4 . ONLY those specific act(s) or practice(s) taking Neutral. But PC envisages practical difficulties in N/A. place in HK will be subject to the specific relevant dissecting the data cycle in different stage and then Reference: sections 44-45 of Appellant,s reply statement DPP or provision of the PDPO covering that act or applying different DPP/ PDPO provisions. practice. Issue 1A. The meaning of “processing，，under the Processing Requirement 5 . “Processing’’ has a narrow definition in the PDPO, covering only amending, augmenting，deleting or rearranging data” and thus，only acts which falls within this narrow definition taking place in HK will fall within the jurisdiction of HK. “ Wider definition of “processing，，i.e. should be construed to cover collection, holding, processing No definitive view and use of data. X relies on the definition of the “processing” under the PDPO 一 processing cover automated means or non-auto- Different from GL mated means under the PDPO. Similar to X X also relies on Google Spain and the 1995 EU Directive to say GL's search engine falls within the meaning of Different from PC and X processing” “ under 1995 EU Directive. Rcfcrcncc: sections 46-54 of Appellant,s reply statement Issue 2. Whether there is any control in or from HK? 6 . No. The search engine is controlled by Google Same as GL LLC，which is located outside of HK. Different from X Same as PC At hearing X says that the domain name “google.com.hk” is registered by Google (HK) Limited with the HKDNR. Hence, Google HK has certain control on the data cycle in , HK. Different from X Reference: sections 141-146 ol、AppellaiU"s reply slatenient