Deposition of Robert Chen

Raw text

Transcribed text as recorded, including headers and formatting fragments.

Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 1 of 29 AMENDED Exhibit 21 PLAINTIFFS' OMNIBUS OPPOSITION TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT Case No.: 4:22-md-03047-YGR MDL No. 3047 In Re: Social Media Adolescent Addiction/Personal Injury Products Liability Litigation 1 Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 2 3 4 IN RE: SOCIAL MEDIA 5 ADOLESCENT ADDICTION/ PERSONAL INJURY PRODUCTS LIABILITY LITIGATION 6 ) ) ) MDL No. 3047 ) ) ) Page 2 of 29 Page 1 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES SPRING STREET COURTHOUSE 9 10 COORDINATION PROCEEDING ) SPECIAL TITLE [RULE 3.400] ) 11 ) SOCIAL MEDIA CASES ) Lead Case No. 12 ) 22STCV21355 This Document Relates To ) 13 ) STATE OF TENNESSEE, ex rel.) 14 JONATHAN SKRMETTI, ) ATTORNEY GENERAL and ) 15 REPORTER, ) V. ) 16 META PLATFORMS, INC., and ) INSTAGRAM, LLC. ) 17 ) 18 HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY 19 20 21 22 PURSUANT TO PROTECTIVE VIDEO-RECORDED DEPOSITION OF ROBERT CHEN (Pages 1 313) Covington & Burling 3000 El Camino Real, Palo Alto, California Tuesday, March 25, 2025, 9:24 a.m. ORDER 23 24 25 REPORTED BY: ELAINA BULDA-JONES, CSR 11720 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 1 2 3 For the Plaintiffs: 4 5 6 7 8 9 10 11 12 13 14 HIGHLY CONFIDENTIAL APPEARANCES BY: AUSTIN BRANE, ESQ. Wagstaff & Cartmell 4740 Grand Avenue, Suite 300 Kansas City, Missouri 816.701.1100 abrane@wcllp.com 64112 Page 3 of 29 Page 2 For the Defendants Meta Platforms, Inc., f/k/a Facebook, Inc.; Facebook Holdings, LLC; Facebook Operations, LLC; Facebook Payments, Inc.; Facebook Technologies, LLC; Instagram, LLC; Siculus, Inc.; and Mark Elliot Zuckerberg: BY: CHRISTOPHER K. EPPICH, ESQ. BY: ANNA DUNIN-UNDERWOOD, ESQ. BY: CLAUDIA FERNANDEZ, (VIA ZOOM) Covington & Burling LLP 1999 Avenue of the Stars 15 16 17 18 19 20 21 22 23 24 25 Los Angeles, California 90067-4643 424.332.4764 Ceppich@cov.com BY: JORDAN THOMAS, ESQ (VIA ZOOM) Bass, Berry & Sims PLC 100 Peabody Place, Suite 1300 Memphis, TN 37203 (901) 543-5916 For the State of Massachusetts: BY: ΚΑΙTLYN KARPENKO, ESQ. BY: PETER DOWNING, ESQ. BY: CAMY RUCK, ESQ. (VIA ZOOM) Office of the Attorney General State of Massachusetts 1 Ashburton Place, 20th Floor Boston, Massachusetts 02108 617.727.2200 kaitlyn.karpenko@mass.gov 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 4 of 29 Page 28 1 document to be? 2 3 A. It looks like my LinkedIn profile. Ω. Okay. And when you say this looks like 4 5 your LinkedIn profile, you created the LinkedIn profile, correct? 6 A. Yes. 7 Ω. Okay. And you posted this profile online 8 on linkedin.com, correct? 9 A. Yes. 10 Ω. And this is a true and accurate copy of 11 the material that you posted online, correct? 12 A. Yes. 13 Ω. Thank you. 14 Mr. Chen, does this accurately reflect 15 your educational background and current work 16 experience to date? 17 A. Yes. 18 Ω. Okay. Let's just start a little bit on 19 your educational background. 20 A. Uh-huh. 21 Ω. What is your educational background? 22 A. I got a BA in molecular and cellular 23 biology and political science at UC Berkeley. 24 Ω. Okay. And when did you obtain that 25 degree, what year? Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 5 of 29 Page 29 1 A. I graduated in 2008. 2 (Reporter clarification.) 3 BY MR. DOWNING: 4 Ω. Do you have any other educational degrees? 5 A. No other degrees. 6 Ω. Okay. 7 A. High school diploma, but I'm assuming 8 you're... 9 Ω. Yes, I was after - after graduating from 10 UC Berkeley. 11 A. Yeah. 12 Ω. Let's then look at your employment 13 history. 14 I'm going to start from your after 15 graduating college. 