Aleksei - stock.adobe.com
When Facebook’s instant messaging service was falling behind rivals, including WhatsApp, CEO Mark Zuckerberg devised a plan to grow Facebook Messenger into the dominant messaging service. To implement it, Facebook undermined competitors.
Facebook’s staff saw the social network as “the biggest service on Earth” and Messenger was a key, yet vulnerable, part of the business. Despite Facebook’s popularity, its messaging service was losing out to competitors that focused solely on messaging.
Confidential documents, published by Computer Weekly and NBC, are likely to raise questions for lawmakers and regulators, as they reveal that Facebook walked over developers who had helped make Facebook a success.
The documents are being examined by US lawmakers in the House Judiciary Subcommittee on Antitrust, Commercial and Administrative Law as part of its antitrust investigation into Facebook and other big tech companies. Separate investigations are underway by the US Federal Trade Commission and US state attorneys general.
Based on extensive analysis of leaked documents, Computer Weekly can reveal how Zuckerberg’s plan to dominate instant messaging unfolded.
Facebook said in a statement that Six4Three, which developed an app called Pikinis to find friends wearing bikinis, had “cherry-picked” the documents as part of a lawsuit attempting to force Facebook to share information on friends of the app’s users.
Paul Grewall, vice-president and deputy general counsel at Facebook, said: “The set of documents by design tells only one side of the story and omits important context. We still stand by the platform changes we made in 2014/2015 to prevent people from sharing their friends’ information with developers like the creators of Pikinis.”
Zuckerberg pulls the trigger
At 1.28am on 10 January 2013, Facebook co-founder Mark Zuckerberg was working into the night.
“I think we should block WeChat, Kakao and Line Ads [from Facebook],” he wrote in an email to his team. “Those companies are trying to build social networks and replace us.”
His decision followed tormented discussions among Facebook’s team about the threat posed by rival messaging services.
“I think we should block WeChat, Kakao and Line Ads. Those companies are trying to build social networks and replace us. The revenue is immaterial compared to any risk”
Mark Zuckerberg, Facebook
Zuckerberg must have read his vice-president of international growth Javier Olivan’s anxious message several times: “We will look like complete idiots if we lose our business to these messenger services and help them along for a couple of $$.”
One of Facebook’s biggest sources of revenue was an advertising service for app developers, called Neko, which allowed developers to promote their apps to Facebook users, for a fee.
But Olivan had qualms that Facebook could be helping developers who threatened Facebook’s business model.
The company had good reason to worry. It had been slow off the mark to move Facebook services to mobile, and it was seeing a “terminal decline” in the number of posts people were making on their personal Facebook pages.
“The sum-product of shift to mobile + messenger services morphing into fully fleshed [social networking] sites is IMO [in my opinion] the biggest competitive threat we face as a business,” said Olivan.
Javier Olivan, Facebook
“Messenger services deserve special treatment since [they are] arguably one of the most dangerous beach heads to morph into Facebook ” he wrote.
A tweet from WhatsApp on 2 January had triggered Olivan’s panic. He shared it with Zuckerberg: “On Dec 31st we had a new record day: 7B msgs inbound, 11B msgs outbound = 18 billion total messages processed in one day! Happy 2013!!".
More bad news came from Korea’s Information Society Development Institute, which revealed the volume of messages sent via Kakao Talk – a free mobile instant messaging application for smartphones – had increased by over 850% and more than 100 billion users in just one year.
Facebook goes on the offensive
News about the success of strategic competitors kept landing as the team pulled together shortlists of apps and developers it considered a strategic threat.
Facebook had encouraged developers to build apps and to embed them into the Facebook platform since 2007, a tactic which helped it to rapidly acquire millions of new users.
Now, after fending off rival social networking sites such as MySpace, Facebook planned to restrict access to data about the friends of people who used rival messenger apps – information that many developers considered offered the greatest value for their products.
Third-party apps could access a wide range of data about users’ friends, through an application programming interface (API) called Friends.get. It gave them access to the names of their customers’ friends, their birthdays, gender, geographic location, email addresses and personal photographs. Developers used this information to encourage friends of their existing users to download their apps.
Jud Hoffman, then Facebook’s global policy manager, wrote in January 2013: “On the Platform side, we’re restricting access to Friends.get for all messenger apps so that they’re not using our data to compete with us.”
