Campbell et al v. Facebook Inc.

Filing 149

RESPONSE (re 138 MOTION to Certify Class ) Opposition to Plaintiffs Motion for Class Certification (Redacted) filed byFacebook Inc.. *** ATTACHMENTS 1, 7 LOCKED AT FILER'S REQUEST. SEE DOCUMENT 162 *** (Attachments: # 1 Declaration Declaration of Christopher Chorba In Support of Defendant Facebook, Inc.s Opposition to Plaintiffs Motion for Class Certification (Redacted), # 2 Declaration Declaration of Alex Himel In Support of Defendant Facebook, Inc.s Opposition to Plaintiffs Motion for Class Certification (Redacted), # 3 Declaration Declaration of Dan Fechete In Support of Defendant Facebook, Inc.s Opposition to Plaintiffs Motion for Class Certification (Redacted), # 4 Exhibit Expert Report of Dr. Benjamin Goldberg (Redacted), # 5 Exhibit Exhibit BBB to Expert Report of Dr. Benjamin Goldberg, # 6 Exhibit Exhibit CCC to Expert Report of Dr. Benjamin Goldberg, # 7 Exhibit Expert Report of Dr. Catherine Tucker (Redacted), # 8 Exhibit Exhibit DDD to Expert Report of Dr. Catherine Tucker, # 9 Exhibit Exhibit EEE - Expert Report of Dr. Catherine Tucker, # 10 Exhibit Exhibit FFF - Expert Report of Dr. Catherine Tucker, # 11 Exhibit Exhibit GGG - Expert Report of Dr. Catherine Tucker, # 12 Exhibit Exhibit HHH - Expert Report of Dr. Catherine Tucker, # 13 Exhibit Exhibit III - Expert Report of Dr. Catherine Tucker, # 14 Exhibit Exhibit JJJ - Expert Report of Dr. Catherine Tucker)(Chorba, Christopher) (Filed on 1/15/2016) Modified on 1/22/2016 (ewn, COURT STAFF). Modified on 1/22/2016 (vlkS, COURT STAFF).

EXHIBIT BBB

Curriculum Vitae

BENJAMIN F. GOLDBERG
Courant Institute of Mathematical Sciences
Department of Computer Science
New York University
251 Mercer Street
New York, New York 10012
Phone: [phone]
Fax: [phone]
Email: [e-mail]
http://cs.nyu.edu/goldberg

Personal
Born January 31, 1961, Las Cruces, New Mexico.
U.S. Citizen.
Education
Ph.D. in Computer Science, Yale University, 1988. Dissertation: "Multiprocessor Execution of
Functional Programs."
M.S. and M.Phil in Computer Science, Yale University, 1984.
B.A. with Highest Honors in Mathematical Sciences, Williams College, Cum Laude, Phi Beta
Kappa, Sigma Xi, June 1982. Honors Thesis: "Theory and Implementation of an Automatic
Program Verifier."
Employment
Associate Professor (Tenured), Courant Institute of Mathematical Sciences, Department of
Computer Science, New York University. September 1994 – Present.
Invited Professor, Ecole Normale Supérieur, Paris, France. June 2007 – July 2007 and
June 2003 – July 2003.
Director of Graduate Studies (for the MS programs), Department of Computer Science, New York
University. September 2009 – August 2012 and September 2014 – present.
Director of Undergraduate Studies, Department of Computer Science, New York University.
September 1995 – August 1998 and September 2003 – August 2006.
Visiting Professor, Institute National de Recherche en Informatique et en Automatique (INRIA),
Rocquencourt, France. September 1994 – August 1995.
Assistant Professor, Courant Institute of Mathematical Sciences, Department of Computer
Science, New York University. September 1987 - August 1994.