16 A. Okay. 17 Ω. After graduating from UC Berkeley, did you 18 take a job somewhere? 19 A. Yes. 20 Ω. Okay. Where did you begin working? 21 A. At Accenture. 22 Ω. Okay. And I see here on the second page 23 of your LinkenIn profile it says "Accenture, 24 Business Strategy Manager." 25 Is that your was that your title? Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 6 of 29 Page 30 1 A. Yes. 2 Ω. Okay. And it says September 2008 to 3 October 2015. 4 Is that the length of time that you were 5 at Accenture? 6 A. Yes. 7 Ω. Okay. And under that, this describes your 8 9 10 11 work at Accenture as including "Advised technology clients in the SF Bay Area with an emphasis on new product development, business development, and marketing." 12 Did I read that correctly? 13 A. Yes. 14 Ω. Is that an accurate description of your 15 work experience at Accenture? 16 A. I also did a little bit of work in 17 healthcare. 18 Ω. Okay. 19 A. But yeah. 20 Ω. So this is but your answer is this is 21 accurate here? 22 A. This is accurate here, yeah. 23 Ω. But then you're also saying in addition 24 you did healthcare work as well; is that correct? 25 A. That's correct. 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 7 of 29 Page 31 1 Ω. All right. Let's turn to the front page, 2 page 1 of 2. 3 A. Uh-huh. 4 Ω. Do you see at the bottom, it says 5 "Facebook Product Strategist"? 6 A. Yes. 7 Ω. Okay. It says October 2015 to 8 September 2019. 9 Do you see that? 10 A. Yes. 11 2. Okay. So this indicates that you joined 12 Facebook as a product strategist; is that right? 13 A. The role as it was then called was market 14 strategist. Later on the team changed its name. 15 Ω. Okay. And this says October '15 to 16 September '19. That's the time period that you had 17 this role as a product strategist; is that correct? 18 A. Yes. 19 Ω. Okay. All right. 20 And can you tell me what team or teams you 21 were on during the time that you were a product 22 strategist? 23 A. Yeah. So we eventually consolidated into 24 a central team. And that central team was then 25 known as market strategy and then product strategy. 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 8 of 29 HIGHLY CONFIDENTIAL Page 32 1 And I would work with a variety of product teams at 2 Meta. 3 In terms of the teams that I worked with, 4 5 6 I worked on Facebook groups. I worked on what was initially known as the teens team. And then it changed to the youth team. 7 I worked on just, like, Facebook, the app 8 more generally. 9 10 11 12 variety product. So that would include Facebook Messenger, Instagram Direct, and WhatsApp. And I also did work that connected with a various, like, messaging aspects of the 13 Ω. Okay. Who did you report to during the 14 time period that you had the title of product 15 strategist? 16 A. I had, per usual at Meta, many managers. 17 My first manager was My 18 second manager was And I think my 19 third manager was 20 Ω. Okay. 21 A. And my fourth manager was 22 And my fifth manager was 23 24 25 Ω. Were these managers that you had at different times or did they overlap as managers for you? 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 9 of 29 Page 33 1 A. Different times. I have one manager at a 2 time. 3 Ω. Okay. And as the product strategist role, 4 did you supervise anyone? 5 A. I did not. 6 Ω. Okay. All right. 7 Let me ask you about on page 2 of 2, the 8 top, the first, I guess paragraph there. 9 A. Uh-huh. 10 Ω. You say, "Product strategy for 11 12 13 Facebook Inc.'s family of apps, including WhatsApp, Instagram, Messenger, and the main Facebook App. Worked with C-suite and heads of family of apps." 14 Did I read that correctly? 