Page 1 PageID#
EXHIBIT 1Page 2 PageID#
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 SundayPage 3 PageID#
fi
Con dential Treatment Requested
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
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