Justin Osofsky, Facebook
When Twitter launched Vine, a service for making and sharing six-second videos, Zuckerberg ordered immediate counter-measures.
Facebook’s vice-president, Justin Osofsky, emailed the leadership team alerting them to Vine as soon as it appeared: “Unless anyone raises any objections, we will shut down their [Vine’s] friends API access today.” Zuckerberg’s reply came swiftly: “Yeah, go for it.”
Facebook dealt Vine another blow some five months later, when Facebook’s newly acquired picture-sharing service, Instagram, launched its own 15-second video-sharing apps on Android and iPhone.
Messenger services pay more for ads
By August 2012, Facebook had decided to increase advertising prices “for the entire competitive list”, starting with Google products.
Leaked documents show some Facebook staff worried about how the plan would affect Facebook financially.
Facebook’s advertising chief, David Fischer, warned that “a large part of the market for our network will come from current and potential competitors”. He was sceptical that Facebook could “have the winning product if we rule out such large parts of the market”.
Facebook kept a list of strategic competitors that was “personally reviewed” by Zuckerberg, according to confidential emails. Messaging apps WhatsApp, Viber, Imo and Kakao Talk were among those that attracted Zuckerberg’s interest.
Hoffman suggested ways to ensure that rival messaging apps could not promote their apps to Facebook users: “Reject ads for WeChat and a specific list of competitors. This is ‘surgical’ but the list is difficult to maintain as new products/companies become successful and it’s difficult to explain.”
Or: “Reject ads for all messenger apps. This would potentially affect more advertisers, but it is easier to consistently enforce and explain, especially since it mirrors the Platform policy.”
Hoffman wanted Facebook to “reserve the right to reject ads for any reason”, including those that promote competitive products, a policy that ensured Facebook users would not be able to see ads encouraging them to download apps from competitors.
Doug Purdy, Facebook’s director of product, explained how losing developers would be treated: “There are a small number of developers whom no amount of sharing on FB or monetary value can justify giving them access to Platform,” he said.
“These developers do not want to participate in the ecosystem we have created, but rather build their ecosystem at the expense of our users, other developers and, of course, us. That is something that we will not allow.”
Surveillance and blacklisting
In Facebook’s feverish battle with competitors, one ally was crucial: Onavo, an Israeli tech intelligence company, which Zuckerberg bought in 2013.
Facebook marketed Onavo as a secure mobile phone virtual private network (VPN) to protect its users’ privacy. Users were unaware that Facebook was surreptitiously using Onavo to gather intelligence on the apps they were using.
Facebook used Onavo to monitor the popularity of competing apps, how engaged people were with them, and how many people were using them.
Olivan produced a spreadsheet based on data from 30 million Onavo users and other sources, to compare WhatsApp, Facebook Messenger and the main Facebook app downloads across different countries.
Facebook used data from Onavo to compare the engagement and reach of WhatsApp with Facebook Messenger, and Facebook’s main site.
There was some “good news” for the social network – audiences for Facebook Messenger became more engaged with the Messenger app, as more people joined Facebook.
“This signals that the quality of our app isn’t where it needs to be yet. We need to invest in performance and reliability of our app.” a draft presentation revealed.
“More bad news – we have not reached more than 40% Messenger penetration in a given country,” it said.
A highly confidential report in April 2013, drawing on data from Onavo and the market research company Neilsen, assessed the performance of Facebook Messenger against a range of rival messaging and social media apps.
It showed that, measured by volume of messages, WhatsApp was way ahead of Facebook’s mobile phone messenger service. WhatsApp was sending 8.2 billion messages a day, compared with 3.5 billion for Facebook’s mobile app.
The data identified two emerging apps in the US that also posed potential threats to Facebook. Twitter’s video service, Vine, was the most popular app in the US iTunes store, and Path, a social networking-enabled photo-sharing and messaging service for mobile devices, was ranked number two in social media.
Facebook also kept a close eye on Snapchat, a service which offers disappearing messages – and another serious competitive risk.
Shooting the messenger
Facebook’s executives became increasingly worried about how much rival messaging apps were spending on advertisements to promote themselves on Facebook.
Rivals were spending hundreds of thousands of dollars promoting their apps on Facebook’s mobile app advertising service, known internally as Neko.
