United States et al v. Google LLC Document 284: Response, Attachment 12

Virginia Eastern District Court
Case No. 1:23-cv-00108-LMB-JFA
Filed July 17, 2023

Response to [280] Order,, filed by Google LLC. (Attachments: # (1) Exhibit 1 MTC Appendix, # (2) Exhibit 2 MTC Brief, # (3) Exhibit 3 MTC EX 1, # (4) Exhibit 4 MTC EX 2, # (5) Exhibit 5 MTC EX 3, # (6) Exhibit 6 MTC EX 4, # (7) Exhibit 7 MTC EX 6, # (8) Exhibit 8 MTC EX 7, # (9) Exhibit 9 MTC EX 8, # (10) Exhibit 10 MTC EX 9, # (11) Exhibit 11 MTC EX 10, # (12) Exhibit 12 MTC EX 11, # (13) Exhibit 13 MTC EX 12, # (14) Exhibit 14 MTC EX 13, # (15) Exhibit 15 MTC EX 14, # (16) Exhibit 16 MTC EX 15, # (17) Exhibit 17 MTC EX 16, # (18) Exhibit 18 MTC EX 17, # (19) Exhibit 19 MTC EX 18, # (20) Exhibit 20 MTC EX 19, # (21) Exhibit 21 MTC EX 21, # (22) Exhibit 22 MTC EX 22, # (23) Exhibit 23 MTC EX 25, # (24) Exhibit 24 MTC EX 27, # (25) Exhibit 25 MTC EX 28, # (26) Exhibit 26 MTC EX 29, # (27) Exhibit 27 MTC EX 30, # (28) Exhibit 28 MTC EX 31, # (29) Exhibit 29 MTC Reply Appendix, # (30) Exhibit 30 Opposition EX A, # (31) Exhibit 31 Opposition EX B, # (32) Exhibit 32 Opposition EX C, # (33) Exhibit 33 Reply EX 1, # (34) Exhibit 34 Reply EX 2, # (35) Exhibit 35 Reply EX 5, # (36) Exhibit 36 Reply EX 6, # (37) Exhibit 37 Reply)(Reilly, Craig)

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Page 1 PageID#
EXHIBIT 1

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Confidential Treatment Requested
By Email
John Hogan
Antitrust Division
U.S. Department of Justice
450 5th St. NW
Washington, DC
August 19, Re:
Civil Investigative Demand No.
Dear John:
On behalf of Alphabet, Inc. (“Company”), I write regarding certain documents produced in
response to the Civil Investigative Demand for Documents and Information (“CID”) issued on October
20, 2020. Despite extensive and reasonable steps taken to prevent disclosure of privileged information,
the Company inadvertently disclosed documents relating to the projects listed below, which are protected
by attorney-client privilege, the work product protection and/or another cognizable privilege or immunity.
The inadvertent production of these documents does not constitute a waiver of any privilege or protection
applicable to the documents or subject matter contained therein.
We will be sending you, on a rolling basis beginning August 20 until September 3, letters
identifying the inadvertently disclosed documents by beginning Bates number. We request that the
Antitrust Division (“Division”) destroy or sequester all of the documents listed in those letters, and that it
refrain from using information gleaned from those privileged documents in its investigation in any way.
In addition, we request that if the Division in the meantime encounters any documents containing
references to or relating to the following projects, the Division destroy or sequester them and notify
Freshfields.
●
Project Sunday

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fi
Con dential Treatment Requested
2⎪
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●
●
●
●
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Project Monday
Project Stonehenge
Project SingleClick
Project Quantize
Project Banksy
Project Metta
Project Garamond
*
*
*
The Company requests confidential treatment of these materials to the fullest extent allowed by
law, including the Antitrust Civil Process Act, 15 U.S.C. § 1311 et seq., Exemption 4 of the Freedom of
Information Act, as well as all other applicable statutes, regulations, and customary confidentiality
policies. The Company specifically requests advance notice before disclosure of any of these materials to
any person and return or destruction of materials when the Department’s investigation is completed.
Please do not hesitate to contact me with any questions.
Sincerely yours,
/s/ Julie Elmer

PDF Page 1	PlainSite Cover Page

PDF Page 2	Case 1:23-cv-00108-LMB-JFA Document 284-12 Filed 07/17/23 Page 1 of 3 PageID# 2868 EXHIBIT 11

PDF Page 3	Case 1:23-cv-00108-LMB-JFA Document 284-12 Filed 07/17/23 Page 2 of 3 PageID# 2869 Confidential Treatment Requested By Email John Hogan Antitrust Division U.S. Department of Justice 450 5th St. NW Washington, DC 20530 August 19, 2021 Re: Civil Investigative Demand No. 30471 Dear John: On behalf of Alphabet, Inc. (“Company”), I write regarding certain documents produced in response to the Civil Investigative Demand for Documents and Information (“CID”) issued on October 20, 2020. Despite extensive and reasonable steps taken to prevent disclosure of privileged information, the Company inadvertently disclosed documents relating to the projects listed below, which are protected by attorney-client privilege, the work product protection and/or another cognizable privilege or immunity. The inadvertent production of these documents does not constitute a waiver of any privilege or protection applicable to the documents or subject matter contained therein. We will be sending you, on a rolling basis beginning August 20 until September 3, letters identifying the inadvertently disclosed documents by beginning Bates number. We request that the Antitrust Division (“Division”) destroy or sequester all of the documents listed in those letters, and that it refrain from using information gleaned from those privileged documents in its investigation in any way. In addition, we request that if the Division in the meantime encounters any documents containing references to or relating to the following projects, the Division destroy or sequester them and notify Freshfields. ● Project Sunday

PDF Page 4	Case 1:23-cv-00108-LMB-JFA Document 284-12 Filed 07/17/23 Page 3 of 3 PageID# 2870 fi Con dential Treatment Requested 2⎪2 ● ● ● ● ● ● ● Project Monday Project Stonehenge Project SingleClick Project Quantize Project Banksy Project Metta Project Garamond * * * The Company requests confidential treatment of these materials to the fullest extent allowed by law, including the Antitrust Civil Process Act, 15 U.S.C. § 1311 et seq., Exemption 4 of the Freedom of Information Act, as well as all other applicable statutes, regulations, and customary confidentiality policies. The Company specifically requests advance notice before disclosure of any of these materials to any person and return or destruction of materials when the Department’s investigation is completed. Please do not hesitate to contact me with any questions. Sincerely yours, /s/ Julie Elmer


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