Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 1 of 28
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`HUNTON ANDREWS KURTH LLP
`Ann Marie Mortimer (State Bar No. 169077)
`amortimer@HuntonAK.com
`Jason J. Kim (State Bar No. 221476)
`kimj@HuntonAK.com
`Jeff R. R. Nelson (State Bar No. 301546)
`jnelson@HuntonAK.com
`550 South Hope Street, Suite 2000
`Los Angeles, California 90071-2627
`Telephone: (213) 532-2000
`Facsimile: (213) 532-2020
`
`Attorneys for Plaintiff
`FACEBOOK, INC.
`
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION
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`
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`FACEBOOK, INC., a Delaware
`corporation,
`
`
`Plaintiff,
`
`
`
`v.
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`
`MOHAMED ZAGHAR, d/b/a
`Massroot8,
`
`
`Defendant.
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` CASE NO.: 3:20-CV-04054
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`COMPLAINT; DEMAND FOR JURY
`TRIAL
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`COMPLAINT; DEMAND FOR JURY TRIAL
`Case No. 3:20-cv-04054
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 2 of 28
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`Plaintiff Facebook, Inc. (“Facebook”) asserts the following:
`INTRODUCTION
`Beginning no later than 2018 and continuing to the present, Defendant
`1.
`operated an unlawful business using the website massroot8.com, which targeted
`Facebook and its users. Defendant’s business was an online service designed to
`improperly collect certain user data – namely, email address, mobile phone number,
`gender, and date of birth. Defendant collected the data by using self-compromised
`accounts and a computer program to control a network of computers or “bots,” which
`pretended to be an Android device connected to the official Facebook mobile app.
`Through this fraudulent mobile connection, Defendant’s service delivered automated
`requests for user data to Facebook computers and transmitted the data to
`massroot8.com. This data harvesting technique is known as “mobile scraping.”
`Specifically, between April 23, 2020 to May 6, 2020, Defendant’s service
`2.
`collected and used Facebook login credentials from approximately 5,500 users, in
`order to access Facebook and scrape user data. This was not authorized by Facebook.
`Facebook now seeks injunctive relief and damages to remedy and prevent Defendant’s
`violations of Facebook’s Terms of Service, the Computer Fraud and Abuse Act, and
`California Penal Code Section 502.
`
`PARTIES
`Plaintiff Facebook, Inc., is a Delaware corporation with its principal place
`3.
`of business in Menlo Park, San Mateo County, California.
`Defendant Mohamed Zaghar is a resident of Morocco, and since 2014,
`4.
`and at all times relevant to this Complaint, he owned and operated several websites,
`including fast-likers.com, fast-autolikers.com, and massroot8.com. Exs. 1 – 4.
`JURISDICTION AND VENUE
`The Court has federal question jurisdiction over the federal cause of
`5.
`action alleged in this Complaint pursuant to 28 U.S.C. § 1331.
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`COMPLAINT; DEMAND FOR JURY TRIAL
`Case No. 3:20-cv-04054
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 3 of 28
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`The Court has supplemental jurisdiction over the state law causes of
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`action alleged in the Complaint pursuant to 28 U.S.C. § 1367 because these claims
`arise out of the same nucleus of operative facts as Facebook’s federal claim.
`In addition, the Court has jurisdiction under 28 U.S.C. § 1332 over all
`7.
`causes of action alleged in this Complaint because complete diversity exists and the
`amount in controversy exceeds $75,000.
`The Court has personal jurisdiction over Zaghar because he had multiple
`8.
`Facebook accounts and thereby agreed to Facebook’s Terms of Service and agreed to
`submit to the personal jurisdiction of this Court for litigating this matter.
`In addition, the Court has personal jurisdiction over Zaghar because he
`9.
`knowingly directed and targeted his conduct at California and at Facebook, which has
`its principal place of business in California. Zaghar transacted business and engaged
`in commerce in California by, among other things, using a California server to host
`the website massroot8.com. Facebook’s claims arise directly from these California
`contacts.
`10. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) as the
`threatened and actual harm to Facebook occurred in this District.
`11. Pursuant to Civil L.R. 3-2(c), this case may be assigned to either the San
`Francisco or Oakland division because Facebook is located in San Mateo County.
`FACTUAL ALLEGATIONS
`Background on Facebook
`A.
`12. Facebook is a social networking website and mobile application that
`enables its users to create their own personal profiles and connect with each other on
`their personal computers and mobile devices. As of March 2020, Facebook daily
`active users averaged 1.73 billion and monthly active users averaged 2.6 billion.
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 4 of 28
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`13. To access Facebook and view certain user profiles, Facebook requires
`that each user create a Facebook account. To create a Facebook account, Facebook
`requires each user to register with a unique username and password.
`14. Registered users can create user profiles and include information about
`themselves, including their email address, phone numbers, and date of birth.
`Registered Facebook users can make connections on Facebook by becoming “Friends”