In December 2012, Hoffman warned that WeChat had spent over $500,000 on Neko ads to drive downloads of its app and was accelerating its spending.
Facebook gave its rivals no warning. Nine minutes after the clock struck 9.00am on 10 January 2013, Osofsky emailed everyone to implement Zuckerberg’s ban on messenger apps advertising on Facebook, and prepared “reactive PR” to pre-empt any complaints.
Ten days after Zuckerberg’s guillotine email, Debora Liu, Facebook vice-president for platform and marketplace, informed her colleagues that WeChat and other competitive networks would no longer be advertising on Neko.
Paranoia over WhatsApp
Facebook had cut off messaging apps from data about Facebook users’ friends, and had blocked them from advertising their mobile apps on Facebook. But the social network company continued to remain paranoid about losing ground to WhatsApp.
Before Facebook acquired WhatsApp, the social network was looking at ways to reduce the messaging app’s influence on the platform. Blacklisting WhatsApp from advertising on Facebook was one option.
Mike Vernal, Facebook
“WhatsApp have apparently been placing domain ads through an agency that lead to whatsapp[.]com (rather than the app). Do we want to add them to the list of messenger apps we reject?” Hoffman wrote to the team.
In 2014, Layer, a sophisticated messaging platform for app developers, won a TechCrunch award. The award sparked conversations among Facebook executives about the merits of turning Messenger into a similar platform.
Facebook still did not take competitors lightly. “WhatsApp launching a competing platform is definitely something that makes me paranoid,” product and engineering lead Mike Vernal told his colleagues.
For Vernal, Messenger represented an “existential threat” to Facebook. He proposed a radical solution: offer all the features app developers needed “as a service”.
His idea was inspired by Amazon’s decision to make spare capacity in its datacentres available to other companies, including competitors, to run their own datacentre applications.
But Vernal proposed going further. In addition to hardware, Facebook could offer the software infrastructure to other companies to allow them to build their own social networks of users.
“We do all this to lock in mobile developers to our stack (vs iOS or Google),” he wrote.
The plan was that Facebook Messenger would become “the de facto web standard by integrating with all other apps out there”.
Zuckerberg: Get people to ditch WhatsApp
Some six years earlier, in 2007, Zuckerberg had propelled Facebook ahead of its competition by encouraging developers to build web and mobile applications on top of Facebook in return for access to Facebook users’ data.
The strategy paid off handsomely. Hundreds of thousands of developers built applications on the Facebook Platform, bringing a vastly expanded audience to the social network.
From 2007 to 2011, Facebook grew its user base from 60 million active monthly users to well over 800 million, on the back of third-party apps and features that Facebook could not hope to build itself.
Now Zuckerberg planned to use the same playbook with Facebook Messenger.
Zuckerberg wrote a long vision statement laying out plans to grow Messenger by turning it into a platform that other companies could build on. His main concern was “to get people to ditch WhatsApp and switch to Messenger”.
It would never be enough to be 10% better than WhatsApp or to offer better features, he wrote. “We will have to offer some new fundamental use case that becomes important to people’s daily lives.”
Zuckerberg’s plan was audacious – rather than simply offering a communications service, Facebook Messenger would become the “backbone” for everyone’s activity on a mobile phone.
Phone users, for example, would be able to use Messenger to make reservations at a restaurant, order food deliveries or takeaways, and to play games.
Zuckerberg was playing a long game. He talked of a future in which people would share through private messages, rather than public posts on Facebook’s timeline. “Sharing is become increasingly private,” he said. The strategy became public over five years later, in 2019, when Zuckerberg announced Facebook’s “pivot to privacy”.
Mark Zuckerberg, Facebook
Facebook would have to move fast. Rivals Line, Kakao and WhatsApp were already thinking along similar lines, Zuckerberg warned.
“When the world shifts like this, being first is how you build a brand and a network effect. We have an opportunity to do this at scale, but that opportunity won’t last forever. I doubt we even have a year before WhatsApp starts moving in this direction,” he said.
If Facebook was going to succeed, it could not hope to build the infrastructure needed to make this project succeed by itself.
Instead, Zuckerberg would leverage third-party developers to do the work for Facebook, as he did in 2007 when he encouraged developers to build apps on Facebook’s platform.
