Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 1 of 79
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`WILMER CUTLER PICKERING
` HALE AND DORR LLP
`SONAL N. MEHTA (SBN 222086)
` Sonal.Mehta@wilmerhale.com
`2600 El Camino Real, Suite 400
`Palo Alto, California 94306
`Telephone: (650) 858-6000
`DAVID Z. GRINGER (pro hac vice)
` David.Gringer@wilmerhale.com
`7 World Trade Center
`250 Greenwich Street
`New York, New York 10007
`Telephone: (212) 230-8800
`ARI HOLTZBLATT (pro hac vice)
` Ari.Holtzblatt@wilmerhale.com
`MOLLY M. JENNINGS (pro hac vice)
` Molly.Jennings@wilmerhale.com
`1875 Pennsylvania Ave NW
`Washington, DC 20006
`Telephone: (202) 663-6000
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`Attorneys for Defendant Meta Platforms, Inc.
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`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
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`
`MAXIMILIAN KLEIN, et al., on behalf of
`themselves and all others similarly situated,
`Plaintiffs,
`
`v.
`META PLATFORMS, INC., a Delaware
`Corporation headquartered in California,
`Defendant.
`
` Case No. 3:20-cv-08570-JD
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`DEFENDANT META PLATFORMS,
`INC.’S ANSWER TO THE FIRST
`AMENDED CONSOLIDATED
`ADVERTISER CLASS ACTION
`COMPLAINT
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`Judge: Hon. James Donato
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`No. 3:20-cv-08570-JD
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`ANSWER TO FIRST AMENDED CONSOLIDATED
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 2 of 79
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`Defendant Meta Platforms, Inc. (“Meta”) answers Plaintiffs’ First Amended Consolidated
`Advertiser Class Action Complaint as follows:
`Except as otherwise expressly stated below, Meta denies each and every allegation
`contained in the Complaint. Meta states that the headings, sub-headings, and footnotes throughout
`the Complaint do not constitute well-pled allegations of fact and therefore require no response. To
`the extent a response is required, Meta denies the allegations in the headings, sub-headings, and
`footnotes in the Complaint, except as otherwise stated. Meta reserves the right to seek to amend
`and/or supplement its Answer as may be necessary.
`ANSWERS TO SPECIFIC ALLEGATIONS
`Meta admits that Jessyca Frederick, Mark Young, 406 Property Services, PLLC,
`1.
`Mark Berney, and Katherine Looper purchased advertising from Meta. Meta lacks knowledge or
`information sufficient to form a belief about whether advertising purchases by Jessyca Frederick
`were made on behalf of Affilious, Inc. Meta avers that Plaintiff Joshua Jeon voluntarily dismissed
`his claims on August 29, 2022. Meta otherwise denies the allegations in Paragraph 1.
`Meta denies the allegations in Paragraph 2.
`2.
`3.
`Meta denies the allegations in Paragraph 3.
`4.
`Meta denies the allegations in Paragraph 4.
`5.
`Meta denies the allegations in Paragraph 5.
`6.
`Meta denies the allegations in Paragraph 6.
`7.
`Meta denies the allegations in Paragraph 7.
`8.
`Meta denies the allegations in Paragraph 8.
`9.
`Meta denies the allegations in Paragraph 9.
`10. Meta denies the allegations in Paragraph 10.
`11. Meta denies the allegations in Paragraph 11.
`12. Meta denies the allegations in Paragraph 12.
`13. Meta denies the allegations in Paragraph 13.
`14. Meta denies the allegations in Paragraph 14.
`15. Meta denies the allegations in Paragraph 15.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 3 of 79
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`16. Meta denies the allegations in Paragraph 16.
`To the extent Paragraph 17 refers to an agreement between Meta and Google, Meta
`17.
`respectfully refers the Court to that agreement, which speaks for itself, for a complete and accurate
`statement of its contents. Meta otherwise denies the allegations in Paragraph 17.
`18. Meta denies the allegations in Paragraph 18.
`19. Meta denies the allegations in Paragraph 19.
