Case 1:20-mc-00036-JEB-ZMF Document 31 Filed 12/03/21 Page 5 of 14 dispute. See Minute Entry of November 12, 2021. Given that Facebook has now committed to produce public postings — e.g., postings that anyone on Facebook can view — and associated metadata, the parties there agreed that the Court should address at this juncture only the question of whether private pages and communications — e.g., direct messages between users — may be disclosed to The Gambia pursuant to a § 1782 subpoena. II. Legal Standard A district court’s review of objections to a magistrate judge order is governed by Fed. R. Civ. P. 72. When reviewing non-dispositive orders, a court must “set aside any part of the order that is clearly erroneous or is contrary to law.” Fed. R. Civ. P. 72(a). The “clearly erroneous” standard provides for deferential review of factual findings, but the “contrary to law” standard “permits de novo review of a magistrate judge’s legal conclusions.” American Center for Civil Justice v. Ambush, 794 F. Supp. 2d 123, 129 (D.D.C. 2011) (citations omitted). Review of objections to dispositive motions, conversely, is governed by Rule 72(b), which provides that courts should conduct de novo review of any part of a magistrate judge’s order to which a party has objected. See Fed. R. Civ. P. 72(b)(3). Since the Court now confronts only objections to the Order’s legal conclusions, whether such Order is considered non-dispositive or dispositive — a question that appears to remain open in this district — is of no consequence. The Court will thus apply de novo review. III. Analysis Facebook proffers two types of objections to the Order’s determination that The Gambia may obtain the private pages and communications pursuant to a § 1782 subpoena: 1) the SCA prohibits Facebook from disclosing these communications, even if it wishes to do so, and 2) the 5