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Before the
Federal Trade Commission
Washington, DC
In the Matter of
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Facebook, Inc.
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Complaint, Request for Investigation, Injunction, and Other Relief
I. Introduction
1. This complaint concerns material changes to privacy settings made by Facebook, the
largest social network service in the United States, which adversely impact users of the
Facebook service. Facebook’s changes to users’ privacy settings disclose personal
information to the public that was previously restricted. Facebook’s changes to users’
privacy settings also disclose personal information to third parties that was previously not
available. These changes violate user expectations, diminish user privacy, and contradict
Facebook’s own representations. These business practices are Unfair and Deceptive
Trade Practices, subject to review by the Federal Trade Commission (the “Commission”)
under section 5 of the Federal Trade Commission Act.
2. These business practices impact more than 100 million users of the social networking site
who fall within the jurisdiction of the United States Federal Trade Commission.1
3. EPIC urges the Commission to investigate Facebook, determine the extent of the harm to
consumer privacy and safety, require Facebook to restore privacy settings that were
previously available as detailed below, require Facebook to give users meaningful control
over personal information, and seek appropriate injunctive and compensatory relief.
1 Facebook, Statistics, http://www.facebook.com/press/info.php?statistics (last visited Dec. 14, 2009); see also Eric
Eldon, Facebook Reaches 100 Million Monthly Active Users in the United States, InsideFacebook.com, Dec. 7,
2009, http://www.insidefacebook.com/2009/12/07/facebook-reaches-100-million-monthly-active-users-in-the-
united-states (last visited Dec. 15, 2009).
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II. Parties
4. The Electronic Privacy Information Cen