Case 1:20-mc-00036-JEB-DAR Document 8 Filed 08/04/20 Page 15 of 18 The document requests here would sweep in potentially thousands of Myanmar-affiliated accounts, pages, and groups and their related content dating back a decade or more. For example, Request No. 13 seeks “all documents relating to any internal investigation … from 2012 to the present, committed by accounts … acting in coordination, or suspected of acting in coordination, with Myanmar state entities,” O’Toole Decl., Ex. 1, Schedule A (RFP No. 13), even though such a request may reach an untold number of accounts dating back nearly a decade, including four years prior to the events described in the application, Appl. at 3, and involve activity wholly unrelated to the atrocities at issue. Additionally, the phrase “suspected of acting” offers no meaningful way to limit the scope, as it is open-ended as to which accounts were “suspected” of having an affiliation with the Myanmar government, or how to make that determination. Moreover, the application’s request for information about Facebook’s internal policies and procedures is not relevant to the claims being pursued in the ICJ about the actions of the Myanmar government. O’Toole Decl., Ex. 1, Schedule A (RFP No. 13) (requesting “[a]ll documents relating to any internal investigations conducted by Facebook of ‘coordinated inauthentic behavior,’ or other terms of service violations, from 2012 to the present”). There is no indication whatsoever as to how such materials would be useful or useable in the ICJ proceedings, as the outcome of those proceedings will turn on factual findings made by the ICJ, not hearsay documents discussing internal findings made by Facebook. See, e.g., Rainsy, 311 F. Supp. 3d at 1111 (denying Section 1782 request for information related to “Facebook’s historical processes for preventing false or deceptive news and threatening or harassing statements” where it bore no relation to the foreign action). 11