Facebook’s unchecked
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`market power and anticompetitive conduct. This is no coincidence. Facebook’s integration efforts
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`are deliberately intended to avoid regulatory divestiture of assets, to consolidate the geographic
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`regions it controls through its various apps, and to finally flex the market power it acquired through
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`those mergers. This last piece of Facebook’s monopolization scheme is on the verge of
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`completion—and once culminated, the backend integration will imbue Facebook with unrivaled
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`global dominance of the Social Data and Social Advertising Markets.
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`16.
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` The net effect of Facebook’s anticompetitive scheme is one of the largest unlawful
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`monopolies ever seen in the United States—one protected by a far-reaching and effectively
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`impenetrable barrier to entry arising from feedback loops and powerful network effects. Facebook
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`not only has the power to raise prices and keep them high, it can do so without suffering any
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`decrease in demand, and without having to provide more value to users to obtain their data. This
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`is the very definition of market power. Facebook has sought to bury the story of how it acquired,
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`maintained and abused that market power for years, but ultimately it cannot avoid the truth.
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`17.
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`This lawsuit seeks to hold Facebook accountable for its overtly anticompetitive
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`conduct. The company, its executives, and its engineers worked together over years to execute the
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`anticompetitive scheme described in this Complaint. They did so with flagrant disregard for
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`competition, for Facebook users, or for the law. Plaintiffs seek trebled damages and injunctive
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`relief under the federal antitrust laws to remedy Facebook’s brazen play for dominance—and to
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`stop the company from further solidifying its unlawful monopoly, barrier to entry, and market
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`power.
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`I.
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`PLAINTIFFS
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`PARTIES
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`18.
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`Plaintiff Reveal Chat HoldCo LLC (“Reveal Chat”) is a Delaware limited liability
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`company headquartered in Bainbridge Island, WA. Reveal Chat is the successor in interest to
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`Reveal Chat, Inc. (f/k/a LikeBright, Inc. (“LikeBright”)), pursuant to an April 2015 merger
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`between Reveal Chat and Reveal Chat, Inc.
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`19.
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`LikeBright was founded in 2011 and launched the dating site LikeBright.com that
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`same year. LikeBright was designed as a platform to make dating safe and fun for women. Unlike
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`most other matchmaking platforms during that time period, Likebright was designed to incorporate
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`users’ social media data to help facilitate better matches, drawing on second-degree friend
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`connections and shared interests. LikeBright also featured a system in which women could vouch
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`for their male friends. In order to facilitate these and other features essential to its business model,
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`LikeBright was designed to incorporate—and relied heavily on—social media data made available
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`by Facebook to developers (during the time LikeBright operated) through its Open Graph APIs.
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`Such social data included friends, photos, likes, groups, pages and other data that facilitated pairing
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`members to matches with similar interests and shared friends.
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`20.
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`Plaintiff USA Technology and Management Services, Inc. (d/b/a Lenddo USA)
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`(and together with its affiliates, referred to herein as “Lenddo”) is a Delaware corporation with its
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`principal place of business in New York, NY.
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`21.
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`Lenddo is a market leader in alternative credit scoring and identity verification,
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`allowing individuals and small enterprises in emerging markets to leverage their digital footprints,
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`including social media data, to unlock access to financial and credit services to which they might
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`not have access through traditional means. Founded in 2011, Lenddo first began underwriting and
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`making loans to customers in the Philippines. It then entered the Columbian market in 2012,
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`followed shortly thereafter by its entry into the Mexican market in 2013. By 2014, Lenddo had
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`originated over 10,000 loans using its proprietary LenddoScore algorithm and was able to provide
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`customers the world’s first Facebook-only loan origination process. Lenddo’s origination
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`algorithm was designed to incorporate and analyze social media data provided by Facebook to its
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`developers, including through its Open Graph APIs, in order to accurately measure credit risk
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`based on factors such as friend networks, frequency and consistency of social interactions, and the
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`social media characteristics of applicants’ friend connections. In 2015, Lenddo first made available
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`to third parties its proprietary data scoring system and began offering identity verification services.
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`22.
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`Plaintiff Cir.cl, Inc. (“Cir.cl”) is a dissolved Delaware corporation formerly
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`headquartered in New York, NY. Plaintiff Cir.cl’s claims are brought by and through Carol
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`Davidsen, who has been appointed as a receiver by the Delaware Court of Chancery pursuant to 8
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`Del. C. § 279 for purposes of pursing Cir.cl’s claims in this action.
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`23.
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`Cir.cl was founded in 2013 and designed an online platform for individuals and
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`communities to manage peer-to-peer marketplace transactions, with the goal of allowing real-time
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`integration of users’ various online communities. This allowed them to use their digital presence
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`and social connections to complete real-life peer-scale marketing and fulfilment goals. Cir.cl’s
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`platform was designed around and incorporated its user’s social media data, including data made
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`available by Facebook through its Open Graph APIs.