`20. Meta denies the allegations in Paragraph 20.
`21. Meta denies the allegations in Paragraph 21.
`22. Meta denies the allegations in Paragraph 22.
`23. Meta denies the allegations in Paragraph 23.
`24. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 24, including whether Jessyca Frederick’s advertising purchases were
`made on behalf of Affilious, Inc., and on that basis denies the allegations.
`25. Meta admits that Jessyca Frederick purchased advertisements at various times on
`Facebook between April 4, 2009 and August 2017. Meta lacks knowledge or information
`sufficient to form a belief about the truth of the remaining allegations in Paragraph 25, and on that
`basis denies the allegations.
`26. Meta admits that Mark Young purchased advertisements at various times on
`Facebook between June 2017 and April 2019. Meta lacks knowledge or information sufficient to
`form a belief about the truth of the remaining allegations in Paragraph 26, and on that basis denies
`the allegations.
`27. Meta avers that Plaintiff Joshua Jeon voluntarily dismissed his claims on August
`29, 2022, and therefore, no response is required.
`28. Meta admits that 406 Property Services, PLLC purchased advertisements at various
`times on Facebook between June 8, 2017 and October 20, 2017. Meta lacks knowledge or
`information sufficient to form a belief about the truth of the remaining allegations in Paragraph
`28, and on that basis denies the allegations.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 4 of 79
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`29. Meta admits that Mark Berney purchased advertisements at various times on
`Facebook between 2016 and December 2018. Meta lacks knowledge or information sufficient to
`form a belief about the truth of the remaining allegations in Paragraph 29, and on that basis denies
`the allegations.
`30. Meta admits that Katherine Looper purchased advertisements at various times on
`Facebook between 2013 and March 2020. Meta denies that Reality House West is “Looper’s
`nonprofit organization.” Meta lacks knowledge or information sufficient to form a belief about
`the truth of the remaining allegations in Paragraph 30, and on that basis denies the allegations.
`31. Meta denies the allegations in Paragraph 31.
`32. Meta admits the allegations in Paragraph 32.
`33. Meta admits that it was founded by Mark Zuckerberg in 2004. Meta further admits
`that it offers a suite of products to billions of users around the world. Meta further admits that it
`earns revenues from delivering ads to users. Meta otherwise denies the allegations in Paragraph
`33.
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`To the extent Paragraph 34 refers to Meta’s public securities filings, Meta
`34.
`respectfully refers the Court to those filings, which speak for themselves, for a complete and
`accurate statement of their contents. Meta admits that its services include the Facebook
`application, Instagram, Messenger, and WhatsApp. Meta further admits that the Facebook
`application is a web-based and mobile service that, among other things, allows people to connect,
`share, discover, and communicate. Meta further admits that the Facebook application has several
`features that facilitate these connections, including News Feed. Meta further admits that Instagram
`is a mobile and web-based application that allows users to share photos, videos, and messages and
`that Meta acquired Instagram in 2012. Meta further admits that Messenger is a messaging
`application available on desktops and a variety of mobile platforms that allows users to share
`content and experiences by sending messages, photos, and videos. Meta further admits that
`WhatsApp is a messaging application used by individuals and businesses. Meta further admits
`that it acquired WhatsApp in 2014. Meta admits that Oculus is a hardware, software, and
`developer ecosystem that allows people around the world to come together through Meta’s Oculus
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 5 of 79
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`augmented reality and virtual reality. Meta further admits that it acquired Oculus in 2014. Meta
`otherwise denies the allegations in Paragraph 34.
`35. Meta admits that its revenue as of year-end 2019 was $70.70 billion, up 27% from
`the previous year, with net income from operations of $23.99 billion. Meta further admits that it
`maintained $54.86 billion in cash and cash-equivalent securities as of year-end 2019. Meta further
`admits that it employed 44,942 people around the world at the end of 2019, up 26% from the
`previous year. Meta further admits that its revenue as of year-end 2020 was $85.97 billion, a 22%
`increase from the previous year, with net income from operations of $32.67 billion. Meta further
`admits that it maintained $61.95 billion in cash and cash-equivalent securities as of year-end 2020.
