IN RE: SOCIAL MEDIA ADOLESCENT ADDICTION/PERSONAL INJURY PRODUCTS LIABILITY LITIGATION
4:22-md-03047-YGR
N.D. Cal.May 19, 2025Background
- This case is a multidistrict litigation (MDL) concerning claims by multiple states against Meta (Facebook and Instagram) for alleged consumer protection violations related to social media harm to adolescents.
- The dispute centers on Meta’s amended Rule 30(b)(6) deposition notice to states pursuing consumer protection claims, regarding the permissible scope of discovery topics.
- The court addresses various objections by the states to the breadth, relevance, and burden of Meta’s requested deposition topics.
- Both parties negotiated the scope of several topics, with the court approving certain agreements and imposing additional limitations for proportionality under Federal Rule of Civil Procedure 26(b).
- The court’s order clarifies the permissible scope for specific deposition topics, often requiring advance identification of documents or subject areas to mitigate discovery burdens.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Definition of "Social Media Platforms" in notice | Limit to Facebook and Instagram (platforms at issue) | Include all major platforms in MDL for relevance | Limit to Facebook/Instagram for non-teen-use topics; include all six MDL platforms for teen-use topics |
| Scope of Topic 2: States' "use" of social media | Overbroad; burdensome; info in Meta’s possession | Will limit to ads, promotions, and posts; advance docs | Allow only ads, promotions, posts; Meta must provide advance docs; questioning limited to docs provided |
| Breadth of studies sought in Topics 8 & 15 | Overbroad; should cover only state-funded or authored studies | Include considered or contributed-to studies; exclude none | Limit to studies created, funded, or authored by State; allow Meta to pre-identify additional docs for depositions |
| State provision of mental health services/devices (Topics 7, 18) | Overbroad; cover only directly provided/funded by State | Include indirect provision via contractors; advance docs | Limit to wholly State-directed/funded programs; allow Meta to inquire on pre-identified docs for indirect provision |
| Testimony on alternate causes of teen mental health (Topic 17) | Overbroad/unduly burdensome; improper for 30(b)(6); expert-only | Seek factual knowledge; can admit lack thereof | Limit to 21 specific factors; Meta must pre-identify supporting docs; limit testimony to doc-based knowledge |
| Discovery on state expenditures (Topic 19) | Should be limited to docs only; deposition inappropriate | Allow clarifying deposition questions; pre-identify docs | Limit to clarifying questions on documents; no memory-testing; parties to exchange and identify docs in advance |
Key Cases Cited
- U.S. Fid. & Guar. Co. v. Lee Inv. LLC, 641 F.3d 1126 (9th Cir. 2011) (district courts have broad discretion to control discovery)
- Laub v. U.S. Dep't of Interior, 342 F.3d 1080 (9th Cir. 2003) (wide latitude in discovery management)
- Crawfford-El v. Britton, 523 U.S. 574 (1998) (courts have broad discretion to tailor discovery)
- Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340 (1978) (broad scope of discovery relevance)
- Blankenship v. Hearst Corp., 519 F.2d 418 (9th Cir. 1975) (burden on party resisting discovery to show why it should not be allowed)
- Surfvivor Media, Inc. v. Survivor Prods., 406 F.3d 625 (9th Cir. 2005) (district court’s discretion in determining discovery relevance)