The idea, he said, was one of his most ambitious and riskiest: “With a relatively small team at Facebook, we can build a system that leverages a lot of the work outside. We could build a developer community that builds agents for virtually any task you can imagine, ranging from running errands to looking up shuttle times or other information.”
Facebook’s nuclear option
Facebook planned to test the idea by working with selected partners, such as music streaming services Spotify and Deezer and mobile phone operators.
By making deals to build exclusive integrations with other apps, Facebook would be able to differentiate Messenger from WhatsApp. It would be able to exploit network effects to compete “asymmetrically” with the “category leader”, WhatsApp.
As a further buttress against competitors, Facebook would encourage rival messaging services, such as Kik, Kakao Talk and Line, to “hook” into Messenger. That way, Zuckerberg calculated, people would be less likely to install other messaging apps alongside Facebook’s Messenger.
If all else failed, there was the nuclear option – if Facebook could not win at messaging, it would ensure no one else could.
Facebook’s fall-back idea was to turn messaging into a commodity service. It would integrate Messenger with BlackBerry Messenger, SMS text messages and Apple’s iPhone messaging service, to make messaging services a low-value ubiquitous business. The message was: “If we can’t win, commoditise.”
Facebook never had to implement its mutually assured destruction strategy. Rather than blow up its number one competitor, WhatsApp, in February 2014, Facebook bought it for some $20bn.
Secure messaging – sort of
Secure communications have been an issue for Facebook’s Messenger. WhatsApp affords users end-to-end messaging encryption, making private communications more secure. This is one feature that Facebook’s Messenger lacks, not in the least because Zuckerberg said he cooperates with law enforcement agents to prevent the use of Facebook for criminal activities.
Stung by a series of privacy scandals, including most prominently Cambridge Analytica’s use of data on Facebook users in an attempt to influence the outcome of the 2016 US election, Zuckerberg set out a vision for a privacy-focused Facebook in March 2019.
The core of Zuckerberg’s message, however, hails back to his vision to produce a Facebook Messenger Platform, which he first articulated in December 2013.
“In a few years, I expect future versions of Messenger and WhatsApp to become the main ways people communicate on the Facebook network. We’re focused on making both of these apps faster, simpler, more private and more secure, including with end-to-end encryption. We then plan to add more ways to interact privately with your friends, groups and businesses,” he wrote in a 2019 blog post.
The UK Home Department and hard Brexiteer Priti Patel wrote to him, on 4 October 2019, to object to complete end-to-end Messenger encryption and to lobby in favour of state agencies’ access to Facebook’s users’ data and private messages.
UK, Australia and US state agencies have asked Facebook to build backdoors into the company’s privacy system to allow access for crime investigators.
This can have unintended damaging consequences, given that, just two years ago, Facebook launched a messenger app for children, built partnerships with groups that discuss mental health issues via Facebook apps, and offered internet security ambassadors to secondary schools in Britain.
If Facebook is denied encryption, its messaging services may also lead to financial fraud. As Messenger encourages online payments or sending money over Messenger, it is easy to argue Facebook’s Messenger is not a safe environment for sensitive information in the absence of end-to-end encryption.
In May 2014, having eliminated the threat from WhatsApp, Zuckerberg emailed his team with a more confident memo, fleshing out his vision to turn Messenger into a business that could rival Google.
His poise was partly reassured by Facebook’s ability to spy on competitors’ strengths and weaknesses.
Messenger would become a “competitive barrier for other messaging products like WeChat that try to compete with us for either consumer attention or business dollars”, Zuckerberg wrote.
He saw a big financial opportunity in low-brow content, such as stickers or in-message games, which did well for Facebook’s competitors: “It’s easy to say these things are silly, but I think this is how WeChat and Line make 30-50% of their revenue today.”
Zuckerberg had no qualms about learning from competitors, particularly WeChat, China’s biggest messaging app.
“I imagine we’re going to need to run constant promotions like WeChat has to encourage people to pay and transfer money in different ways – gifts on new year’s, paying for taxis, investing in mutual funds, etc,” he said.
WeChat also offered a service that alerts people when their friends are in town or people are nearby who may like to meet, and Zuckerberg asked his team to develop similar features on Facebook.
Facebook could do better than WeChat, he argued. The Chinese company had taken the easy opportunities, but had failed to invest in the infrastructure that could allow it to make money from the majority of its traffic.