Expert Testimony at Trial or Deposition in the Past Four Years
Retained by Jones Day on behalf of Kyocera in the matter of Wi-LAN v. Kyocera, February 2015 –
present.
Retained by Kaye Scholer on behalf of Google in the matter of ContentGuard v. Google (Covered
Business Method patent review before the USPTO). August 2014-September 2015.
Retained by Orrick on behalf of EMC in the matter of Oasis v. EMC et al., June 2014 – September
2015.
Retained by Fulbright & Jaworski on behalf of Qualcomm in the matter of Certain Consumer
Electronics and Display Devices with Graphics Processing and Graphics Processing Units Therein
(NVIDIA v. Qualcomm). International Trade Commission, December 2014 – June 2015.
Retained by Orrick on behalf of EMC and VMware in the matter of Clouding v. EMC et al. (Inter
Partes Review before the USPTO), June 2014 – July 2015.
Retained by Quinn Emanuel and Perkins Coie on behalf of Samsung, Google, and HTC in the
matter of Smartflash v. Samsung et al. April 2014 – present.
Retained by Kenyon & Kenyon on behalf of Advanced Ground Information Systems (AGIS) in the
matter of AGIS v. Life360 (Patent Litigation). August 2014 – November 2014.
Retained by Milbank Tweed on behalf of Apple in the matter of Wi-LAN v. Apple, February 2014 –
September 2014.
Retained by Boies Schiller on behalf of InfoSpan in the matter of InfoSpan v. Emirates NBD Bank,
September 2013 – present.
Retained by Boies Schiller on behalf of Apple in the matter of Apple v. Personal Web Technologies
(Inter Partes Review before the PTO), August 2013 – July 2014.
Retained by Cooley on behalf of Apple in the matter of GBT v. Apple, October 2013 – June 2014.
Retained by Quinn Emanuel on behalf of Toshiba in the matter of Certain Digital Media Devices,
Including Televisions, Blu-Ray Disc Players, Home Theater Systems, Tablets and Mobile Phones,
Components Thereof and Associated Software (Black Hills Media v. Toshiba et al). International
Trade Commission. September 2013 – February 2014.
Retained by Wilson Sonsini on behalf of Sasken in the matter of Sasken v. Spreadtrum. American
Arbitration Association. July 2013 – January 2014.
Retained by Sheppard Mullin on behalf of HTC and Apple in the matter of Wi-LAN v. HTC et al.
June 2013 – October 2013.
Retained by Bingham McCutchen on behalf of Oracle America in the matter of Oracle America v.
Service Key et al. March 2013 – September 2013.
Retained by Latham & Watkins on behalf of InterDigital Communications, Inc. in the matter of
Certain Wireless Devices with 3G Capabilities and Components Thereof (InterDigital v. Huawei et
al). International Trade Commission, December 2011 – February 2013.
Retained by Ballard Spahr on behalf of Go Daddy in the matter of WhitServe v. Go Daddy. August
2011 – June 2013.

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Retained by Kenyon & Kenyon on behalf of Barnes & Noble in the matter of Deep9 v. Barnes &
Noble. February 2012 – August 2012.
Retained by Gibson Dunn & Crutcher on behalf of Lawson Software in the matter of ePlus v
Lawson Software. October 2011 – April 2013.
Retained by Kenyon & Kenyon on behalf of Barnes & Noble in the matter of Certain Handheld
Electronic Computing Devices, Related Software, and Components Thereof (Microsoft v. Barnes &
Noble), International Trade Commission. August 2011 – February 2012.
Retained by Morrison & Foerster on behalf of Oracle America in the matter of Oracle America v.
Google. August 2011 – May 2012.
Retained by Jones Day on behalf of Nielsen in the matter of comScore v. Nielsen et al. May 2011
– November 2011.
Teaching Awards
New York University "Golden Dozen" Award, 1992. Awarded to twelve faculty members in the
entire College of Arts and Sciences for excellence in teaching.
Professional Activities
Editorial Board, The Computer Journal. Published by Oxford University Press on behalf of the
British Computer Society. 2007 – 2009.
Program Committee member: 2007 Symposium on Principles of Programming Languages (POPL)
External Review Committee member: 2013 Symposium on Principles of Programming Languages
(POPL)
Program Committee member: 2001 Workshop on Practical Applications of Declarative Languages
(PADL'01), ACM SIGPLAN'95 Conference on Programming Language Design and
Implementation, 1995 ACM SIGPLAN Symposium on Partial Evaluation and Semantics-Based
Program Manipulation (PEPM '95), 1995 International Workshop on Memory Management
(IWMM'95), ACM SIGPLAN'93 Conference on Programming Language Design and
Implementation.
Review Panel Member, National Science Foundation, January 1998 and January 2000.
Official Collaborator, Los Alamos National Laboratory, Computing and Communications Division.
Member, Association for Computing Machinery and ACM Special Interest Group on Programming
Languages (SIGPLAN).
Referee for: ACM TOPLAS, IEEE Computer, International Journal of Parallel Programming,
Software Practice and Experience, Computational Intelligence, ACM TOCS, ACM Computing
Surveys, etc.
Referee for a variety of ACM and IEEE conferences.
Journal Papers
"Translation and Run Time Validation of Optimized Code'', with L. Zuck, A. Pnueli, C. Barrett, Y.
Fang, and Y. Hu, Formal Methods in System Design. 27(3): 335-360, November 2005