`Meta further admits that it employed 58,604 people at the end of 2020, up 30% from the previous
`year. Meta further admits that it earned $117.93 billion in revenue in 2021. Meta further admits
`that it earned $114.93 billion in revenue from advertising in 2021. Meta further admits that it
`earned $46.753 billion in income from operations in 2021. Meta further admits that it earned
`$56.95 billion in income from operations of its Family of Apps in 2021. Meta further admits that
`its net income from operations was $39.37 billion in 2021. Meta otherwise denies the allegations
`in Paragraph 35.
`36. Meta admits that it reported to investors that on average it had 1.66 billion daily
`active users of Facebook for the 2019 fiscal year, up 9% from the previous year, and 2.50 billion
`monthly active users, up 8% from the previous year. Meta further admits that it had 2.26 billion
`daily active people who used one or more of Facebook, Instagram, Messenger, and/or WhatsApp,
`up 11% from the previous year, and 2.89 billion monthly active people, up 9% from the previous
`year. Meta further admits that it reported to investors that on average it had 1.84 billion daily
`active users of Facebook for the 2020 fiscal year, up 11% from the previous year, and 2.80 billion
`monthly active users, up 12% from the previous year. Meta further admits that it reported to
`investors that on average it had 2.60 billion daily active people who used one or more of Facebook,
`Instagram, Messenger, and/or WhatsApp, up 15% from the previous year. Meta otherwise denies
`the allegations in Paragraph 36.
`Paragraph 37 includes legal conclusions to which no answer is necessary.
`37.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 6 of 79
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`Paragraph 38 includes legal conclusions to which no answer is necessary.
`38.
`Paragraph 39 includes legal conclusions to which no answer is necessary. To the
`39.
`extent a response is required, for purposes of the current action, Meta does not contest that venue
`in this district is proper.
`Paragraph 40 includes legal conclusions to which no answer is necessary. To the
`40.
`extent a response is required, for purposes of the current action, Meta does not contest that this
`Court has personal jurisdiction over Meta and that Meta transacts business in this district.
`41. Meta admits the allegations in Paragraph 41.
`42. Meta admits that it was founded by Mark Zuckerberg in 2004, that it rose to
`prominence in the face of fierce competition, and that today, it is used by people in the United
`States and worldwide. Meta otherwise denies the allegations in Paragraph 42.
`43. Meta admits that it was more successful than some of its rivals between 2004 and
`2010. Meta otherwise denies the allegations in Paragraph 43.
`44. Meta admits that Myspace was a competitor of Facebook. Meta lacks knowledge
`or information sufficient to form a belief about the truth of the remaining allegations in Paragraph
`44, and on that basis denies the allegations.
`To the extent Paragraph 45 refers to a public report, Meta respectfully refers the
`45.
`Court to that report, which speaks for itself, for a complete and accurate statement of its contents.
`Meta lacks knowledge or information sufficient to form a belief about the truth of the remaining
`allegations in Paragraph 45, and on that basis denies the allegations.
`46. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 46, and on that basis denies the allegations.
`47. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 47, and on that basis denies the allegations.
`To the extent Paragraph 48 refers to reporting by Adweek, Meta respectfully refers
`48.
`the Court to that reporting, which speaks for itself, for a complete and accurate statement of its
`contents. Meta otherwise denies the allegations in Paragraph 48.
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`49. Meta admits that Time magazine named Mr. Zuckerberg as its 2010 Person of the
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`To the extent Paragraph 50 refers to a Time magazine article, Meta respectfully
`50.
`refers the Court to that magazine article, which speaks for itself, for a complete and accurate
`statement of its contents. Meta otherwise denies the allegations in Paragraph 50.
`51. Meta denies the allegations in Paragraph 51.
`52. Meta denies the allegations in Paragraph 52.
`53. Meta admits that it delivers ads to certain users. Meta otherwise denies the
`allegations in Paragraph 53.