`with other Facebook users.
`15. Facebook provides its users with control over how to customize their
`profiles and how much personal information to include in their profile. In addition,
`Facebook’s privacy settings provide users with control over how much profile
`information is viewable publicly, to other Facebook users, or to the users’ Friends.
`16. Facebook uses a number of technical measures to secure its service.
`These include measures designed to verify that users access the service through the
`official Facebook mobile application (on Android or iPhone) and have proper access
`to their account. For example, the official Facebook mobile application has a unique
`application identification number and digitally signs requests sent to Facebook servers,
`using a cryptographic key embedded in the application and a proprietary signature.
`17. When a Facebook user logs into Facebook through the official Facebook
`mobile app, his or her device connects with restricted computers that provide the user
`with access to their profile and posts, as well as their Friends’ profile and posts (subject
`to the Friends’ privacy settings).
`B.
`Facebook’s Terms of Service
`18. All Facebook users must agree to Facebook’s Terms of Service
`(“Terms”) (available at https://www.facebook.com/terms.php) and other rules that
`govern access to, and use of, Facebook.
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 5 of 28
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`19. Section 3.2.1 of Facebook’s Terms prohibits users from “do[ing] . . .
`anything unlawful, misleading, [ ] or fraudulent” or facilitate or support others in doing
`so.
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`20. Section 3.2.2 of Facebook’s Terms prohibits users from “do[ing]
`anything that could . . . impair the proper working or appearance of [Facebook]
`Products.”
`21. Section 3.2.3 of Facebook’s Terms prohibits “access[ing] or collect[ing]
`data from [Facebook] Products using automated means (without our permission) or
`attempt[ing] to access data you don’t have permission to access.”
`C.
`Background on Scraping
`22.
`“Web scraping” refers to the process of extracting data from a website
`interface. This can be done manually (i.e. copy and paste by a person) or by using
`automated means, such as specialized tools and software. Websites, including the
`official Facebook site, are designed for human end-users and not for automated use,
`and employ anti-scraping measures to prevent and detect web scraping.
`“Mobile scraping” refers to the process of extracting data from a mobile
`23.
`application by using a fraudulent mobile connection. A mobile application is a kind of
`software specifically designed to run on a mobile device and connect to protected
`computers. Mobile scrapers use specialized software to collect data pretending to be
`an Android or iPhone device to connect to protected computers. Through this
`fraudulent mobile connection, mobile scrapers deliver automated requests for data.
`24. Automation tools and software are necessary for mobile scraping.
`Facebook employs a number of measures to detect and disrupt unauthorized automated
`requests on its systems, including monitoring use patterns that are inconsistent with a
`human user, CAPTCHA, and disabling of accounts engaged in automated activity.
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`25. When web and mobile scrapers extract the desired data from a website or
`mobile app, they often restructure and format it, and can save and store it for further
`use, such as lead generation and pricing competition and optimization.
`D.
`Background on Defendant Zaghar
`26. At various times between May 2007 and February 2019, Zaghar created
`and used approximately ten Facebook accounts and agreed to Facebook’s Terms.
`Zaghar also created and controlled several Facebook apps and Pages.
`27. Zaghar created and used certain Facebook accounts before receiving a
`cease and desist letter from Facebook. Facebook disabled his known accounts on or
`about July 11, 2018, when it sent the cease and desist letter to Zaghar. Subsequently,
`Zaghar created at least three Facebook accounts using the aliases “Ixo Ver,” and “Zag
`Har.”
`28. Between August 2014 and September 2016, Zaghar controlled and
`operated the website fast-likers.com. Exs. 1 and 4. Between February 2016 and
`October 2018, Zaghar used the domain fast-autolikers.com to host his website. Exs.
`2 and 4.
`29. Between September 2014 and July 2018, Zaghar operated the fast-
`likers.com and fast-autolikers.com websites. On those websites, which no longer
`operate, Zaghar offered a scraping service with various functionalities, including the
`ability to extract the mobile phone number and email address of a Facebook user.
`Zaghar also offered fake engagement services, including the ability to artificially
`increase the number of a users’ Facebook friends. Zaghar advertised the fast-liker.com
`and fast-autolikers.com services on YouTube using the name “TheMrZaghar.” Ex. 5.
`30. Beginning no later than October 27, 2018, Zaghar began operating the
`website massroot8.com and redirecting users of the fast-autolikers.com website to the
`massroot8.com website. Ex. 4. As explained in more detail below, Zaghar offered
`another scraping service on massroot8.com.
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 7 of 28
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`Facebook’s Prior Enforcement Against Zaghar
`E.
`31. On or about July 11, 2018, Facebook sent Zaghar a cease and desist letter
`by FedEx and email. In the letter, Facebook demanded that Zaghar stop violating
