to block all third party cookies. If you have not changed those settings, this option essentially accomplishes the same thing as setting the opt-out cookie.”7 In February 2012, Stanford graduate student Jonathan Mayer published an online report revealing that Google and the other defendants had discovered, and were surreptitiously exploiting, loopholes in both the Safari cookie blocker and the Internet Explorer cookie blocker.8 Safari’s cookie blocker turns out to have had a few exceptions, one of which was that it permitted third-party cookies if the browser submitted a certain form to the third-party. Because advertisement delivery does not, in the ordinary course, involve such forms, the exception ought not have provided a pathway to installing advertiser tracking cookies. But according to Mayer’s report, Google used code to command users’ web browsers to automatically submit a hidden form to Google when users visited websites embedded with Google advertisements. This covert form triggered the exception to the cookie blocker, and, used widely, enabled the broad placement of cookies on Safari browsers notwithstanding that the blocker—as Google publicly acknowledged—was designed to prevent just that. The other defendants, meanwhile, accomplished similar circumventions. As a result, the defendants could—and did— place third-party cookies on browsers with activated blockers. 7 Compl. ¶ 79. 8 Compl. ¶ 75; Jonathan Mayer, Web Policy Blog, Safari Trackers (Feb. 17, 2012), http://webpolicy.org/2012/02/17/safari-trackers/. 9