“They’re still doing at a bit more than ~$3 per person annually, but our goal is to reach the monetisation levels we see in News Feed of greater than $10 per person, if not more,” he said.
Turning messages into money
Those were just details in a much bigger plan to turn Messenger into a communications platform that would bring in significant advertising revenues.
Zuckerberg talked of a future where Facebook would make money by charging businesses to send direct advertising messages to users.
“A business messaging you out of the blue is where I expect most of our business to be over time,” he wrote. “If we can pull this off then we can enable experiences like you’re walking down the street and get a notification for a personalised offer to a nearby shop based on your identity and history there.”
The idea was risky. Injecting business content straight into people’s inboxes appeared “dangerous and unnatural”, Zuckerberg acknowledged. It would have to be introduced gradually over time.
As a first step, Facebook would add a “discovery tab” to Messenger that would keep business discussions separate from personal discussions.
“This is important because people will not just wake up one morning and start messaging businesses,” said Zuckerberg. “First we need to introduce the idea of business within Messenger to people and show people how they can be useful.”
Zuckerberg planned to lure businesses in slowly, with free and low-cost offers, before raising prices.
“Initially, I expect we’d highlight these businesses on Messenger for free or very cheaply. But once we have a good number in there, then the third stage of evolution for the discovery tab is to turn this into a market and start charging for paid placement.”
The discovery tab was not intended to be a permanent feature. The real money would come from businesses being able to message people directly.
This roadmap is a big stepping stone to getting people used to engaging with businesses through their Messenger inbox, Zuckerberg wrote.
Bigger than Google
Zuckerberg’s boldest idea was to build a digital assistant in Facebook that could answer questions from Messenger users.
Facebook would encourage other business to build their own meta-assistants. On the back of this, Facebook would build its own over-arching meta-assistant using the data that businesses provided.
Partnering would give Facebook a ready-made registry of which businesses knew how to answer what questions.
“With these pieces, building this meta-assistant is just a matter of enabling our special Facebook entity to answer any question that has registered a response from any other entity in our system,” he wrote.
Facebook’s meta-assistant could become more useful than Google and other search engines for helping people find what they are looking for, Zuckerberg predicted.
“If we can succeed in building the most useful assistant – for which the most important step would be getting as many businesses as possible into Messenger – then this could actually be the future of search in addition to a big part of the future of advertising and commerce,” he said.
In Zuckerberg’s vision, a user’s habits, including spending via Facebook, were going to be monitored, analysed and marketed for personalised offers. He knew back then that Facebook Messenger’s future was going to be anything but private.
To make commercial transactions work on Messenger, Facebook would need to keep credentials on file for a large percentage of its users, including credit cards and bank account information.
Facebook blocks Path
By December 2014, Facebook was placing restrictions on competitive messaging apps, but hardly in an impartial way.
“We have more restrictions imposed on Line than we have on Path,” wrote strategic partner manager Konstantinos Papamiltiadis in an email.
Facebook had ensured that Line’s access to friends’ data, photos, photo album, checking, stream read, post and group message features was restricted. Path, too, could not access photos and people’s status.
Path’s founder, Dave Morin, was unhappy with Facebook’s new policy and requested a meeting. He told Ime Archibong, Facebook’s vice-president for partnerships, that he was going to “reach out to Mark and get a sense of how he views Path these days”.
He was confirming what Facebook’s communications director, Tera Randall, wrote about him, in that he was going to be one of their suspected “noisy” developers who might kick up a fuss about the negative impact of its platform changes for developers.
Archibong didn’t share with Morin what he shared with his team: “I think Path is blacklisted from a couple of things.”
Zuckerberg could afford to buy its competitors. Following its uninhibited popularity in the messaging ecosystem, Facebook bought WhatsApp in early 2014, two years after acquiring Instagram. These are just two of its strategic mergers and acquisitions.
Before Zuckerberg could buy WhatsApp, he had to reassure antitrust regulators in the European Union (EU) that WhatsApp and Facebook platforms would not be merged. Facebook told the EU that it could not reliably match Facebook and WhatsApp user accounts.
However, it wasn’t long before WhatsApp announced the merger of the two platforms in the app’s new terms and policy details. The EU issued a fine of €110m in 2017 for supplying “incorrect or misleading information”, though the breach was not enough to overturn the EU’s authorisation of the merger.