`Facebook’s Terms, revoked his access to Facebook, and notified Zaghar that his
`conduct may violate the Computer Fraud and Abuse Act (18 U.S.C. § 1030), as well
`as Section 502 of the California Penal Code. Facebook also deleted apps, pages, and
`user accounts associated with Zaghar.
`32. On July 19, 2018, Zaghar sent an email to Facebook’s attorneys stating
`that he “closed” the fast-autolikers.com website and deleted any Facebook user data
`he collected as a result of operating that website. He also provided a list of Facebook
`user account IDs that allegedly used his service.
`33. By August 5, 2018, Zaghar posted on fast-autolikers.com that the site was
`“closed,” and that he had been contacted “by Facebook lawyers that [sic] if the site is
`not stopped, they will sue [ ] because the site violates Facebook’s privacy policy.”
`Zaghar also wrote that Facebook learned that his website was “helping people to know
`their friends ’information [sic] and this is causing them harm so Facebook has disabled
`[a]ll the accounts of the owner of the site . . . and the owner of the site was permanently
`banned from using Facebook . . . .” Ex. 6.
`F.
`Zaghar’s Scraping Service Violates Facebook’s Terms
`34. After Facebook revoked Zaghar’s access to Facebook and sent Zaghar
`the cease and desist letter, he violated Facebook’s Terms by creating approximately
`three new Facebook user accounts and accessing Facebook for the purpose of scraping
`non-publicly viewable user data. Specifically, Zaghar used mobile scraping in order
`to obtain data from Facebook protected computers.
`In or around October 27, 2018, Zaghar began using the website
`35.
`massroot8.com to engage in new scraping activity targeting Facebook and its users.
`Specifically, Zaghar’s fast-autolikers.com website began directing users to the website
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`massroot8.com. Ex. 7. As a result, anyone who tried to visit the fast-autolikers.com
`website would instead visit the massroot8.com website.
`36. On the massroot8.com website, Zaghar offered his customers the ability
`to scrape their Facebook Friends’ contact information, such as email address, phone
`number, gender, and date of birth. Zaghar did not charge users a fee to access and use
`the massroot8.com website. Instead, Zaghar ran advertisements on his website to
`generate revenue.
`37. To use Zaghar’s scraping service, massroot8.com customers first had to
`create an account on massroot8.com.
` Zaghar’s customers registered with
`massroot8.com with an email address, first and last name, and a password. Zaghar’s
`customers also needed a valid Facebook username and password in order to use the
`service. After registering with massroot8.com, Zaghar required his customers to link
`their Facebook account to their massroot8.com account and share their Facebook login
`credentials with the service. As a result, Zaghar’s customers self-compromised their
`Facebook account by relinquishing control of their username and password.
`38. After Zaghar collected the user’s access information, his scraping
`software enabled the automated and improper collection of data from Facebook. In
`order to evade Facebook’s technical restrictions against web scraping, Zaghar’s
`scraping software engaged in mobile scraping by emulating Facebook’s official
`Facebook Android app to connect a bot with Facebook restricted endpoints, and send
`automated requests to Facebook as if a human user was logging into the Facebook app.
`Zaghar and his customers could not use the scraping software to access any Facebook
`user data that they were not otherwise authorized to view by their Facebook Friends.
`39. Zaghar’s scraping software was programmed to request user data from
`Facebook and transmit it to massroot8.com, where it was accessible to his customers
`on a dashboard.
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`40. Between April 23, 2020 and May 6, 2020, Zaghar’s service used
`approximately 5,500 Facebook users’ credentials to obtain, through automated means,
`their Facebook Friends’ email address, mobile phone number, and date of birth. In
`large part, this data was not publicly viewable, rather, only registered Facebook users
`who were logged into Facebook and were Facebook Friends with Zaghar’s customers
`could view the data.
`41. Facebook has taken various technical enforcement measures against
`Zaghar and his customers, including disabling Zaghar’s user accounts on Facebook
`and Instagram and requiring his customers to create new passwords in order to secure
`their Facebook accounts.
`G. Zaghar’s Acts Harmed Facebook
`42. Zaghar’s scraping service and his violations of Facebook’s Terms have
`caused Facebook to expend valuable resources to investigate and remediate his
`conduct.
`43. Facebook has suffered damages attributable to the efforts and resources
`it has used to address Zaghar’s conduct described in this Complaint in an amount to
`be determined at trial, and in excess of $75,000.
`FIRST CAUSE OF ACTION
`(Breach of Contract)
`44. Facebook realleges and incorporates all preceding paragraphs here.
`45. Between 2007 and 2019, Zaghar created multiple Facebook accounts and
`agreed to Facebook’s Terms. Facebook’s Terms constitute an agreement between
`Facebook users and Facebook.
`In addition, since at least 2015, Zaghar collected and used Facebook
`46.
`users’ login credentials. These users’ accounts were also governed by Facebook’s
`Terms and Policies. Because Zaghar’s unlawful business used the Facebook platform,
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`including targeting Facebook user accounts that were governed by Facebook’s Terms,
`Zaghar further agreed to be bound by Facebook’s Terms.