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`24.
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`Plaintiff Beehive Biometric, Inc. (a/k/a Beehive ID) (“Beehive”) is a dissolved
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`Delaware corporation formerly headquartered in Austin, TX. Plaintiff Beehive’s claims are
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`brought by and through Mary Haskett, who has been appointed as a receiver by the Delaware Court
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`of Chancery pursuant to 8 Del. C. § 279 for purposes of pursing Beehive’s claims in this action.
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`25.
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`Beehive was founded in 2013 and designed an identity verification system drawing
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`heavily on social media data through a trademarked and proprietary Social Authentication
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`Technology (“SAT”). Beehive’s SAT leveraged social media data, including data made available
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`through Facebook’s Open Graph APIs, to identify fraud risks based on unique digital patterns and
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`online social interactions.
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`II.
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`DEFENDANT
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`26.
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`Defendant Facebook, Inc. (“Facebook”) is a publicly traded company, incorporated
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`in Delaware. Facebook’s principal place of business and headquarters is located at 1601 Willow
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`Road in Menlo Park, California.
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`27.
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`Founded in 2004 by Mark Zuckerberg, Facebook is a social media company that
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`provides online services to two billion users around the world. In exchange for providing services,
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`Facebook collects user data, which it uses to create and sell targeted advertising services.
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`Facebook’s principal revenue is from targeted social media advertising that it provides to
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`advertisers as a data broker.
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`28.
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`Facebook also operates as a platform for third-party applications and hardware, and
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`owns and operates several business divisions:
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` Facebook. Facebook’s core application, which bears the Company’s name, is,
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`according to Facebook’s filing with shareholders, designed to enable “people to
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`connect, share, discover, and communicate with each other on mobile devices and
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`personal computers.” The Facebook core product contains a “News Feed” that
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`displays an algorithmically ranked series of stories and advertisements
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`individualized for each person.
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`
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`Instagram. Instagram is a photo sharing application, which allows users to share
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`photos, videos and messages on mobile devices. Instagram was acquired in April
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`2012 and at present, Facebook operates Instagram as a separate application from its
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`core Facebook product—but that is about to change, absent relief from this Court.
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`Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 11 of 110
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` Messenger. Facebook’s Messenger application is a multimedia messaging
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`application, allowing messages that include photos and videos to be sent from
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`person to person across platforms and devices.
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` WhatsApp. WhatsApp is a secure messaging application used by individuals and
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`businesses. WhatsApp was acquired by Facebook in 2014 for $21.8 billion, and at
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`the time had approximately 450 million users worldwide. Facebook operates
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`WhatsApp as its own application, separate from its Messenger and Facebook
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`products and lines of business—but that is about to change, absent relief from this
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`Court.
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` Oculus. Oculus is Facebook’s virtual reality hardware line of business, which
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`Facebook acquired in March 2014 for approximately $2 billion.
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`29.
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`Facebook’s revenue as of year-end 2018 was $55.84 billion, with net income from
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`operations of $21.11 billion. Almost all of this revenue ($55 billion) came from advertising. As of
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`year-end 2018, Facebook maintained $41.11 billion in cash and cash-equivalent securities.
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`Facebook employed 35,587 people around the world at the end of 2018.
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`30.
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`Across all of its lines of business, Facebook reported to investors in 2018 that it had
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`1.52 billion daily active users (“DAU”) on average for the year. Facebook reported 2.32 billion
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`monthly active users (“MAU”) on average during the same period.
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`JURISDICTION AND VENUE
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`31.
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`This action arises under sections 1 and 2 of the Sherman Antitrust Act (15 U.S.C.
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`§§ 1 and 2) and sections 4, 7, and 16 of the Clayton Act (15 U.S.C. §§ 15(a), 18, and 26). The
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`action seeks to recover treble damages, interest, costs of suit, equitable relief, and reasonable
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`attorneys’ fees for damages to Plaintiffs and members of the Class resulting from Defendant’s
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`restraints of trade and monopolization of the Social Data and/or Social Advertising Markets
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`described herein.
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`Case 3:20-cv-00363 Document 1 Filed 01/16/20 Page 12 of 110
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`32.
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`This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 (federal
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`question), 1332 (class action diversity jurisdiction), and 1337(a) (antitrust); and under 15 U.S.C.
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`§ 15 (antitrust).
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`33.
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`Venue is appropriate in this district under 15 U.S.C. § 15(a) (Clayton Act), 15
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`U.S.C. § 22 (nationwide venue for antitrust matters), and 28 U.S.C. § 1391(b) (general venue
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`provision). Facebook transacts business within this district, and it transacts its affairs and carries
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`out interstate trade and commerce, in substantial part, in this district.
