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[ NNSquad ] Re: Google complies with order of Bay Area federal judge -- Wikileaks all over again



----- Forwarded message from David Farber <dave@farber.net> -----

Date: Tue, 29 Sep 2009 02:18:48 -0400
From: David Farber <dave@farber.net>
Subject: [IP] Re:   Google complies with order of Bay Area federal judge --
	Wikileaks all over again
Reply-To: dave@farber.net
To: ip <ip@v2.listbox.com>



Begin forwarded message:

From: "Paul Levy" <plevy@citizen.org>
Date: September 28, 2009 10:52:10 PM EDT
To: dave@farber.net, "Matthew Tarpy" <tarpy@tarpify.com>
Subject: RE: [IP] Google complies with order of Bay Area federal judge -- 
Wikileaks all over again

1.  Emergency situation involving a violation of what law?  Without a  
violation, prior restraint for what?  The recipient of the mail did  
nothing wrong; and there is no suggestion of any intent or plan to do  
anything wrong; so what is the basis for seeking an injunction against him 
or her?  RMB said diversity jurisdiction presumably because it recognized 
it had no federal cause of action.  And there was no real attempt to assert 
any state cause of action -- it was just, gee, we made a terrible mistake 
and we want to harness the court's power to do something about it. And 
there is no cause of action against Google -- Google is immune from suit 
for any wrongdoing by its users.  Sorry, when a bank inadvertently 
discloses info, that info doesn't become a trade secret.  And even if it 
were, the Ninth Circuit does not agree that state law IP claims (and trade 
secret claims are under state law) are within the IP exception to section 
230.

2.  Since the anonymous recipient is a Doe, Rocky Mt Bank had no right to 
file in federal court; you can't sue a Doe in diversity.  Sure, they wanted 
to be in federal court, because of the augmented powers, many litigants try 
to come to federal court for that reason, but we have had 30 years of 
precedent, since the end of the Warren Court, emphasizing that federal 
courts are courts of limited jurisdiction and you can't sue there just 
because you want to use the federal courts.

3.  Then you have the problem of seeking relief against the Doe with, so 
far as I can tell, no effort whatsoever to notify the Doe of the  
proceeding so that Doe could retain counsel and oppose.  This raises  
procedural issues under Rule 65, not to speak of the constitutional  
problems.  It is not even clear that there was notice of the TRO  
proceeding to Google -- Google's counsel entered an appearance the day  
after the TRO.  Not saying there was no notice to Google -- just don't  
know that there was.

4.  Yes, the relief was amazingly overbroad.  Freeze Doe's email account, 
because some bank employee screwed up?  Strip Doe of his or her right to 
anonymity because the bank staffer screwed up?  The whole idea of being 
able to waltz into court and compel an ISP to suspend an email account on 
such vague grounds is incredibly offensive.

5.  "exigent circumstances" seems suspect to me.  The problem occurred on 
August 13.    RMB went to court on September 17, sought a TRO on September 
18, then had to file publicly on September 22.  Why couldn't it take time 
to give notice and provide a real chance to respond?  Usually, when the 
litigant delays filng for relief, that counts against the claim for a TRO
6.  Finally, it would be nice to know exactly what Google did to comply 
with the court's order
Google told the court that it had comnplied, and how, but it did that in a 
secret filing

Paul Alan Levy
Public Citizen Litigation Group
1600 - 20th Street, N.W.
Washington, D.C. 20009
(202) 588-1000
http://www.citizen.org/litigation.
>>> "Matthew Tarpy" <tarpy@tarpify.com> 9/28/2009 8:33 PM >>>
Hi Paul-

I'll start off with IANAL, but from what I've read of this case so far, it 
sounds like the bank had a pretty good argument that the accidental 
disclosure of the information and possible redisclosure of the information 
did meet some "test" of exigent circumstance giving the Bank the right to 
get the prior restraint relief it was seeking.

Is your issue that the ruling by the judge was overbroad, or that there 
shouldn't have been any prior restraint at all? If the first, would you 
view as a more reasonable course of action have been the judge requiring 
the Gmail account holder (who could have remained anonymous by creation of 
a secondary Gmail account or some other means to communicate between 
Google, the account holder, the bank, and the special master) to cede 
temporary custody of the account to a special master who would verify that 
the information hadn't been re-distributed, and compel Google to delete all 
copies of that spreadsheet (I'm sure there's some trade secrets law that 
could be stretched to fit around this situation)?

If the second, then what remedy would the bank have to protect themselves 
and their customers against a data breach?

--matthew

From: David Farber [mailto:dave@farber.net]
Sent: Monday, September 28, 2009 6:12 PM
To: ip
Subject: [IP] Google complies with order of Bay Area federal judge --  
Wikileaks all over again



Begin forwarded message:

From: "Paul Levy" <plevy@citizen.org>
Date: September 28, 2009 4:34:36 PM EDT
To: <dave@farber.net>
Subject: Google complies with order of Bay Area federal judge -- Wikileaks 
all over again

Last week, a federal judge in the Northern District of California issued an 
order requiring Google to suspend a gmail account and identify its 
anonymous owner in another case that bears an eerie resemblance to last 
year's Wikileaks controversy -- bank runs into court, describes a threat to 
the confidentiality of its banking records that requires urgent action, and 
judge willingly goes along by issuing an order of questionable validity 
under the First Amendment, all without hearing from the other side (raising 
Due Process issues). And just as in Bank Julius Baer v Wikileaks, even 
apart from the consitutional concerns, the lawsuit itself is highly 
questionable -- although the potential disclosure of confidential documents 
is a serious issue, it is not at all clear that Rocky Mountain Bank had any 
valid claims against Google or the accidental recipient of its own  
careless disclosures, there was an obvious defect in the claim for fereral 
court jurisdiction, and the papers raised questions about whether the bank 
complied with the notice requirements of the Federal Rules of Civil 
Procedure before it could seek a temporary restraining order.  In the 
Wikileaks case, it was a small ISP that went along with the court order 
because it didn't want to spend money litigating the case in its customer's 
interest; here is was Google that went along, and it remains to be seen why 
it complied so easily.

I discuss these issues here:
http://pubcit.typepad.com/clpblog/2009/09/did-google-yield-too-easily-to-a-baseless-court-order.html




Paul Alan Levy
Public Citizen Litigation Group
1600 - 20th Street, N.W.
Washington, D.C. 20009
(202) 588-1000
http://www.citizen.org/litigation

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