15 A. Yes. 16 Ω. Okay. When you say "worked with C-suite 17 and heads of family apps," what do you mean? 18 A. So I mean I would be in meetings with a 19 20 21 22 23 variety of company leadership. Usually, the interactions would be I would present to them my findings. And in some instances there would be working sessions where we would be developing a work product. 24 Ω. When I read "C-suite, I think of like a " 25 CEO, CFO, or CTO. Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 10 of 29 HIGHLY CONFIDENTIAL 1 2 3 Page 34 Can you be a little bit more specific on who or what titles in the C-suite you're referring to here? 4 A. Yes. CFO. 5 Ω. Okay. 6 A. And CPΟ. 7 Ω. Okay. So CFO would be the chief financial 8 officer? 9 A. Yes. 10 Ω. Okay. And CPO is the chief product 11 officer? 12 A. Yes. 13 14 Ω. So you're saying that some of your work involved you presenting to the CFO or the CPO; is 15 that right? 16 A. Yes. 17 Oh. I also presented to the COO. 18 2. Okay. 19 A. Once. 20 Ω. Chief operating officer? 21 A. Yes. 22 Ω. Okay. Did you ever have an opportunity to 23 present to the CEO? 24 A. No. 25 Ω. 877-370-3377 Okay. So you never presented to Mark Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 11 of 29 HIGHLY CONFIDENTIAL Page 35 1 Zuckerberg directly? 2 A. No. 3 Ω. And when you say "heads of family apps, " 4 who fits within that umbrella? 5 A. It would be the people who led WhatsApp, 6 Instagram, Messenger, or the main Facebook app. 7 Ω. Okay. 8 A. And so at the time for a time WhatsApp 9 was led by Chris Daniels. Messenger was led by Stan 10 Chudnovsky. 11 And then Facebook was led by probably 12 Chris Cox. And then Will Cathcart. 13 (Reporter clarification.) 14 THE WITNESS: And then Fidji Simo. 15 BY MR. DOWNING: 16 Ω. And you mentioned Instagram in here as 17 well. Did you - 18 A. I did not present to Kevin Systrom. 19 Ω. I'm sorry. You said you did not present 20 to Kevin Systrom? 21 A. No. 22 Ω. Okay. Let's move down to, I guess, the 23 next bullet. I'll read that here. It says [as 24 read]: 25 877-370-3377 Developed the overall strategy and Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 12 of 29 HIGHLY CONFIDENTIAL Page 36 1 corresponding measurement framework for the Facebook 2 app in collaboration with the head of Facebook and 3 the small cross-functional team. 4 Did I read that correctly? 5 A. Yes. 6 Ω. Okay. When you say "in collaboration with 7 8 the head of Facebook," who are you talking about there? 9 A. Will Cathcart. 10 Ω. Okay. And when you refer to the overall 11 12 13 strategy and corresponding measurement framework for the Facebook app, what project or what title does that involve? 14 A. The work was connected with our what we 15 then called our social services strategy. So the 16 idea here was that Facebook had a -- like a core of 17 18 19 assets, such as the people that use it, the brand, and whatnot, that could be used to help develop new products, such as Facebook Dating, for example. 20 And then the measurement framework was a 21 22 framework that I helped develop to help us understand kind of like the give-and-take between 23 Facebook and any new services or existing services 24 that we had for Facebook. 25 Ω. Did the measurement framework have a name 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 13 of 29 Page 37 1 internally? 2 A. I think it was just called measurement 3 framework. 4 5 Ω. Okay. Okay. Let's go down to another bullet. this is This is the third bullet. I'll 6 read it here. It says [as read]: 7 Led strategy sprint for product team; 8 strategy adopted and materials were presented to 9 Facebook's board of directors. 10 Did I read that correctly? 11 A. Yes. 12 13 Ω. So this talks about leading a strategy sprint for the product team. 14 15 A. What was the strategy sprint related to? It was related to teens. 