`54. Meta denies the allegations in Paragraph 54.
`55. Meta denies the allegations in Paragraph 55.
`56. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in the second sentence of Paragraph 56, and on that basis denies the allegations.
`Meta otherwise denies the allegations in Paragraph 56.
`57. Meta denies the allegations in Paragraph 57.
`58. Meta admits that it delivers ads to certain users. To the extent Paragraph 58 refers
`to public statements from Meta, Meta respectfully refers the Court to those statements, which
`speak for themselves, for a complete and accurate statement of their contents. Meta otherwise
`denies the allegations in Paragraph 58.
`59. Meta denies the allegations in Paragraph 59.
`60. Meta denies the allegations in Paragraph 60.
`To the extent Paragraph 61 refers to an internal Meta communication, Meta
`61.
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 61.
`62. Meta denies the allegations in Paragraph 62.
`63. Meta denies the allegations in Paragraph 63.
`64. Meta denies the allegations in Paragraph 64.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 8 of 79
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`To the extent Paragraph 65 refers to a public report, Meta respectfully refers the
`65.
`Court to that report, which speaks for itself, for a complete and accurate statement of its contents.
`Meta otherwise denies the allegations in Paragraph 65.
`To the extent Paragraph 66 refers to a public report, Meta respectfully refers the
`66.
`Court to that report, which speaks for itself, for a complete and accurate statement of its contents.
`Meta otherwise denies the allegations in Paragraph 66.
`67. Meta denies the allegations in Paragraph 67.
`68. Meta denies the allegations in Paragraph 68.
`69. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 69, and on that basis denies the allegations.
`70. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 70, and on that basis denies the allegations.
`71. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 71, and on that basis denies the allegations.
`72. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 72, and on that basis denies the allegations.
`73. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 73, and on that basis denies the allegations.
`74. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 74, and on that basis denies the allegations.
`75. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 75, and on that basis denies the allegations.
`76. Meta admits that Google released Google+ in 2011. Meta lacks knowledge or
`information sufficient to form a belief about the truth of the remaining allegations in Paragraph
`76, and on that basis denies the allegations.
`77. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 77, and on that basis denies the allegations.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 9 of 79
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`78. Meta denies that a “DTBE” protects Facebook. Meta lacks knowledge or
`information sufficient to form a belief about the truth of the remaining allegations in Paragraph
`78, and on that basis denies the allegations.
`79. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 79, and on that basis denies the allegations.
`80. Meta denies the allegations in the last sentence of Paragraph 80. Meta lacks
`knowledge or information sufficient to form a belief about the truth of the remaining allegations
`in Paragraph 80, and on that basis denies the allegations.
`81. Meta denies the allegations in Paragraph 81.
`82. Meta admits that Apple launched Apple iPhone in 2007. Meta otherwise denies the
`allegations in Paragraph 82.
`83. Meta admits that Apple released the Apple iPhone 3G in 2008. Meta lacks
`knowledge or information sufficient to form a belief about the truth of the remaining allegations
`in Paragraph 83, and on that basis denies the allegations.
`84. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 84, and on that basis denies the allegations.
`To the extent Paragraph 85 refers to a Pew Research survey, Meta respectfully
`85.
`refers the Court to that Pew Research survey, which speaks for itself, for a complete and accurate
`statement of its contents. Meta lacks knowledge or information sufficient to form a belief about
`the truth of the remaining allegations in Paragraph 85, and on that basis denies the allegations.
`To the extent Paragraph 86 refers to a Nielsen survey, Meta respectfully refers the
`86.
`Court to that Nielsen survey, which speaks for itself, for a complete and accurate statement of its
`contents. Meta lacks knowledge or information sufficient to form a belief about the truth of the
`remaining allegations in Paragraph 86, and on that basis denies the allegations.
`To the extent Paragraph 87 refers to a Nielsen survey, Meta respectfully refers the
`87.
