Campbell et al v. Facebook Inc.

Filing 150

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 18 (Redacted), # 2 Exhibit 19 (Unredacted), # 3 Exhibit 20 (Redacted), # 4 Exhibit 21 (Unredacted), # 5 Exhibit 22 (Unredacted), # 6 Exhibit 23 (Unredacted), # 7 Exhibit 24 (Unredacted), # 8 Exhibit 25 (Unredacted), # 9 Exhibit 26 (Unredacted), # 10 Exhibit 27 (Unredacted))(Chorba, Christopher) (Filed on 1/15/2016) Modified on 1/20/2016 (vlkS, COURT STAFF).

EXHIBIT 20
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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MATTHEW CAMPBELL, MICHAEL

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HURLEY, and DAVID SHADPOUR,

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on behalf of themselves and

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all others similarly situated,

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Plaintiffs,
vs.

No. 4:13-cv-05996-PJH

FACEBOOK, INC.,

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Defendants.
________________________________

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**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**

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**CONTAINS SOURCE CODE**

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VIDEOTAPED 30(b)(6) DEPOSITION OF

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MICHAEL ADKINS

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Wednesday, October 28, 2015

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Reported by:

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COREY W. ANDERSON

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CSR No. 4096

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Job No. SF 2173701A

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And I saw that earlier prior to the

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deposition and at the beginning of it you were doing

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something with the computer.

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initially?

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Q.

A.

Okay.

What were you doing

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The source code as delivered appeared to

be compressed.

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Q.

Uh-huh.

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A.

And when compressed into a single archive

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you cannot inspect the individual files.

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So I decompressed it onto the file system

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of the computer in the event that I would need to

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access the individual source files for the purposes

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of the deposition.

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Q.

As part of your preparation for this

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deposition, did you review the source code that

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specifically relates to topic 1 (c)?

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A.

I reviewed the source code for

and

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Q.

Okay.

Can you please identify the source

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code that carries out the processes characterized in

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section 1 (c)?

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A.

Yes.

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Q.

Please do.

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A.

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,

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.

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.
Q.

I believe you said that the

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?

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A.

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Yes.

So if you are using an online

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product, and let's say you are writing the name of a

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person you know or you are typing an e-mail address,

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the product might have a list of recognizable search

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terms which it would then offer to fill in for you

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so you do not have to type the entire name or

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address.

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Q.

During the 2010 to 2012 timeframe when

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A.

This is

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Q.

And where is it located?

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A.

It is in

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.

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Q.

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.

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What are the relevant features that

has to take into account?
A.

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Relevant features

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.

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.

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.

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Q.

The

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A.

Uh-huh.

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Q.

That's one of the files we were looking

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at.

?

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Where --

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A.

That is this file.

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Q.

That's this file?

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A.

Yes.

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Q.

Where is the

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A.

That's it (indicating).

in this?

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.

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.
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So the Facebook abuse- and

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security-related platform that's referenced in this

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section?

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A.

Uh-huh.

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Q.

Is

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A.

I would say that is

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Q.

?

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.

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A.

Those would be the ones we previously

discussed:
Q.

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sigma, et cetera.

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Which, what's the name of the
?

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A.

The name of the

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Q.

Uh-huh.

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A.

It is simply called

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Q.

Okay.

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?

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.

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And what does that function

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perform?
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That is simply the

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.

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A.

Uh-huh.

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Q.

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States

,

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."

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Is that correct?

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A.

That is correct.

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Q.

What are the

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that are

being referred to here?

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A.

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Q.

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Where is the source code that carries out

this functionality?

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A.

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.

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Q.

What

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would be available to the

integrity and abuse- and security-related platforms?
A.

that -- and I'm

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not sure that "

" is quite the correct

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word, it's probably just more like

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What format was the

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stored in?

Q.

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A.

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Q.

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I believe it would be

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Okay.

And where does that

?

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A.

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.

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Q.

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?

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And where are the
I'm sorry, withdrawn.

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?
A.

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They are similar to

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