`47. Despite his agreement to Facebook’s Terms, Zaghar breached and
`continues to breach Terms sections 3.2.1, 3.2.2, and 3.2.3 by (a) accessing and using
`Facebook after Facebook revoked his access; (b) scraping data from Facebook using
`automated means without Facebook’s permission; (c) sending code to Facebook that
`masquerades as the Facebook mobile app, which is “unlawful, misleading, [ ] or
`fraudulent;” and (d) facilitating others to scrape data from Facebook without
`Facebook’s permission through the massroot8.com website.
`48. Facebook has performed all conditions, covenants, and promises required
`of it in accordance with its agreements with Zaghar.
`49. Zaghar’s breaches have caused Facebook to incur damages in an amount
`to be determined at trial, and in excess of $75,000.
`SECOND CAUSE OF ACTION
`(Computer Fraud and Abuse Act, 18 U.S.C. § 1030)
`50. Facebook realleges and incorporates all preceding paragraphs here.
`51. Since at least October 2018, Zaghar accessed Facebook protected
`computers, namely, restricted endpoints, without authorization in order to scrape data
`from Facebook.
`52. Facebook computers are “protected computers” as defined by 18 U.S.C.
`§ 1030(e)(2)(B) because they are “used in or affecting interstate commerce or
`communication.”
`53. Zaghar violated 18 U.S.C. § 1030(a)(2) because he intentionally accessed
`and caused to be accessed a Facebook protected computer without authorization and
`obtained information. More specifically, Zaghar’s scraping service emulated
`Facebook’s official Facebook Android app and misused Facebook login credentials in
`order to fraudulently login to Facebook and scrape data, including certain users’ email
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`address, mobile phone number, and date of birth, that was not publicly viewable
`beyond their group of Facebook Friends.
`54. Zaghar violated 18 U.S.C. § 1030(a)(4) because he knowingly and with
`intent to defraud, accessed Facebook protected computers, by sending unauthorized
`commands and requests, and by means of such conduct furthered the intended fraud
`and obtained something of value. Zaghar’s intended fraud included sending
`unauthorized commands and requests to Facebook that falsely represented themselves
`as Facebook’s official Android app for the purpose of scraping and obtaining access
`to and data from Facebook, the value of which exceeded $5,000.
`55. Zaghar caused a loss to Facebook in an amount in excess of $5,000 during
`a one-year period.
`56. Zaghar’s actions caused plaintiff to incur a loss as defined by 18 U.S.C.
`§ 1030(e)(11), including the expenditure of resources to investigate and remediate
`Zaghar’s fraud and unauthorized access. Plaintiff is entitled to compensation for
`losses and any other amount to be proven at trial.
`THIRD CAUSE OF ACTION
`(California Penal Code § 502)
`57. Facebook realleges and incorporates all preceding paragraphs here.
`58. Zaghar knowingly accessed and without permission used Facebook’s
`computers, computer system, or computer network in order to wrongfully obtain data
`in violation of California Penal Code § 502(c)(1)(B).
`59. Zaghar knowingly and without permission used or caused to be used
`Facebook’s computer services, as defined by § 502(b)(4), in violation of California
`Penal Code § 502(c)(3).
`60. Zaghar knowingly and without permission accessed and caused to be
`accessed Facebook’s computers, computer systems, or computer networks after
`Facebook disabled his accounts in violation of California Penal Code § 502(c)(7).
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`61. Facebook suffered and continues to suffer damages and a loss as a result
`of Zaghar’s actions. Facebook, therefore, is entitled to compensatory damages, in an
`amount to be proven at trial, as well as injunctive relief and attorney’s fees under
`California Penal Code § 502(e)(1) and (2).
`62. Because Zaghar willfully violated California Penal Code § 502 and given
`the clear and convincing evidence that Zaghar committed “fraud” as defined by 3294
`of the California Civil Code, Plaintiff is entitled to punitive damages under California
`Penal Code § 502(e)(4).
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`PRAYER FOR RELIEF
`Facebook seeks judgment awarding the following relief:
`(a) An injunction restraining Zaghar from accessing Facebook;
`(b) An injunction requiring Zaghar to identify the location of any and all data
`obtained from Facebook, delete any and all data obtained from Facebook, including
`users’ Facebook credentials, and to identify any and all entities with whom Zaghar
`shared data obtained from Facebook;
`(c) Compensatory and punitive damages in an amount to be determined at
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`trial;
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`(d) Attorney’s fees, costs, and expenses, including but not limited to those
`incurred in connection with the investigation and remediation of Zaghar’s misconduct;
`(e) Pre-judgment and post-judgment interest; and
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 13 of 28
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`
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`(f) All other equitable or legal relief the Court deems just and proper.
`
`Dated: June 18, 2020
`
`
`
`
`
`
`HUNTON ANDREWS KURTH LLP
`
`
`
`By: /s/ Ann Marie Mortimer
`Ann Marie Mortimer
`Jason J. Kim
`Jeff R. R. Nelson
`Attorneys for Plaintiff
`FACEBOOK, INC.
`Platform Enforcement and
`Litigation
`Facebook, Inc.
`Jessica Romero
`Michael Chmelar
`Stacy Chen
`
`
`
`
`
`12
`COMPLAINT; DEMAND FOR JURY TRIAL
`Case No. 3:20-cv-04054
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`