3

"VOC: A Methodology for Translation Validaton of Optimizing Compilers'', with L. Zuck, A. Pnueli,
and Y. Fang. Journal of Universal Computer Science, March 2003.
"A Syntactic Method for Finding Least Fixed Points of Higher-Order Functions over Finite
Domains", with Tyng-Ruey Chuang. Journal of Functional Programming. Vol. 7, No. 4, pp. 357394, July 1997
"Functional Programming Languages", in ACM 50th Anniversary Issue of Computing Surveys.
March 1996.
"Order-of-demand analysis for lazy languages", with Young-Gil Park. Information Processing
Letters, Vol. 55, 1995, pp. 343-348.
"Static Analysis for Optimizing Reference Counting", with Young-Gil Park. Information Processing
Letters, Vol. 55, 1995, pp. 229-234.
"Multiprocessor Execution of Functional Programs", International Journal of Parallel Programming,
Vol. 17, No. 5, October 1988.
"Distributed Execution of Functional Programs Using Serial Combinators," with P. Hudak, IEEE
Transactions on Computers, Vol. C-34, No. 10, October 1985, pp. 881-891.
Books or Chapters in Books
"Functional Programming Languages", in Handbook of Computer Science and Engineering, CRC
Press, Inc. 1996.
Publications in Proceedings of Refereed Symposia
“Translation Validation of Loop Optimizations and Software Pipelining in the TVOC Framework”.
Proceedings of the 17th International Static Analysis Symposium (SAS 2010), September 2010.
“TVOC: A translation validator for optimizing compilers”, with C. Barrett, Y. Fang, Y. Hu, A.Pnueli,
and L. Zuck. Proceedings of the 17th International Conference on Computer Aided Verification
(CAV '05), July 2005.
"Theory and algorithms for the generation and validation of speculative loop optimizations", with Y.
Hu and C. Barrett. Proceedings of the 2nd IEEE International Conference on Software Engineering
and Formal Methods (SEFM), September 2004.
"Into the Loops: Practical Issues in Translation Validation for Optimizing Compilers", with L. Zuck
and C. Barrett. Proceedings of the Third International Workshop on Compiler Optimization meets
Compiler Verification (COCV). April 2004.
"Run-Time Validation of Speculative Optimizations using CVC", with C. Barrett and L. Zuck.
Proceedings of the Workshop on Runtime Verification 2003, ENTCS 89(2). July 2003.
"Software Bubbles: Using Predication to Compensate for Aliasing in Software Pipelines'', with E.
Chapman, C. Huneycutt, and K. Palem. Proceedings of the PACT-2002 International Conference
on Parallel Architectures and Compilation Techniques, September 2002.
"Translation and Run-Time Validation of Optimized code'', with L. Zuck, A. Pnueli, Y. Fang, and Y.
Hu. Proceedings of the Workshop on Runtime Verification 2002, ENTCS 70(4). July 2002.

4

"VOC: A Translation Validator for Optimizing Compilers''. Proceedings of the Workshop on
Compiler Optimization Meets Compiler Verification (COCV) 2002, ENTCS 65(2). April 2002.
"Formal Models of Distributed Memory Management", with Cristian Ungureanu. Proceedings of
the ACM International Conference on Functional Programming, June 1997.
"Partial Evaluation of Concurrent Programs", with Mihnea Marinescu. Proceedings of the ACM
Symposium on Partial Evaluation and Program Manipulation, June 1997.
"Real-Time Deques, Multihead Turing Machines, and Purely Functional Programming", with T-R.
Chuang. Proceedings of the 1993 ACM Conference on Functional Programming Languages and
Computer Architecture, June 1993.
"Polymorphic Type Reconstruction for Garbage Collection without Tags", with M. Gloger.
Proceedings of the 1992 ACM Conference on LISP and Functional Programming, June 1992.
"A Syntactic Approach to Fixed Point Computation on Finite Domains", with T.R. Chuang.
Proceedings of the 1992 ACM Conference on LISP and Functional Programming, June 1992.
"Escape Analysis on Lists", with Y.G. Park. Proceedings of the 1992 ACM SIGPLAN Conference
on Programming Language Design and Implementation, June 1992.
"Incremental Garbage Collection without Tags", Proceedings of the 1992 European Symposium on
Programming, February 1992.
"Reference Escape Analysis: Optimizing Reference Counting based on the Lifetime of
References", with Y.G. Park. Proceedings of the 1991 ACM/IFIP Conference on Partial Evaluation
and Program Manipulation, June 1991.
"Tag-Free Garbage Collection for Strongly Typed Programming Languages", Proceedings of the
ACM SIGPLAN'91 Conference on Programming Language Design and Implementation, June
1991.
"Higher Order Escape Analysis: Optimizing Stack Allocation in Functional Program
Implementations", Proceedings of the 1990 European Symposium on Programming, May 1990.
Springer-Verlag LNCS 432, pp. 152-160.
"Generational Reference Counting: A Reduced-Communication Distributed Storage Reclamation
Scheme", Proceedings of the SIGPLAN'89 Conference on Programming Language Design and
Implementation, June 1989.
“A Reduced-Communication Storage Reclamation Scheme for Distributed Memory
Multiprocessors", Proceedings of the Fourth Conference on Hypercubes, Concurrent Computers,
and Applications, January 1989.
"Buckwheat: Graph Reduction on a Shared Memory Multiprocessor", Proceedings of the 1988
ACM Symposium on Lisp and Functional Programming, July 1988, pp. 40-51.
"Executing Functional Programs on a Hypercube Multiprocessor", Proceedings of the Third
Conference on Hypercube Concurrent Computers and Applications, January 1988.
"Detecting Sharing of Partial Applications in Functional Programs", Proceedings of the Conference
on Functional Programming Languages and Computer Architecture, September 1987. Published
in the Springer-Verlag Lecture Notes in Computer Science, Vol. 274, pp. 408-425.