16 Ω. 17 what -- Okay. Can you explain a little bit more when you say it's related to teens, in what 18 way? 19 A. 20 21 So the main participants of the sprints were the market strategy team, subsequently known as product strategy. And we, as a team, did a series 22 23 of analyses on teens and their app usage and how we as Facebook would want to help improve our product 24 to increase the number of teens on Facebook. 25 Ω. And this this refers to a strategy 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 14 of 29 HIGHLY CONFIDENTIAL Page 38 1 sprint. 2 3 A. What does sprint mean in this context? Oh, yeah. A sprint means a group of 4 people working together for a short period of time 5 on a particular topic. 6 7 Ω. Okay. And why was there a strategy sprint related to this teen work? 8 A. There was a decline in the number of 9 10 11 monthly active teens on the Facebook app. So that was a concern. And given that concern, it was important to develop a stronger understanding of 12 what might be going on in that space. And so that's 13 14 why we brought in a bunch of people together to increase the focus on it. 15 Ω. Okay. And this goes on to say that the 16 strategy was adopted. 17 Adopted in what sense? 18 A. Adopted in the sense of I forget the 19 exact contents of the strategy. I think the main 20 21 22 thing that was adopted was we stood up a teens product team to work on the teen space to build product for teens. 23 24 25 Ω. Okay. And the reason to build the product was to stop the teen decline and get more teen users on the Facebook app; is that right? 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 15 of 29 HIGHLY CONFIDENTIAL Page 39 1 2 3 MR. EPPICH: Object to the form. THE WITNESS: My understanding was that the teens team was formed to bring teens back to 4 Facebook. 5 BY MR. DOWNING: 6 Ω. Okay. And then I think this is going to 7 8 be my last question on this bullet, but you talk about the materials were presented to Facebook's 9 board of directors. 10 Were you involved personally in presenting 11 the material to the Facebook board of directors? 12 A. No. 13 Ω. Okay. 14 A. I helped put together the materials, but I 15 did not present on it. 16 Ω. So when you say you helped put together 17 the materials, what materials did you help put 18 19 A. 20 21 22 together? Slides, like PowerPoint slides. Ω. And based on your understanding, those PowerPoint slides were then presented to Facebook's board of directors; is that right? 23 A. That's my understanding. 24 Ω. Okay. Do you know who did the 25 presentation to Facebook's board of directors? 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 16 of 29 Page 40 1 A. I believe it was 2 Ω. Okay. And was on this team 3 that you were working on? 4 A. He was a lead product manager for the 5 teens team. 6 Ω. Okay. And do you know if the board did 7 anything in response to receiving the presentation? 8 MR. EPPICH: Object to the form. 9 Foundation. 10 THE WITNESS: I do not. 11 BY MR. DOWNING: 12 Ω. Okay. Let me ask you going back to 13 page 1 of your LinkedIn profile, you show a 14 different role, and I'll read it. It says: Meta 15 product lead, September 2019 to present. 16 Is this a new role or - I should say - 17 strike that. 18 Is this a change in your role at Meta? 19 A. Yes. I switched from product strategist 20 to product management. 21 Ω. Okay. And did you switch in September of 22 2019? 23 A. Yes. 24 Ω. Okay. And are you presently in that role? 25 A. Yes. 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 17 of 29 HIGHLY CONFIDENTIAL Page 41 1 Ω. Okay. And who is your supervisor 2 presently? 3 A. 4 Ω. And do you supervise anyone presently in 5 your role as product lead? 6 A. No. 7 Ω. And let me ask you, above the Meta product 8 lead there's it also says: Instagram product 9 lead, April 2024 to present. 10 Do you see that? 11 A. Yes. 12 Ω. Do you also have a title within Instagram 13 somehow? 