Campbell et al v. Facebook Inc.

Filing 160

EXHIBITS re 149 Opposition/Response to Motion,,,,, filed byFacebook Inc.. (Attachments: # 1 Chorba Decl. - Exhibit Y, # 2 Chorba Decl. - Exhibit Z, # 3 Chorba Decl. - Exhibit AA, # 4 Chorba Decl. - Exhibit BB (Redacted), # 5 Chorba Decl. - Exhibit CC (Redacted), # 6 Chorba Decl. - Exhibit DD (Redacted), # 7 Chorba Decl. - Exhibit EE (Redacted), # 8 Chorba Decl. - Exhibit FF (filed under seal), # 9 Chorba Decl. - Exhibit GG (filed under seal), # 10 Chorba Decl. - Exhibit HH (filed under seal), # 11 Chorba Decl. - Exhibit II (Redacted), # 12 Chorba Decl. - Exhibit JJ (Redacted), # 13 Chorba Decl. - Exhibit KK (filed under seal), # 14 Chorba Decl. - Exhibit LL (filed under seal))(Related document(s) 149 ) (Chorba, Christopher) (Filed on 1/16/2016)

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

1

UNITED STATES DISTRICT COURT

2

NORTHERN DISTRICT OF CALIFORNIA

3

MATTHEW CAMPBELL, MICHAEL

4

HURLEY, and DAVID SHADPOUR,

5

on behalf of themselves and

6

all others similarly situated,

7
8
9

Plaintiffs,
vs.

No. 4:13-cv-05996-PJH

FACEBOOK, INC.,

10
11

Defendants.
________________________________

12
13

**HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY**

14

**CONTAINS SOURCE CODE**

15
16

VIDEOTAPED 30(b)(6) DEPOSITION OF

17

MICHAEL ADKINS

18

Wednesday, October 28, 2015

19
20
21

Reported by:

22

COREY W. ANDERSON

23

CSR No. 4096

24

Job No. SF 2173701A

25

PAGES 1 - 124
Page 1
Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

And I saw that earlier prior to the

10:46:31

2

deposition and at the beginning of it you were doing

10:46:37

3

something with the computer.

10:46:41

4

initially?

5
6

Q.

A.

Okay.

What were you doing

10:46:45
The source code as delivered appeared to

be compressed.

10:46:47
10:46:49

7

Q.

Uh-huh.

10:46:51

8

A.

And when compressed into a single archive

10:46:53

9

you cannot inspect the individual files.

10

10:46:56

So I decompressed it onto the file system

10:47:01

11

of the computer in the event that I would need to

10:47:04

12

access the individual source files for the purposes

10:47:07

13

of the deposition.

10:47:10

14

Q.

As part of your preparation for this

10:47:11

15

deposition, did you review the source code that

10:47:31

16

specifically relates to topic 1 (c)?

10:47:35

17

A.

I reviewed the source code for

and

18
19

10:47:38
10:47:43

Q.

Okay.

Can you please identify the source

10:47:43

20

code that carries out the processes characterized in

10:47:56

21

section 1 (c)?

10:48:01

22

A.

Yes.

10:48:09

23

Q.

Please do.

10:48:10

24

A.

10:48:49

25

10:48:51
Page 45

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

11:04:15

2

11:04:24

3

11:04:29

4

11:04:35

5

11:04:40

6

11:04:45

7

11:04:48

8

11:04:53

9

,

10

11:04:54
11:05:01

11

.

11:05:06

12

11:05:12

13

11:05:13

14
15

.
Q.

I believe you said that the

16

11:05:20
11:05:22
11:05:27

17

?

18

A.

11:05:30
Yes.

So if you are using an online

11:05:33

19

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

11:05:36

20

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

11:05:39

21

the product might have a list of recognizable search

11:05:46

22

terms which it would then offer to fill in for you

11:05:50

23

so you do not have to type the entire name or

11:05:53

24

address.

11:06:01

25

Q.

During the 2010 to 2012 timeframe when

11:06:02
Page 54

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

A.

