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)

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EXHIBIT BB HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY UNITED STATES DISTRICT COURT 1 NORTHERN DISTRICT OF CALIFORNIA 2 OAKLAND DIVISION 3 4 5 MATTHEW CAMPBELL, MICHAEL HURLEY, ) 6 and DAVID SHADPOUR, ) Plaintiffs, 7 ) vs. 9 FACEBOOK, INC., C 13-05996 PJH ) Defendant. 11 Case No. ) 8 10 ) 12 ) ) 13 14 15 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY VIDEOTAPED DEPOSITION OF JIAKAI LIU Palo Alto, California 16 June 30, 2015 17 Volume I 18 19 20 21 Reported by: 22 KELLI COMBS, CSR No. 7705 23 Job No. 2094258 24 Pages 1 - 256 25 Page 1 Veritext Legal Solutions 866 299-5127 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 1 of communication did you primarily use? 2 A In what context? 3 Q 10:52:01AM In terms of electronic communication. 4 I'll withdraw the question. Did you typically e-mail other members of 5 6 So 10:52:13AM the Software Engineering team between 2010 and 2012? 7 A Yes. 8 Q Other than e-mail, did you use any other 9 10 form of electronic communications such as Chat or some sort of internal e-mail system, et cetera? 11 A Yes. 12 Q 10:52:31AM And tell me about those other means of 13 14 communication you used. A Facebook Messages, that includes Chat and, 15 like, non-chat Message. 16 think. 17 recall at this point. 18 19 Q That's 10:52:47AM that, primarily I I might miss some other tool, but I couldn't What was -- what was your e-mail address between 2010 and 2012, your Facebook? 20 A It's 10:53:21AM 21 Q If you'd turn back to Exhibit Number 2 and 22 you look on the second page, do you see the heading 23 "Understanding Cells"? 24 A Yes. 25 Q And do you see the third bullet point 10:53:54AM Page 50 Veritext Legal Solutions 866 299-5127 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 1 send her a message and what's going to happen, like, 2 after the request enters the first, like, Facebook 3 MTA server. 4 Q 5 6 diagram. A 11:44:49AM And -- so let's -- let's walk through this What does "MTA" mean? 11:45:06AM MTA is a commercial -- I think it's a 7 commercial software we bought to receive the -- to 8 handle the external e-mail requests and also, like, 9 we use it for internal message sending/receiving 10 11 12 13 14 15 16 purpose as well. Q 11:45:34AM 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? 17 A No. 18 Q Who was primarily responsible for that? 19 A We call it Site Integrity on Facebook. 20 Q And did you have a primary point of 21 contact in the Site Integ- -- on the Site Integrity 22 11:46:05AM team between 2010 and 2012? 23 A I didn't personally. 24 Q Did you write any code that dealt with 25 I couldn't remember. spam detection in the Messages product? 11:46:23AM Page 84 Veritext Legal Solutions 866 299-5127 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 1 2 A User Snapshot was the blob of metadata we 1:22:09PM saved to HBase. 3 Q Let's -- let's turn just for one few more 4 questions back to Exhibit Number 3. 5 go to the -- that diagram on the second page, the 6 "Incoming Flow" diagram. 7 about spam detection earlier, and you indicated that 8 Site Integrity was primarily responsible for that. 9 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 11 A I don't know. 12 Q Don't know? 13 A I don't. 14 Q And just so we're clear, do you know 15 whether they did any malware scanning of incoming 16 messages between January 1st, 2010, and January 1st, 17 2013? 18 19 20 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 21 with anyone about any malware scanning that Facebook 22 1:24:36PM was doing? 23 MR. JESSEN: 24 THE WITNESS: 25 Object to form. I couldn't recall now. It might, but because it's, like, four, five years ago, 1:24:52PM Page 107 Veritext Legal Solutions 866 299-5127 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY 1 I couldn't recall now. 2 BY MR. CARNEY: Q 3 4 Do you recall whether you were -- ever wrote any code dealing with malware scanning? A 5 6 1:24:55PM I couldn't remember at this point. I 1:25:15PM couldn't remember. Q 7 Do you know whether Facebook does any 8 scanning to protect the site from hackers? 9 that. Strike Do you know whether Facebook did any 10 11 scanning to protect the site from hackers between 12 1:25:34PM January 1st, 2010, January 1st, 2013? 