Google's Response to DOJ

Google put their Response to the DoJ motion online. It's an interesting read. I'd like to see Cutts' declaration if anyone knows if it's available. For those not even wanting to read the intro (I recommend reading the whole thing), the key arguments are:

• Insufficient justification for non-party subpoena
• Possibility to becoming admissible evidence not established
• Compromising trade secrets without substantial need
• Undue burden for non-party

Sub-points to the third are it's also a compromise of user privacy and trust, and sub-points to the fourth are that some information is covered under various government privacy acts that may not be covered by a subpoena or require advance notification of the user. Like I said, it's an interesting read.