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`34.
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`The Court has personal jurisdiction over Facebook as it is subject to general
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`jurisdiction in the State of California, where it maintains its headquarters and its principal place of
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`business. The scheme, conspiracy, and monopolization alleged in this Complaint was targeted at
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`individuals throughout the world and the United States, causing injury to persons not only
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`throughout the world, but in the United States, including in this district.
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`FACTS
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`I.
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`FACEBOOK EMERGES AS THE DOMINANT SOCIAL NETWORK
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`A.
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`35.
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`The Last Social Network Standing
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`Facebook’s meteoric rise since its founding in 2004 is well documented. The
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`company—started in the dorm room of its CEO Mark Zuckerberg (“Zuckerberg”) as “the
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`facebook”—rose to prominence in the face of fierce competition from several social networks.
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`Initially an exclusive service for elite universities throughout the United States, Facebook
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`eventually expanded its network to encompass a general audience of users throughout the United
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`States and worldwide.
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`36.
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`Between 2004 and 2010, Facebook vanquished a number of rivals to emerge as the
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`dominant social network in the United States.
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`37.
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`Facebook’s first chief competitor was MySpace. Founded in 2003—a year before
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`Facebook—MySpace targeted the same audience, provided largely the same services, and rapidly
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`attracted an enormous number of users. By 2005, MySpace had 25 million active users, and was
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`acquired by NewsCorp for $580 million. In 2006, MySpace registered 100 million users, passing
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`Google as the most visited website in the United States.
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`38.
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`However, the next three years featured a steady downward spiral for MySpace—
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`and countervailing growth by Facebook. In 2008, Facebook passed MySpace in worldwide active
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`users, and continued to grow, reaching 307 million active users across the globe by April 2009. In
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`May 2009, Facebook passed MySpace in United States, 70.28 million to 70.26 million monthly
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`active users.
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`39. MySpace never came close to Facebook again. By 2010, MySpace had mostly
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`exited the market, leaving the business of social media for good. MySpace’s CEO capitulated in
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`November of 2010: “MySpace is not a social network anymore. It is now a social entertainment
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`destination.” In September 2010, MySpace reported that it had lost $126 million, and in June 2011,
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`NewsCorp sold the company for $35 million—$545 million less than it had paid for MySpace just
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`six years earlier. By then, its user base had dwindled to just 3 million monthly visitors.
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`40.
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`During the same time period, several other social networks also met their demise,
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`including Google’s Orkut, AOL’s Bebo, and Friendster, which failed to scale rapidly enough to
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`compete with MySpace and Facebook.
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`41.
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`By 2009 and through 2010, Facebook emerged as the only peer-to-peer social
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`media network to exist at scale, and no other network or company rivaled Facebook’s massive user
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`base. On March 2, 2010, Adweek reported that Facebook had booked revenues of up to $700
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`million in 2009 and was on track for $1.1 Billion in 2010—almost all from advertising to its newly
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`won users. Facebook had been roughly doubling its revenues every year up until that point—$150
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`million in 2007; $280-300 million in 2008; and $700 million in 2009.
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`42.
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`Time Magazine heralded Zuckerberg as its 2010 Person of the Year.
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`43.
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`Time’s cover story set out the stakes—the scope of the newly assembled social
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`network was unprecedented and staggering:
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`What just happened? In less than seven years, Zuckerberg wired
`together a twelfth of humanity into a single network, thereby
`creating a social entity almost twice as large as the U.S. If Facebook
`were a country it would be the third largest, behind only China and
`India. It started out as a lark, a diversion, but it has turned into
`something real, something that has changed the way human beings
`relate to one another on a species-wide scale. We are now running
`our social lives through a for-profit network that, on paper at least,
`has made Zuckerberg a billionaire six times over.
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`44.
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`By 2010, Facebook was unrivaled and dominant in a way no company since
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`Microsoft had been in post-personal-computer history. And it had done so by riding the currents
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`of powerful network effects.
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`B.
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`45.
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`A New Market of Its Own Creation
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`By the beginning of the millennium’s second decade, Facebook was the
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`indisputable king of an entirely new market—a market built not on hardware or operating system
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`dominance, but one built on a network of people, with its power and value directly derived from
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`their engagement with that network. The more data users fed into Facebook by communicating
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`and interacting with each other, posting their pictures, and publishing their content, the more
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`valuable the Facebook network became to third parties, who could advertise to Facebook’s users
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`by targeting them using the very information they provided to Facebook’s network.
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`46.
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`Data about what information users shared on their personal pages; the photos and
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`profiles they viewed; their connections to others; what they shared with others; and even what they
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`put in messages to