Campbell et al v. Facebook Inc.

Filing 148

Exhibits re 147 Administrative Motion to File Under Seal Documents in Support of Facebook's Opposition to Plaintiffs Motion for Class Certification filed by Facebook Inc.. (Attachments: # 1 Exhibit 9 (Unredacted), # 2 Exhibit 10 (Redacted), # 3 Exhibit 11 (Unredacted), # 4 Exhibit 12 (Redacted), # 5 Exhibit 13 (Unredacted), # 6 Exhibit 14 (Redacted), # 7 Exhibit 15 - Part 1 (Unredacted), # 8 Exhibit 15 - Part 2 (Unredacted), # 9 Exhibit 16 (Redacted), # 10 Exhibit 17 (Unredacted))(Chorba, Christopher) (Filed on 1/15/2016) Modified on 1/20/2016 (vlkS, COURT STAFF).

EXHIBIT 10
REDACTED VERSION OF DOCUMENT(S)
SOUGHT TO BE SEALED

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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MATTHEW CAMPBELL, MICHAEL HURLEY, )

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and DAVID SHADPOUR,

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)

Plaintiffs,

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) Case No.

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vs.

) C 13-05996 PJH

FACEBOOK, INC.,

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)

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Defendant.

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__________________________________ )

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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
VIDEOTAPED DEPOSITION OF JIAKAI LIU

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Palo Alto, California

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June 30, 2015

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Volume I

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Reported by:

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KELLI COMBS, CSR No. 7705

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Job No. 2094258

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Pages 1 - 256

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Page 1
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of communication did you primarily use?

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A

In what context?

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Q

In terms of electronic communication.

10:52:01AM

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I'll withdraw the question.

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So

Did you typically e-mail other members of

10:52:13AM

the Software Engineering team between 2010 and 2012?

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A

Yes.

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Q

Other than e-mail, did you use any other

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form of electronic communications such as Chat or
some sort of internal e-mail system, et cetera?

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A

Yes.

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Q

10:52:31AM

And tell me about those other means of

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communication you used.
A

Facebook Messages, that includes Chat and,

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like, non-chat Message.

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think.

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recall at this point.

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Q

That's primarily that, I

10:52:47AM

I might miss some other tool, but I couldn't

What was -- what was your e-mail address

between 2010 and 2012, your Facebook?

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A

It's [e-mail].

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Q

If you'd turn back to Exhibit Number 2 and

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you look on the second page, do you see the heading

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10:53:21AM

"Understanding Cells"?

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A

Yes.

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Q

And do you see the third bullet point

10:53:54AM
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send her a message and what's going to happen, like,

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11:44:49AM

after the request enters the first, like, Facebook

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Q
diagram.

And -- so let's -- let's walk through this
What does "

mean?

11:45:06AM

A

11:45:34AM
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Q

And then how about that next box, "Spam

Detection"; what does that mean?
A

Spam Detection means we detect whether a

message is a spam message or not.
Q

And did you play any role in creating the

11:45:47AM

Spam Detection functionality?

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A

No.

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Q

Who was primarily responsible for that?

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A

We call it Site Integrity on Facebook.

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Q

And did you have a primary point of

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contact in the Site Integ- -- on the Site Integrity

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11:46:05AM

team between 2010 and 2012?

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A

I didn't personally.

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Q

Did you write any code that dealt with

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I couldn't remember.

spam detection in the Messages product?

11:46:23AM
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A

1:22:09PM

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Q

Let's -- let's turn just for one few more

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questions back to Exhibit Number 3.

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go to the -- that diagram on the second page, the

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"Incoming Flow" diagram.

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about spam detection earlier, and you indicated that

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Site Integrity was primarily responsible for that.

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10

And I want to
1:23:34PM

And we talked a little bit

Do you know whether Facebook does any
malware detection on incoming messages?

1:24:02PM

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A

I don't know.

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Q

Don't know?

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A

I don't.

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Q

And just so we're clear, do you know

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whether they did any malware scanning of incoming

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messages between January 1st, 2010, and January 1st,

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2013?

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A

I don't have firsthand knowledge.

1:24:15PM

Yeah, I

don't have firsthand knowledge.
Q

Do you ever recall having any discussions

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with anyone about any malware scanning that Facebook

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1:24:36PM

was doing?

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MR. JESSEN:

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THE WITNESS:

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Object to form.
I couldn't recall now.

It

might, but because it's, like, four, five years ago,

1:24:52PM
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I couldn't recall now.

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BY MR. CARNEY:

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Q

Do you recall whether you were -- ever

wrote any code dealing with malware scanning?

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1:24:55PM

A

I couldn't remember at this point.

I

1:25:15PM

couldn't remember.

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Q

Do you know whether Facebook does any

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scanning to protect the site from hackers?

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that.

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Strike

Do you know whether Facebook did any

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scanning to protect the site from hackers between

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1:25:34PM

January 1st, 2010, January 1st, 2013?

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A

I think that's what Site Integrity team

does -- did; that's their job detail.
Q

Did you have any discussions with anyone

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at the Site Integrity team regarding their efforts

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to prevent or protect the site from hackers related

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1:25:52PM

to the Messages product?

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A

I couldn't remember the exact

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conversation.

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something, but I couldn't remember.

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Q

I might be in some e-mail thread or

1:26:10PM

Do you recall whether you wrote any code

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dealing with efforts to protect the site from

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hackers?

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A

I couldn't remember.

1:26:31PM
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June 30, 2015

Jiakai Liu

Date of deposition:

Witness:

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Street address is
Q. And what type of software did you build at
Google?
A. It varies. For example, I worked on Google
Book Search for a while and then because the
Web -- because the Web is like the photo service
and a few other things.
Q. Can you tell me what their names are?
A. One of them was Hary Wang, H-A-R-Y WA-N-G.
A. Kannan, K-A-N-N-A-N; Karthic, Karthic.
Q. Who was your boss on the Home team?
A. It was Tom Addison.
Q. Is Mr. Addison still your boss?
A. No.
Q. Why did you write it?
A. Same reason as, like, this block post.
And when the reviewers are happy, like,

Reads

To clarify the record.
To conform to the facts.
To correct transcription errors.

Page

1.
2.
3.

Reason codes:

Campbell et al. v. Facebook, Inc.
Case No. 13-CV-05996-PJH

In the Matter of:

Street address is
Q. And what type of software did you build at
Google?
A. It varies. For example, I worked on Google
Book Search for a while and then Picasa Web
which is like the photo service and a few other
things.
Q. Can you tell me what their names are?
A. One of them was Harry Wang, H-A-R-R-Y WA-N-G.
A. Kannan, K-A-N-N-A-N; Karthik.
Q. Who was your boss on the Home team?
A. It was Tom Alison.
Q. Is Mr. Alison still your boss?
A. No.
Q. Why did you write it?
A. Same reason as, like, this blog post.
And when the reviewers are happy, like, satisfied,

Should Read

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Reason
Code
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