In Campbell v. Facebook Inc., No. 13-cv-05996 (N.D. Cal. Oct. 14, 2015), the district court granted the plaintiffs’ motions to compel Facebook to produce electronically stored documents and provide a Fed. R. Civ. P. 30(b)(6) deponent to testify about source code Facebook had previously produced.  Facebook objected on the grounds that the vast majority of the information in the documents the plaintiffs requested was contained in the source code itself.  Facebook also argued that the Rule 30(b)(6) topics regarding the source code were improper because Facebook provided a declaration that explained the processes at issue and attached technical documents explaining the relevant portions of the source code.  The court rejected Facebook’s arguments, holding that “different types of discovery address different concerns” and that the plaintiffs had a right to verify and explore its theories related to the source code through document requests and depositions