14 A. I'm indicating that I currently work on 15 16 Instagram products. Ω. Okay. What product do you currently work 17 on at Instagram? 18 A. Instagram's website, instagram.com. 19 Ω. Okay. Can you be more specific, like what 20 part of instagram.com do you work on? 21 22 23 24 A. I focus primarily on the logged-out experience of instagram.com. So if you go to you type in instagram.com on your phone or your computer, and you're not logged in to your Instagram if 25 account, that's the experience that I am focused on. 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 18 of 29 Page 112 1 video record. 2 (Whereupon, a brief recess was taken.) 3 THE VIDEOGRAPHER: 12:42. We're on the 4 video record. 5 BY MR. DOWNING: 6 Ω. All right. Good afternoon Mr. Chen, 7 welcome back. 8 We are going to jump into another set of 9 documents here. I have a document which will be 10 marked Exhibit 5 for you to review. 11 (Whereupon, Meta-Chen Exhibit 5 was marked 12 for identification.) 13 THE WITNESS: Thank you. 14 MR. DOWNING: For the record I will read 15 in the Bates number, which is 16 17 ΜΕΤΑ3047MDL-027-00000106. Ω. Mr. Chen, if you review it generally, then 18 we will go through more specifically some portions 19 of it, so... 20 21 A. Go ahead and do that if you would. Okay. 22 23 Ω. Okay. Mr. Chen, this document is Exhibit 5. At the top, you will see a Bates 0102, 24 the first page, it says "MK & Youth Platform 25 Products Reviews." Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 19 of 29 Page 113 1 Do you see that? 2 A. Uh-huh. 3 Ω. Below that it says [as read]: 4 Closed group. 129 members. Summaries of 5 the MK Leads Reviews with SL dot, dot, dot. 6 Do you see that? 7 A. Uh-huh. 8 Ω. 9 A. This was a Workplace group at Meta, right? Yes. 10 2. Okay. And you are one of the members of 11 12 this 129-member MK and youth platform product review group, right? 13 MR. EPPICH: Object to the form. 14 THE WITNESS: I assume I was a member. 15 BY MR. DOWNING: 16 Ω. Okay. And you assume you were a member 17 because of what? 18 A. There's a post from me. 19 Ω. Okay. 20 A. Yeah. 21 Ω. And that's what I was going to get into. 22 Below that, do you see your name and a 23 circle with your picture in it? 24 A. Yes. 25 Ω. Okay. That is your picture, correct? Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 20 of 29 Page 114 1 A. Yes. 2 Ω. Okay. And it says "Robert Chen (PM) is 3 with " 4 Do you see that? 5 A. Yes. 6 Ω. It says August 18, 2018, correct? 7 A. Yes. 8 Ω. Okay. 9 A. August 10. 10 Ω. Oh, sorry, sorry. Let me read it again. 11 12 August 10, 2018. Thank you for correcting me. 13 A. Uh-huh. 14 2. Okay. This is a post that you made on 15 August 10, 2018, to this Workplace group, correct? 16 A. Yeah. 17 Ω. Okay. Okay. 18 19 20 21 Beneath your name and the date is the title Market Landscape Review Competitive Landscape Review. Correct? August 9th (fka) 22 A. Yes. 23 Ω. FKA means formerly known as? 24 A. I believe so, yes. 25 Ω. 877-370-3377 And under that you say, "We discussed Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 21 of 29 Page 118 1 " 2 3 4 5 6 7 8 9 A. Instagram, what did you mean? A. So I don't remember the specific post. But looking at it now, I think in the context of this post, the long-term retention work was done for Facebook but we hadn't done it for Instagram and so I'm suggesting we could look into the same thing for Instagram. Ω. Okay. Long-term retention for Instagram. 10 Ω. Okay. All right. 11 And then there's a heading for Lifetime 12 Value here, right? 13 Do you see that? 14 A. Yes. 15 Ω. Okay. And there are three bullets below 16 that, correct? 17 A. Uh-huh. 18 Ω. Okay. 19 A. Three top level bullets, yeah. 20 Ω. Three sorry. You're right. 21 Three top level bullets. 22 A. Uh-huh. 23 Ω. The first bullet says "LTV work plugs in 24 retention figures from the retention work above." 