Meta & Children's Online SafetyHigh School Communities
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Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 1 of 81 AMENDED Exhibit 38 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 HIGHLY CONFIDENTIAL (COMPETITOR) Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 2 of 81 HIGH SCHOOL COMMUNITIES APRIL 23, 2018 ΜΕΤΑ3047MDL-044-00008035 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 3 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008036 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 4 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008037 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 5 of 81 Why does high school matter? Almost all of an American¹ teen's most important "jobs to be done" happen at school. • • The typical American teen spends 35 hours per week in classes and an additional 5-15 hours per week doing homework while 57-76%² of US children participate in at least one extra-curricular activity.. American teens meet their friends and romantic interests at school, get to know them through classes or clubs, and gradually become close outside of school. Winning teens requires tipping local school networks. 1. This is true only of Western Teens. We will only focus on US Teens for this year, but we believe our learnings will be generalizable as teens meet and grow closer to friends in other real world communities (religious, neighborhood, sports team) in other markets 2. https://www.census.gov/newsroom/press-releases/2014/cb14-224.html https://nlts2.sri.com/reports/2003_04-2/nlts2_report_2003_04-2_ch4.pdf HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008038 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 6 of 81 High school is a wedge into social Teens meet and get to know new friends and crushes at school. So in building for school, we will mirror teens' real world relationship development and have a shot at winning core social interactions. At School Online Meeting new people Meet people in classes or clubs at school. Discover people in your community and club groups. Becoming Friends Hang out repeatedly with your shared group. Interact repeatedly in club, class or social groups. Deepening a Relationship Hang out 1:1. Direct messaging. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008039 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 7 of 81 Our opportunity By End of 2018: Product Market Fit We have a retentive and engaging product that is used an average of 3x a week by 50%+ of a high school student body. In our qual research, people in this school love how it helps them feel part of the community. We hear about people starting to use and love it for communicating with clubs and classes. By End of 2019: US Growth By End of 2020: US Saturation and Global Testing HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008040 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 8 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008041 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 9 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008042 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 10 of 81 People problem I need one place to communicate with classmates and see what my school community is talking about. HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008043 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 11 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008044 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 12 of 81 Product strategy Our solution to this people problem will work if and only if: 1. Teens believe the audience of the app is only people at their high school. 2. Teens can quickly discover and join the right channels for their classes, clubs and communities. 3. Teens believe that recipients will quickly see the content that they send because: The product is messaging first; The product has reliable push The product can send messages to classmates using other apps (Google Classroom, Remind); 4. Teens can interact with anyone who goes to their high school - not just "friends". HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008045 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 13 of 81 Can we realize this strategy in Blue or Messenger? Need Audience is High School Only Messaging First Push Reliability Integrations with School Apps Community (Rather than Friending) Graph Joinable Channels Have the App Installed Existing Content on the App 1. HIGHLY CONFIDENTIAL (COMPETITOR) Blue Messenger New App ✓ 1 ✓ ✓ ✓ ✓ ✓ ✓ META3047MDL-044-00008046 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 14 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008047 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 15 of 81 People problem I need one place to communicate with classmates and see what my school community is talking about. HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008048 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 16 of 81 Competitive gaps Problems with current solutions • No Standard. Different clubs, classes and community groups use different technologies for sharing about school. Incomplete Graph. People do not have phone numbers, emails or social media connections with everyone in a group so communication is confined to cliques within a team/club/class. Noisiness. Messaging and Snap are not optimized for recalling important content and students report being overwhelmed with low signal messages. Barriers to Switching to a New Solution No one else will use it. Teens are afraid of associating themselves with an uncool product and that if no one else switches, they will feel rejected for using the uncool product. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008049 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 17 of 81 Design principles HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008050 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 18 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008051 School communication is fragmented, with everyone using something different. Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 19 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008052 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 20 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008053 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 21 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008054 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 22 of 81 Keep things fun and social. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008055 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 23 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008056 #Events No more being the person who finds out about fun things after they happen. Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 24 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008057 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 25 of 81 62 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008058 Focus mode Group messaging today is noisy and distracting. Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 26 of 81 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008059 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 27 of 81 What teens had to say "I'm looking forward to having the whole high school experience, you know, both the school stuff and a social life.” 1 HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008060 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 28 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008061 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 29 of 81 Traction and growth 97% of US teens live in an area saturated by Facebook or Instagram. FB-Only Saturated FB+IG Saturated FB+Msg Saturated IG-Only Saturated Non-Saturated HIGHLY CONFIDENTIAL (COMPETITOR) Biode Mand Ferstad 2016 We will attract initial users to download by using ads and QPs across both platforms. We will solve cold start in channels by importing school content from both platforms. We will drive growth by building integrations that enable the sharing of content and sending of messages from to Facebook, Messenger and Instagram. META3047MDL-044-00008062 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 30 of 81 Facebook's Community Integrity teams will be essential to our success Facebook can keep out bad actors. • Teens tell us that other high school social spaces become unsafe as adults, scammers and predators invade the space. • Facebook's real identity, coupled with our age affinity, location and friend graph allow us to have a high degree of confidence when students go to a school. Facebook CI can police bad content. • Teens also warn us that student-only spaces become rife with bullying and drama causing other students to flee. • We have the know-how and resources to enforce high community standards to keep the space feeling safe and positive. HIGHLY CONFIDENTIAL (COMPETITOR) CI ΜΕΤΑ3047MDL-044-00008063 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 31 of 81 Strategy review 1. High School communication is important to teens and important for us to win. 2. The right people problem for us to focus on is class, club and community communication. 3. The right way for us to solve this problem is in a new app. 4. Facebook helps us solve the cold start and growth problems that would stymie other independent apps. 5. When this independent app is successful, it will be valuable for Blue and Messenger. HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008064 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 32 of 81 The Opportunity for By End of 2019: US Growth By End of 2020: US Saturation and Global Testing HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008065 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 33 of 81 The Opportunity for Facebook As grows, it will be a valuable on-ramp to Blue and Messenger. Account growth will require a Facebook account, and enable teens to create accounts directly in the app. Data sharing interaction data can be used to power Facebook ranking like PYMK, Coefficient, Feed Rankings and Groups You Should Join. HIGHLY CONFIDENTIAL (COMPETITOR) META3047MDL-044-00008066 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 34 of 81 Appendix HIGHLY CONFIDENTIAL (COMPETITOR) ΜΕΤΑ3047MDL-044-00008067 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 35 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 36 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 37 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 38 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 39 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 40 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 41 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 42 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 43 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 44 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 45 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 46 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 47 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 48 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 49 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 50 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 51 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 52 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 53 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 54 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 55 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 56 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 57 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 58 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 59 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 60 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 61 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 62 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 63 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 64 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 65 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 66 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 67 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 68 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 69 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 70 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 71 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 72 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 73 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 74 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 75 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 76 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 77 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 78 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 79 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 80 of 81 Case 4:22-md-03047-YGR Document 2648-4 Filed 01/20/26 Page 81 of 81