Case 1:20-mc-00036-JEB-DAR Document 8 Filed 08/04/20 Page 8 of 18 matter of the requested documents or communications, nor are they limited by any particular geography. Id. The requests seek this information on an unspecified number of Facebook and Instagram accounts, either without any time limit, or for a period that extends several years prior to the events that are the subject of The Gambia’s case at the ICJ. See ICJ Order at 7 (“Specifically, The Gambia asserts that in October 2016 the Myanmar military and other Myanmar security forces began widespread and systematic ‘clearance operations’ against the Rohingya group[.]”). The requests also do not identify any accounts with sufficient specificity for Facebook to determine which accounts are within the scope of the request. The application further requests Facebook’s internal policy and procedure documents, including all documents related to “any internal investigations conducted by Facebook” regarding coordinated inauthentic behavior or any “other terms of service violations, from 2012 to the present” by “accounts belonging to or controlled by Myanmar state officials, representatives, entities or groups acting in coordination, or suspected of acting in coordination, with Myanmar state entities.” Appl. at 17. In addition to these broad document requests, The Gambia also seeks to compel Facebook to put forward a Rule 30(b)(6) deponent to testify as a corporate representative on all of these wide-ranging topics related to the document requests, including investigations into potentially hundreds or thousands of Myanmar-affiliated accounts that were suspected of any terms of service violations over roughly the last decade. Id. LEGAL STANDARD An applicant seeking discovery pursuant to 28 U.S.C. § 1782 must satisfy three statutory requirements: (1) the person from whom discovery is sought must “reside[]” or be “found” in the district; (2) the discovery must be for use in a “proceeding in a foreign or international tribunal”; and (3) the applicant must be an “interested person.” 28 U.S.C. § 1782. If these requirements are met, “[t]he statute authorizes, but does not require,” the district court to compel the requested 4

Select target paragraph3