E. H., et al. v. Meta Platforms, Inc.

Summary

The United States District Court for the Northern District of California resolves portions of a discovery dispute in E. H. et al. v. Meta Platforms, Inc. The court orders Meta to search for and produce certain notices, investigate whether documents specific to non-users were excluded from an earlier production, and identify Bates numbers for lineage-mapping results, while denying or limiting several other requests. The dispute concerning additional custodians remains unresolved and may be presented in a further joint discovery letter.

Holdings

1. Plaintiffs established sufficient grounds for targeted supplemental discovery concerning the 34 providers identified as telehealth-only. Meta must search its existing Healthcare-case document collection for those providers and produce any responsive notices.
2. Plaintiffs did not establish good cause for additional searches for communications to non-users or for internal communications specifically concerning Meta's beliefs about what non-users understood about Meta's information-collection practices.
3. The dispute concerning RFP 74 was resolved by Meta's agreement to identify the Bates numbers for the portion of the Healthcare production reflecting the results of the lineage mapping project.
4. Meta must investigate whether the Healthcare production excluded documents specific to non-users on relevance grounds, but plaintiffs did not establish good cause for additional searches for email and other communications concerning non-user data only.
5. Plaintiffs did not establish good cause for the requested discovery because RFP 85 was overbroad and not appropriately targeted or necessary.
6. Plaintiffs did not establish good cause for supplemental discovery under RFP 90 because the request was unreasonably broad and insufficiently targeted.
7. The requests were overbroad to the extent they sought all documents and communications concerning the dashboard, but potentially targeted discovery concerning the dashboard's value and the value of non-user data to the dashboard warranted further party discussions.
8. The dispute concerning whether Meta must search the records of 57 custodians was not ready for decision and required further proceedings.

Questions Presented

1. Whether plaintiffs established good cause for additional targeted discovery concerning the disputed requests for production.
2. Whether Meta must search its existing Healthcare-case collection for notices sent to 34 telehealth-only providers identified by plaintiffs.
3. Whether Meta must conduct additional searches for non-public communications with non-users or internal communications concerning what non-users understood about Meta's data collection.
4. Whether the parties' agreement to identify Bates numbers, investigate possible exclusion of non-user documents, or confer concerning specific custodial sources adequately resolved or narrowed certain requests.
5. Whether the dispute concerning the proposed 57 custodians was ready for decision.

Disposition

other