`Court to that Nielsen survey, which speaks for itself, for a complete and accurate statement of its
`contents. Meta lacks knowledge or information sufficient to form a belief about the truth of the
`remaining allegations in Paragraph 87, and on that basis denies the allegations.
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`88. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in Paragraph 88, and on that basis denies the allegations.
`To the extent Paragraph 89 refers to an article in Wired, Meta respectfully refers
`89.
`the Court to that Wired article, which speaks for itself, for a complete and accurate statement of its
`contents. Meta otherwise denies the allegations in Paragraph 89.
`To the extent Paragraph 90 refers to a Morgan Stanley analysis, Meta respectfully
`90.
`refers the Court to that Morgan Stanley analysis, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 90.
`91. Meta admits that the Facebook mobile app is free to download. To the extent
`Paragraph 91 refers to a public report, Meta respectfully refers the Court to that report, which
`speaks for itself, for a complete and accurate statement of its contents. Meta lacks knowledge or
`information sufficient to form a belief about the truth of the remaining allegations in Paragraph
`91, and on that basis denies the allegations
`92. Meta admits that it introduced its “Timeline” in 2011. Meta otherwise denies the
`allegations in Paragraph 92.
`93. Meta admits that its mobile application was initially built on HTML5 technology.
`To the extent Paragraph 93 refers to public statements, Meta respectfully refers the Court to those
`public statements, which speak for themselves, for a complete and accurate statement of their
`contents. Meta otherwise denies the allegations in Paragraph 93.
`To the extent Paragraph 94 refers to public statements, Meta respectfully refers the
`94.
`Court to those public statements, which speak for themselves, for a complete and accurate
`statement of their contents. Meta otherwise denies the allegations in Paragraph 94.
`95. Meta denies the allegations in Paragraph 95.
`96. Meta admits that it held its initial public offering on May 18, 2012. To the extent
`Paragraph 96 refers to public securities filings, Meta respectfully refers the Court to those public
`securities filings, which speak for themselves, for a complete and accurate statement of their
`contents. Meta otherwise denies the allegations in Paragraph 96.
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`97. Meta admits that it competes with other mobile applications. Meta otherwise denies
`the allegations in Paragraph 97.
`98. Meta admits that its “Open Graph” provided a set of tools to developers. Meta
`otherwise denies the allegations in Paragraph 98.
`To the extent Paragraph 99 refers to public securities filings, Meta respectfully
`99.
`refers the Court to those public securities filings, which speak for themselves, for a complete and
`accurate statement of their contents. Meta otherwise denies the allegations in Paragraph 99.
`100. Meta denies the allegations in Paragraph 100.
`101. To the extent Paragraph 101 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 101.
`102. Meta denies the allegations in Paragraph 102.
`103. To the extent Paragraph 103 refers to a public report, Meta respectfully refers the
`Court to that public report, which speaks for itself, for a complete and accurate statement of its
`contents. Meta otherwise denies the allegations in Paragraph 103.
`104. Meta admits that it competes with certain application developers. Meta otherwise
`denies the allegations in Paragraph 104.
`105. To the extent Paragraph 105 refers to public statements, Meta respectfully refers
`the Court to those public statements, which speak for themselves, for a complete and accurate
`statement of their contents. Meta otherwise denies the allegations in Paragraph 105.
`106. Meta denies the allegations in Paragraph 106.
`107. Meta admits that Platform made it possible for software developers to build apps
`and tools that interoperate with the Facebook application. Meta otherwise denies the allegations
`in Paragraph 107.
`108. Meta denies the allegations in Paragraph 108.
`109. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in the first clause of Paragraph 109, and on that basis denies the allegations. Meta
`otherwise denies the allegations in Paragraph 109.
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 12 of 79
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`110. Meta admits that developers could request access to certain user content from
`Facebook. Meta otherwise denies the allegations in Paragraph 110.
`111. Meta denies the allegations in Paragraph 111.
`112. Meta denies the allegations in Paragraph 112.
`113. To the extent Paragraph 113 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 113.
`114. Meta denies the allegations in Paragraph 114.