This is

2

Q.

And where is it located?

12:06:22

3

A.

It is in

12:06:23

4

.

5

Q.

6
7

.

12:06:28
What are the relevant features that

has to take into account?
A.

12:06:17

12:06:36
12:06:38

Relevant features

12:06:41

8

12:06:43

9

12:06:48

10

12:06:51

11

12:06:53

12

12:06:55

13

12:06:58

14

12:07:01

15

12:07:05

16

12:07:07

17

12:07:11

18

12:07:15

19

12:07:20

20

12:07:22

21

12:07:23

22

12:07:26

23

12:07:28

24

.

25

12:07:30
12:07:35
Page 75

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

.

12:07:38

2

12:07:49

3

12:07:53

4

12:07:56

5

12:08:00

6

12:08:02

7

12:08:06

8

.

12:08:08

9

12:08:15

10

.

12:08:20

11

Q.

The

12

A.

Uh-huh.

12:08:39

13

Q.

That's one of the files we were looking

12:08:40

14

at.

?

12:08:37

Where --

12:08:41

15

A.

That is this file.

12:08:42

16

Q.

That's this file?

12:08:43

17

A.

Yes.

12:08:44

18

Q.

Where is the

19

A.

That's it (indicating).

in this?

12:08:44
12:08:49

20

12:08:55

21

12:09:02

22

12:09:05

23

12:09:08

24

12:09:11

25

12:09:21
Page 76

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

12:09:25

2

12:09:28

3

12:09:31

4

.

12:09:34

5

12:09:35

6
7

.
Q.

12:09:38

So the Facebook abuse- and

12:09:45

8

security-related platform that's referenced in this

12:09:47

9

section?

12:09:52

10

A.

Uh-huh.

12:09:53

11

Q.

Is

12

A.

I would say that is

13

Q.

?

12:09:53
.

12:09:55

12:10:01
15
16
17

A.

Those would be the ones we previously

discussed:
Q.

12:10:03

sigma, et cetera.

12:10:05

Which, what's the name of the
?

12:10:48

19

A.

The name of the

20

Q.

Uh-huh.

21

A.

It is simply called

22

Q.

Okay.

23
24

?

12:10:51
12:10:53
.

12:10:54

And what does that function

12:10:56

perform?
A.

12:11:00
That is simply the

25

12:11:01
.

12:11:05
Page 77

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

A.

Uh-huh.

2

Q.

13:44:52

States

,

13:44:54

3

13:44:56

4

13:45:00

5

13:45:02

6

13:45:05

7

13:45:07

8

."

9

Is that correct?

13:45:13
13:45:14

10

A.

That is correct.

11

Q.

What are the

12
13

13:45:10

that are

being referred to here?

13:45:21
13:45:24

A.

13:45:26

14

13:45:30

15

13:45:33

16

13:45:37

17

13:45:41

18

13:45:44

19

13:45:48

20
21
22
23

.
Q.

13:45:51

Where is the source code that carries out

this functionality?

13:46:05
13:46:07

A.

13:46:11

24

13:46:13

25

13:46:16
Page 118

Veritext Legal Solutions
866 299-5127

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
1

13:46:22

2

.

13:46:25

3

Q.

What

4
5
6

13:46:32
would be available to the

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

that -- and I'm

7

not sure that "

" is quite the correct

8

word, it's probably just more like

13:46:35
13:46:38
13:46:45
13:46:48
13:46:51

9

13:46:53

10

13:46:57

11
12

.
What format was the

13:47:30

stored in?

Q.

13:47:00

13:47:33

13
14

A.

15
16

.
Q.

17
18

I believe it would be

13:47:43
Okay.

And where does that

?

13:47:51
13:47:54

A.

13:47:55

19

13:48:00

20

.

21

Q.

22

?

13:48:06

And where are the
I'm sorry, withdrawn.

23

13:48:16
13:48:18
13:48:20

24
25

13:47:41

?
A.

13:48:22

They are similar to

13:48:27
Page 119

Veritext Legal Solutions
866 299-5127