Van Valin et al v. Google, Inc.

Filing 10

Declaration of Alexander Stamos. Filed by Google, Inc.. (Related document(s): Response to Motion 9 .) (Aldisert, Robert)

Robert L. Aldisert, OSB No. 940433 RAldisert@,perkinscoie.com Julia E. Markley, OSB No. 000791 [e-mail] PERKINS COTE I,LP I 120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4128 Telephone: [phone] Facsimile: 503.727.2222
Attorneys for Defendant Google Inc.

UNITED STATES DISTRICT COURT
DISTRICT OF OREGON PORTLAND DIVISION
VlCKI VAN VALIN, on behalf of herself and all others similarly situated within the state of Oregon; NEIL MERTZ. on behalf of himself and all others similarly situated within the state of Washington,
Plaintiffs,

DECLARATION OF ALEXANDER STAMOS

GOOGLE INC., a Delaware corporation,
Defendant.

1, Alexander Starnos, declare under penalty of perjury as follows: 1.

I have personal knowledge of the facts set forth in this declaration and am

competent to testify.

1-

DECLARATION OF ALEXANDER STAMOS

Perkins Coie LLP 1 120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4 128

LEGAL?83694.64 1

Phone: [phone] Fax: [phone]

2.

iSEC Partners (iSEC) is an infomation security consulting firm headquartered in

San Francisco, with offices in SeattIe and New York. Our work includes software assurance, infrastructure penetration testing, code review, incident response and forensics. Our clients

incIude Microsoft, Oracle, eBay, McKesson, Salesforce.com, Autodesk, Charles Schwab,
JPMorgan Chase, ING Direct and Motorola.
3.

1 am a Partner and one of the founders of the company, which we started in

October 2004. Before founding iSEC Partners I worked as a Managing Security Consultant with the security consultancy @stake, and I was the security lead at Loudcloud, a managed hosting

provider. I have also worked for the EO Lawrence Berkeley NationaI Laboratory. I hold a BS in
Electrical Engineering and Computer Science fiom the University of CaIifornia, Berkeley, where my studies included graduate classes in networking and computer security. 1 was awarded a
Certified Information Systems Security Professional (CISSP) certification in 2002. I am a

frequent speaker at leading security and technology conferences, such as Black Hat USA,

CanSecWest, Microsoft BlueHat, the Web 2.0 Expo, CTIA,OWASP App Sec, and the Financial
Services Information Sharing and Analysis Center (FS-ISAC). I have also spoken on the topic of

computer forensics to private audiences at the FBT's Regional Computer Forensics Laboratory,
and the Federal Reserve Banks in New York and Boston.
4.

I understand that Plaintiffs in this matter seek to assure that Google does not

destroy or alter any of the payload data it has collected for any person or entity within the states

of Oregon and Washington. iSEC Partners was retained by Google on May 14' in connection Google provided me with four hard drives on which with the handling of such data. On May 1 5 ' ~

Google had loaded Wi-Fi payload data for all countries from which it had collected such data. I
created two new encrypted drives to store this data and recorded cryptographic hashes of the original files to guard against intentional or unintentional corruption of the data. I then destroyed
the original four drives. Since then, I have placed what Google ha$ identified as the United States data on a single encrypted hard drive and verified the hashes to insure data was not

modified when copied. I then securely deIeted the transferred United States data h r n what is now the "World except the US" drive. I have also securely stored on machines controlled by
iSEC Partners the hash and file name information that prevents tampering. The encryption keys

Perkins Coie LLP 1 120 N.W.Couch Street, Tenth Floor Portland, OR 97209-4 1128

Phone: [phone] Fax: [phone]

for these drives are possessed by only myself and one other person and the hard drives are
securely stored in a safe controlled by Google's physical security team.

is true and correct.

SIGNED at

m
this 23rd day of May, 2010.
AIexander tamos

3-

DECLARATION OF ALEXANDER STAMOS

Perkins Coie LLP 1 120 N.W. Couch Street, Tenth Floor

LEGhL18369444.1

Portland, OR 97209-4 128 Phone: [phone] Fax: [phone]