`115. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in the first sentence of Paragraph 115, and on that basis denies the allegations. Meta
`otherwise the allegations in Paragraph 115.
`116. To the extent Paragraph 116 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 116.
`117. Meta denies the allegations in Paragraph 117.
`118. Meta denies the allegations in Paragraph 118.
`119. Meta denies the allegations in Paragraph 119.
`120. Meta denies the allegations in Paragraph 120.
`121. Meta lacks knowledge or information sufficient to form a belief about the truth of
`the allegations in the first sentence of Paragraph 121, and on that basis denies the allegations. Meta
`otherwise denies the allegations in Paragraph 121.
`122. Meta denies the allegations in Paragraph 122.
`123. To the extent Paragraph 123 refers to public statements, Meta respectfully refers
`the Court to those public statements, which speak for themselves, for a complete and accurate
`statement of their contents. Meta otherwise denies the allegations in Paragraph 123.
`124. Meta denies the allegations in Paragraph 124.
`125. Meta denies the allegations in Paragraph 125.
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`ANSWER TO FIRST AMENDED CONSOLIDATED
`ADVERTISER CLASS ACTION COMPLAINT
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 13 of 79
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`126. Meta admits that, as of April 30, 2015, certain APIs previously available through
`Platform were no longer available. Meta otherwise denies the allegations in Paragraph 126.
`127. Meta denies the allegations in Paragraph 127.
`128. Meta denies the allegations in Paragraph 128.
`129. To the extent Paragraph 129 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 129.
`130. Meta denies the allegations in Paragraph 130.
`131. Meta denies the allegations in Paragraph 131.
`132. Meta denies the allegations in Paragraph 132.
`133. Meta admits that it restricted or terminated Platform access for certain apps that
`violate Facebook’s policies. Meta further admits that its competitors include Twitter, Pinterest,
`Google, and Foursquare. Meta otherwise denies the allegations in Paragraph 133.
`134. To the extent Paragraph 134 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 134.
`135. To the extent Paragraph 135 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 135.
`136. Meta denies the allegations in Paragraph 136.
`137. To the extent Paragraph 138 refers to an internal Meta presentation, Meta
`respectfully refers the Court to that presentation, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 137.
`138. Meta denies the allegations in Paragraph 138.
`139. Meta denies the allegations in Paragraph 139.
`140. To the extent Paragraph 140 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 140.
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`No. 3:20-cv-08570-JD
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`ADVERTISER CLASS ACTION COMPLAINT
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`Case 3:20-cv-08570-JD Document 408 Filed 01/10/23 Page 14 of 79
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`141. Meta denies the allegations in Paragraph 141.
`142. To the extent Paragraph 142 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 142.
`143. Meta denies the allegations in Paragraph 143.
`144. To the extent Paragraph 144 refers to a statement by Meta, Meta respectfully refers
`the Court to that statement, which speaks for itself, for a complete and accurate statement of its
`contents. Meta otherwise denies the allegations in Paragraph 144.
`145. Meta admits that it launched “Platform 3.0.” Meta otherwise denies the allegations
`in Paragraph 145.
`146. To the extent Paragraph 146 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 146.
`147. To the extent Paragraph 147 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 147.
`148. Meta denies the allegations in Paragraph 148.
`149. Meta denies the allegations in Paragraph 149.
`150. Meta denies the allegations in Paragraph 150.
`151. Meta denies the allegations in Paragraph 151.
`152. Meta denies the allegations in Paragraph 152.
`153. Meta denies the allegations in Paragraph 153.
`154. To the extent Paragraph 154 refers to an internal Meta communication, Meta
`respectfully refers the Court to that communication, which speaks for itself, for a complete and
`accurate statement of its contents. Meta otherwise denies the allegations in Paragraph 154.
`155. Meta denies the allegations in Paragraph 155.
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`No. 3:20-cv-08570-JD
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`13
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`ANSWER TO FIRST AMENDED CONSOLIDATED
`ADVERTISER CLASS ACTION COMPLAINT
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