5

"Serial Combinators: "Optimal" Grains of Parallelism", with P. Hudak, Proceedings of the IFIP
Conference on Functional Programming Languages and Computer Architecture, September 1985.
Published in the Springer-Verlag Lecture Notes in Computer Science, Vol. 201, pp. 382-389.
"Experiments in Diffused Combinator Reduction," with P. Hudak, Proceedings of the ACM
Symposium on Lisp and Functional Programming, August 1984, pp. 167-176.
Keynote Addresses, Invited Talks and Tutorials
Keynote Address, "Software Pipelining and Loop Optimizations in the Presence of Memory
Aliasing'', 8th Workshop on Compiler Techniques for High Performance Computing, Hualien,
Taiwan, March 2002.
Invited Talk, ''Translation Validation of Loop Optimizations'', Ecole Normale Supérieur, Paris.
July 2003.
Invited tutorial, ''The Trimaran Compiler Research Infrastructure'', given at at the following
conferences:
•   IEEE Symposium on Parallel Architectures and Compiler Techniques (PACT'98), Paris,
October 1998.
•   IEEE Symposium on Microarchitecture (MICRO-31), Dallas, December 1998.
•   1999 ACM SIGPLAN Conference on Programming Language Design and Implementation
(PLDI'99), Atlanta, June 1999.
Tutorial, ''Functional Programming'', 1994 ACM SIGPLAN Conference on Programming Language
Design and Implementation (PLDI'94). Orlando, June 1994.
Research Grants and Contracts
“Property-Based Development of reactive and Embedded Systems”, with A. Pnueli and L. Zuck.
National Science Foundation, August 2007 – May 2009.
“PTV: Translation Validation in the Phoenix Compiler Framework”, with A. Pnueli (coordinated
proposal with L. Zuck of U. Illinois-Chicago). Microsoft, April 2006.
"A Methodology for Establishing the Dependability and Security of Telecommunication Protocols",
with A. Pnueli and L. Zuck. Office of Naval Research, July 2003 – June 2005.
"Towards a Seamless Process for the Development of Embedded Systems'', with A. Pnueli and L.
Zuck. National Science Foundation, September 2002 - August 2005.
''Translation Validation of Advanced Compiler Optimizations'', with L. Zuck and A. Pnueli. National
Science Foundation, June 2001 – May 2006.
''Algorithmic Techniques for Compiler Controlled Caches'', with K. Palem. Air Force, July 1999 June 2002.
''Parallel Extensions of the MSTAR System'', with E. Freudenthal. AFOSR, August 1999 - July,
2001.
''A Computational Laboratory for Automatic Target Recognition'', with D. Geiger and E.
Freudenthal. AFOSR, March 1998 - March 1999.

6

''Mobile and Stationary Target Acquisition and Recognition'', DARPA/Air Force, June 1997March 2000.
"An Integrated Parallel Programming Environment for High Performance Parallel Computing on
Workstation Clusters", Department of Energy. May 1994. With Los Alamos National Laboratory
and IBM.
"GRIFFIN - A Common Prototyping Language: Design, Implementation, and Assessment", with R.
Dewar, M. Harrison, E. Schonberg and D. Shasha. DARPA/Office of Naval Research, May 1992 April 1995.
"Research Training in Software Prototyping Languages and Environments". DARPA/ONR May
1992 - April 1995.
"Studies in Automatic Dynamic Load Balancing on Large Loosely-Coupled Multiprocessors",
National Science Foundation Research Initiation Award. September 1989 - June 1992.
"GRIFFIN: a Common Prototyping Language", with R.Dewar, E. Schonberg, M. Harrison, and D.
Shasha. DARPA/ONR September 1989 - April 1992.
New Courses Developed
“Object Oriented Programming”. An undergraduate course covering Java, C++, UML, and object
oriented programming techniques. Also developed an MS-level OOP course.
"The Design and Programming of Embedded Systems''. A graduate course addressing the
computing hardware and software designs in handheld devices, cell phones, appliances, etc.
"Compilers for Advanced Computer Architectures". A graduate course in optimization techniques
for emerging microprocessors.
"Honors Programming Languages''. A Ph.D. course in Programming Language Design and theory.

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