25 Did I read that correctly? 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 22 of 29 Page 119 1 A. Yes. 2 Ω. Okay. So you're talking again about how 3 4 long-term retention feeds into lifetime value, right? 5 A. Yeah. 6 Ω. 7 Okay. The second bullet says [as read]: Because the difference in retention for 8 9 10 11 people who join as teens is so much greater than those who joined later in life, preliminary results suggest that lifetime value for people who joined Facebook as teens is significantly higher. 12 Did I read that correctly? 13 A. Yes. 14 Ω. Okay. And then you propose "Next steps." 15 There are two here that you propose, right? 16 A. Yeah. 17 Ω. 18 A. You propose to refine the model, correct? Yes. 19 Ω. And by refine the model you mean refine 20 the model that does the lifetime value calculation? 21 A. Yes. 22 Ω. Okay. And then you also propose next 23 steps to connect with finance to validate, right? 24 A. Yes. 25 Ω. Okay. What would it mean to validate with 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 23 of 29 Page 173 1 BY MR. DOWNING: 2 Ω. I can re-ask this question. 3 When you say $270 per teen, is that 270 in 4 profit or in revenue? 5 A. 6 It's definitely not profit. For the lifetime value calculations, I had used average 7 revenue per user. 8 9 10 Ω. Okay. So you are saying because you had used average revenue per user, this $270 figure is form of revenue? a 11 12 MR. EPPICH: Object to the form. Vague. THE WITNESS: It is like a transformation 13 14 15 of the revenue, because the ARPU is the component of the model along with retention and the weighted average cost of capital. 16 BY MR. DOWNING: 17 Ω. Okay. 18 A. 19 So it's connected to revenue, yeah. MR. DOWNING: All right. Let's continue 20 21 on to a new document here. This will be Exhibit 9, Tab 16. 22 (Whereupon, Meta-Chen Exhibit 9 was marked 23 for identification.) 24 BY MR. DOWNING: 25 Ω. Here you go. Mr. Chen, I have handed you 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 24 of 29 Page 174 1 Exhibit 9, which has the Bates number 2 ΜΕΤΑ3047MDL-014-00289025. 3 A. Okay. 4 Ω. Okay. Mr. Chen, the first page shows an 5 e-mail from 6 Do you see that? 7 A. Yes. 8 Ω. You had mentioned him earlier. 9 He was one of your supervisors; is that 10 right? 11 A. Yes, he was one of my managers. 12 Ω. Okay. Was he your manager in in 13 October 2018? 14 A. I'm not a hundred percent sure, but I 15 think so. 16 Ω. Okay. So sent an e-mail here 17 to a group that is entitled 18 market_strategy_updates@FB.com. 19 Do you see that? 20 A. Yes. 21 Ω. Do you know if you were part of that 22 group? 23 A. I don't know for sure, but I would 24 expect -- 25 Ω. 877-370-3377 I would think so. Okay. And the subject of this e-mail is Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 25 of 29 Page 175 1 Market Strategy Updates 10/5/18. 2 Do you see that? 3 A. Yeah. 4 Ω. So this was the market strategy update for 5 October 5, 2018, right? 6 A. Yes. 7 Ω. Okay. Let me direct your attention to one 8 of the particular sections, Section 2, which is on 9 0 - I'm sorry -- 9027. 10 Do you see where it says: 2 Ecosystems 11 U.S. User Lifetime Value Phase 1? 12 A. Yes. 13 Ω. Okay. If you look at the next page, 9028, 14 up above Assumptions there is a bullet that says: 15 POC Robert Chen. 16 Do you see that? 17 A. Yes. 18 Ω. Okay. That means that you were the point 19 of contact; is that right? 20 A. Yes. 21 22 23 Ω. Okay. So were you the point of contact on this particular bullet, right, or this particular section? 24 A. Yes. 25 Ω. Okay. And that's because you had done a 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 26 of 29 Page 176 1 significant amount of work on lifetime value, right? 2 A. That's right. 