In December 2014, Olivan’s analysis of more than 80,000 apps showed that, through its acquisition of WhatsApp, Facebook now owned the number one messaging service – a feat it would have struggled to achieve with Messenger alone.
The analysis, based on data secretly gathered from mobile phone users, showed that the app consumers were most engaged with was WhatsApp. Facebook was trailing in third place, and Facebook Messenger a distant eighth place.
Messenger was becoming one of Facebook’s main tools for building a “business ecosystem”.
In 2014, Zuckerberg had a vision for a nationwide deal proposal with Starbucks, which would let users order drinks through Messenger, or order a cab, “because it’s how WeChat started building up their payment base”.
That was just the beginning. Facebook executives were already boasting about their “titan partners” – Netflix, RBC Social Payments, Dropbox, Waze, Spotify, Nokia, BlackBerry, Rockmelt, Foursquare – in internal presentations about Facebook’s Messenger strategy. They had further plans to woo brands such as Nike, Evernote and Pinterest.
The first businesses to go live on Facebook’s “Business on Messenger” service were fashion retailers Everlane and Zulily, and software company ZenDesk.
By 2016, Facebook boasted that 34,000 developers had joined Messenger and had built 30,000 bots. Two years later, the number of active bots reached 300,000.
Fast-forward to 2019, and Messenger is now part of the corporations’ and institutions’ engagement with us – Uber, banks, schools, Vogue, sports groups, Spotify, Nike, computer manufacturers and marketing groups, you name it.
The question for regulators in the US and Europe is now whether Facebook’s dominance in messaging and its treatment of rival messaging app developers breaches antitrust and competition law.
Facebook’s vice-president and deputy general counsel, Paul Grewal, said in a statement that the Six4Three documents were selectively leaked as “part of what the court found was evidence of a crime or fraud to publish some, but not all, of the internal discussions at Facebook at the time of our platform changes. But the facts are clear: we’ve never sold people’s data”.
Facebook is facing multiple investigations. The US Federal Trade Commission (FTC), which agreed a $5m settlement with the social network in July 2019 over charges that it had misled users over the privacy of their data, is continuing a second antitrust probe into the company.
The FTC is understood to be looking at the antitrust implications of Facebook’s acquisitions, including the messaging service WhatsApp and photo- and video-sharing service Instagram. It is also expected to scrutinise Facebook’s decision to cut off data to some developers, while continuing to give access to others that either bought advertising or gave Facebook access to data on their own users.
The FTC has contacted Facebook’s competitors, according to the Wall Street Journal, including developers, tech executives and startups that were bought by Facebook, or went out of business after Facebook cut off their access to data. Lawyers for Snap, which created the Snapchat messaging app, have compiled dossiers, codenamed Project Voldemort, recording what the company believes were a series of moves by Facebook to undermine Snap’s business.
Meanwhile, the House Judiciary Subcommittee on Antitrust, Commercial and Administrative Law is examining about 7,000 pages of leaked Facebook documents for evidence of antitrust behaviour, as part of its investigation into Facebook and other big tech companies.
The House Judiciary Committee has written to Mark Zuckerberg seeking disclosure of a wide-ranging list of correspondence covering Facebook’s acquisition of Instagram, WhatsApp and Onavo. The committee has also requested details of the social media company’s decision to cut off access to data to a wide range of apps using the Facebook Platform, including messaging apps Voxer and MessageMe, and video-sharing apps Vine and Tiiny.
And 47 US attorneys general are carrying out state-level investigations into Facebook, in an inquiry led by New York State’s attorney general, Letitia James.
Documents used for this article were disclosed by Facebook and placed under seal during court proceedings brought by app developer Six4Three against Facebook in the US. Some of the sealed documents had previously been obtained by the Digital, Culture, Media and Sport (DCMS) Committee of Parliament in November 2018 as part of its investigation into “fake news”. The DCMS Committee’s hard-hitting report, published on 18 February, described Facebook and its executives as “digital gangsters”.
Facebook leaked documents in full
- Declaration by David Godkin producing 212 sealed exhibits – 16 May 2018.
- Declaration by David Godkin with 218 exhibits – 17 May 2018.
- Memorandum of points and authorities by David Godkin (with highlights) – 20 May 2018.
- Notes and summaries of Facebook discovered documents (with multiple colour highlights) – undated.