Campbell et al v. Facebook Inc.

Filing 180

EXHIBITS re 179 Notice (Other),,, Exhibits to Joint Notice of Refiling of Documents Accompanying Class Certification Briefs and Evidentiary Objections filed byFacebook Inc.. (Attachments: # 1 Exhibit 26 (Unredacted), # 2 Exhibit 27 (Redacted), # 3 Exhibit 28 (Redacted), # 4 Exhibit 29 (Unredacted), # 5 Exhibit 30 (Redacted), # 6 Exhibit 31 (Redacted), # 7 Exhibit 32 (Redacted), # 8 Exhibit 33 (Unredacted), # 9 Exhibit 34 (Redacted), # 10 Exhibit 35 (Unredacted), # 11 Exhibit 36 (Unredacted), # 12 Exhibit 37 (Redacted), # 13 Exhibit 38 (Unredacted), # 14 Exhibit 39 (Unredacted), # 15 Exhibit 40 (Unredacted), # 16 Exhibit 41 (Unredacted), # 17 Exhibit 42 (Redacted), # 18 Exhibit 43 (Redacted), # 19 Exhibit 44 (Redacted), # 20 Exhibit 45 (Redacted), # 21 Exhibit 46 (Redacted), # 22 Exhibit 47 (Redacted), # 23 Exhibit 48 (Redacted), # 24 Exhibit 49 (Unredacted), # 25 Exhibit 50 (Unredacted))(Related document(s) 179 ) (Chorba, Christopher) (Filed on 3/28/2016)

EXHIBIT 10

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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________________________________

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MATTHEW CAMPBELL, MICHAEL

)

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HURLEY, and DAVID SHADPOUR, on

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behalf of themselves and all

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others similarly situated,

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Plaintiffs,
vs.

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) Case No.

FACEBOOK, INC.,

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) C 13-05996 PJH

Defendant.

) Volume I

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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

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Videotaped Deposition of FERNANDO TORRES,

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taken on behalf of Defendant, at the offices of

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Lieff, Cabraser, Heimann & Bernstein, 275 Battery

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Street, San Francisco, California, beginning at

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8:10 a.m. and ending at 4:42 p.m., on Friday,

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December 18, 2015, before Chris Te Selle, CSR

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No. 10836.

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Job No. 2194240

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PAGES 1 - 307
Page 1
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or formulaic method that you developed?

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MR. DIAMAND:

Objection.

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THE WITNESS:

10:01:22

So, I applied established

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valuation methodologies to value the social graph,

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and then established a method to attribute an

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increase of the value of that asset as a result of

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an increase in the number of edges within the social

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graph, derived from the intercepted messages.

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BY MR. CHORBA:

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Q.

And do you have a section of your report

10:01:40

10:02:20

that's focused on that methodology?

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A.

Well, I think it's all of section 4.

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Q.

Combined, or 4 A?

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A.

Well, 4 A deals more directly with it,

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yes.

10:02:39
Q.

If you look at page 22, paragraph 60, and

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that's at the end of section 4 A of your report, and

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I will just read it.

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that a proper attribution of damages among plaintiff

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class members, as calculated, excuse me, calculated

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as benefits received by the defendant, should be

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based on the number of links, paren, URLs, close

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paren, intercepted.

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Therefore, it is my opinion

10:03:50

Is that your ultimate conclusion in
paragraph or in section 4 A of your opinion?

10:04:09
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I, the undersigned, a Certified Shorthand

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Reporter of the State of California, do hereby

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certify:

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That the foregoing proceedings were taken

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before me at the time and place herein set forth;

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that any witnesses in the foregoing proceedings,

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prior to testifying, were duly sworn; that a record

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of the proceedings was made by me using machine

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shorthand which was thereafter transcribed under my

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direction; that the foregoing transcript is a true

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record of the testimony given.

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Further, that if the foregoing pertains to the

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original transcript of a deposition in a Federal

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Case, before completion of the proceedings, review

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of the transcript [X] was [

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] was not requested.

I further certify I am neither financially

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interested in the action nor a relative or employee

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of any attorney or party to this action.

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IN WITNESS WHEREOF, I have this date subscribed
my name.
Dated: 1/5/2016

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<%signature%>
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CHRIS TE SELLE

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CSR No. 10836
Page 307
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