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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 14 of 28
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`
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`DEMAND FOR JURY TRIAL
`Plaintiff hereby demands a trial by jury on all issues triable to a jury.
`
`Dated: June 18, 2020
`
`
`
`
`
`
`HUNTON ANDREWS KURTH LLP
`
`
`
`By: /s/ Ann Marie Mortimer
`Ann Marie Mortimer
`Jason J. Kim
`Jeff R. R. Nelson
`Attorneys for Plaintiff
`FACEBOOK, INC.
`Platform Enforcement and
`Litigation
`Facebook, Inc.
`Jessica Romero
`Michael Chmelar
`Stacy Chen
`
`
`
`073923.0000052 EMF_US 80628387
`
`13
`COMPLAINT; DEMAND FOR JURY TRIAL
`Case No. 3:20-cv-04054
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`Los Angeles, California 90071-2627
`550 South Hope Street, Suite 2000
`Hunton Andrews Kurth LLP
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`

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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 15 of 28
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 15 of 28
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`EXHIBIT 1
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`EXHIBIT 1
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`

`

`2019-12-12 - Screenshot from domaintools.com
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 16 of 28
`
`< Older
`
`2016-08-21 - (3 years ago)
`
`Domain Name: FAST - LIKERS.COM
`Registry Domain ID : 1871438950 DOMAIN COM- VRSN
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`Update Date: 2015 - 08 - 27T08 : 44 : 05Z
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`Registry Registrant ID: Not Available From Registry
`Registrant Name: Mr Zaghar
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`
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 17 of 28
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 17 of 28
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`EXHIBIT 2
`
`EXHIBIT 2
`
`

`

`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 18 of 28
`2019-12-12 - Screenshot from fast-likers.com as of 2016-07-30 via archive.org
`,_lh_n ,_p:-"//'-fa_s_t-_li_ke_r_s._co_m__,/_h_om_e __________________________ __,I I Go I JUN
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 19 of 28
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 19 of 28
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`EXHIBIT 3
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`EXHIBIT 3
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`

`

`H Amazing services for your w o
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 21 of 28
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 21 of 28
`
`EXHIBIT 4
`
`EXHIBIT 4
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`

`

`Ill About Us - Fast-Autolikers
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 22 of 28
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`2019-06-12 - Screenshot from fast-autolikers.com as of 2016-04-20 via archive.org
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`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 23 of 28
`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 23 of 28
`
`EXHIBIT 5
`
`EXHIBIT 5
`
`

`

`Case 3:20-cv-04054-LB Document 1 Filed 06/18/20 Page 24 of 28
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