3 Ω. Okay. Let's just flip back to 9025, the 4 first page. 5 A. Okay. 6 Ω. There are Highlights here. 7 Do you see 1 through 5 Highlights? 8 A. Yes. 9 Ω. Okay. Highlight 2 says: Ecosystems US 10 User Lifetime Value Phase 1. 11 Do you see that? 12 A. Uh-huh. 13 Ω. Can you read the text that follows U.S. 14 User Lifetime Value Phase 1, that paragraph? 15 A. [As read]: 16 Based on a conservative set of 17 assumptions, we find the lifetime value, LTV, of 18 users in the United States to be between $200 and 19 $350. People who join FB as 13-year-olds have an 20 21 LTV of approximately 350, higher than all other teen ages 13 to 18, due to their very high long-term 22 retention. We should acquire teens as young as 23 possible. Phase 2 of the work will explore how the 24 assumptions may change. 25 Ω. Okay. Thank you. So in this highlight Golkow Technologies, 877-370-3377 A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 Page 27 of 29 HIGHLY CONFIDENTIAL Page 177 1 here, it says that people who join Facebook as 2 13-year-olds have a lifetime value of approximately 3 $350, right? 4 A. Yes. 5 Ω. So previously, your September 7th e-mail 6 had said $270, right? 7 A. I forget exactly. 8 Ω. Okay. 9 A. Sorry. 10 Ω. Here, do you want to look back at 11 A. Sure. 12 Ω. This would be Exhibit 8. 13 A. Uh-huh. 14 Ω. Which would be the second page of the 15 e-mail under "Progress." 16 A. Yes. 17 Ω. Okay. So what I'm trying to understand is 18 that the calculation had now yielded a slightly 19 higher lifetime value for 13-year-olds, right? 20 MR. EPPICH: Object to the form. 21 THE WITNESS: It looks like it's higher in 22 this October e-mail. 23 BY MR. DOWNING: 24 Ω. 25 Okay. And by higher, it's October 13th e-mail, it's $350 for lifetime value of -- in this 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 28 of 29 Page 178 1 a 13-year-old, right? 2 MR. EPPICH: Object to the form. 3 THE WITNESS: That's - yeah, that's what 4 the e-mail says. 5 BY MR. DOWNING: 6 Ω. Okay. Mr. Chen, were you involved in the 7 updating of these figures that went from 270 to 350? 8 A. I 9 MR. EPPICH: Object to the form. 10 THE WITNESS: I was the main person on the 11 team working on this. So I wouldn't have a reason 12 to think that it was somebody else. 13 BY MR. DOWNING: 14 Ω. Okay. 15 A. Yeah. 16 Ω. All right. Let's -- let's go to the 17 actual details that start on Bates 9027. 18 Mr. Chen, do you know did you help 19 actually draft this portion of the e-mail that talks 20 about US User Lifetime Value, Phase 1? 21 A. Most likely. 22 Ω. Okay. 23 A. But I don't remember. It's been a while. 24 Ω. Okay. All right. 25 Under "Context," I want to ask a couple 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com Case 4:22-md-03047-YGR Document 2885-9 Filed 03/26/26 HIGHLY CONFIDENTIAL Page 29 of 29 Page 313 1 2 STATE OF CALIFORNIA COUNTY OF YOLO ) ) 3 4 5 6 7 I, ELAINA BULDA-JONES, a Certified Shorthand Reporter of the State of California, duly authorized to administer oaths pursuant to Section 2025 of the California Code of Civil Procedure, do hereby certify that 8 ROBERT CHEN, 9 10 11 12 13 14 15 16 the witness in the foregoing deposition, was by me duly sworn to testify the truth, the whole truth and nothing but the truth in the within-entitled cause; that said testimony of said witness was reported by me, a disinterested person, and was thereafter transcribed under my direction into typewriting and is a true and correct transcription of said proceedings. 17 18 19 20 21 I further certify that I am not of counsel or attorney for either or any of the parties in the foregoing deposition and caption named, nor in any way interested in the outcome of the cause named in said deposition dated the day of 22 2025. 23 24 Elaßre Jus 25 ELAINA BULDA-JONES, CSR 11720 877-370-3377 Golkow Technologies, A Veritext Division www.veritext.com