13 14 15 A I think that's what Site Integrity team does -- did; that's their job detail. Q Did you have any discussions with anyone 16 at the Site Integrity team regarding their efforts 17 to prevent or protect the site from hackers related 18 1:25:52PM to the Messages product? 19 A I couldn't remember the exact I might be in some e-mail thread or 20 conversation. 21 1:26:10PM something, but I couldn't remember. 22 Q Do you recall whether you wrote any code 23 dealing with efforts to protect the site from 24 hackers? 25 A I couldn't remember. 1:26:31PM Page 108 Veritext Legal Solutions 866 299-5127 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY I, 1 2 the undersigned, a Certified Shorthand Reporter of the State of California, do hereby certify: That the foregoing proceedings were taken 3 4 before me at the time and place herein set forth; that 5 any witnesses in the foregoing proceedings, prior to 6 testifying, were administered an oath; that a record of 7 the proceedings was made by me using machine shorthand 8 which was thereafter transcribed under my direction; 9 that the foregoing transcript is a true record of the 10 testimony given. Further, that the foregoing pertains to the 11 12 original transcript of a deposition in a Federal Case, 13 before completion of the proceedings, a review of the 14 transcript [X] was [ ] was not requested. I further certify I am neither financially 15 16 interested in the action nor a relative or employee of 17 any attorney or any party to this action. IN WITNESS WHEREOF, 18 19 I have this date subscribed my name. 20 21 Dated: July 7, 2015 22 23 24 KELLI COMBS 25 CSR No. 7705 Page 256 Veritext Legal Solutions 866 299-5127 In the Matter of: Campbell et al. v. Facebook, Inc. Case No. 13-CV-05996-PJH Date of deposition: June 30, 2015 Witness: Jiakai Liu Reason codes: 1. 2. 3. To clarify the record. To conform to the facts. To correct transcription errors. Page Line Reads Should Read 9 14 23 21 16 18 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 21 28 4 6 29 4 60 24 71 16 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 . A. . Q. Who was your boss on the Home team? A. It was . Q. Is 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, A. . Q. Who was your boss on the Home team? A. It was . Q. Is 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, Reason Code 3 3 3 3 3 1 3 3 94 21 94 23 99 25 106 3 108 14 121 3 123 21 164 21 197 7 197 10 satisfied, they can accept the change, and then you can lend the change, commit the change to the repository. A. Uh-huh. Index is -- it’s generally you can imagine it as a mapping from a stream, from, like, some – something, from some entities. It maps to a collection of some other ID or streams. Q. What’s a memcache tier? A. Memcache tier is a common cache service using Facebook. their Facebook e-mail address, by the time team we support e-mail address for Facebook users, and that message will start an e-mail-originated thread. A. I think that’s what Site Integrity team does – did; that’s their job detail. Q. How about ? A. , I heard his name, but I don’t know him personally or worked with him, no. A. , the boss, I mentioned earlier. So, to me, it’s like two independent concepts. One, it’s the implementation for Facebook Messages, which I had worked on and continue to work on, like, is the patent worth filing. The memory cache dirty service and posted processing -The memcache dirty service and posted processing 2 they can accept the change, and then you can land the change, commit the change to the repository. A. Uh-huh. Index is -- it’s generally you can imagine it as a mapping from a string, from, like, some – something, from some entities. It maps to a collection of some other ID or strings. 3 3 Q. What’s a memcache tier? A. Memcache tier is a common cache service used in Facebook. their Facebook e-mail address, by the time we support e-mail address for Facebook users, and that message will start an e-mail-originated thread. 3 A. I think that’s what Site Integrity team does – did; that’s their job duty. Q. How about ? A. , it’s a guy I know on Messages team and had some work relationship. 3 A. I mentioned earlier. So, to me, it’s like two independent concepts. One, it’s the implementation for Facebook Messages, which I had worked on and continue to work on, like, while the patent was filing. The memory cache dirty service and post processing -The memcache dirty service and post processing 3 3 1 3 3 3

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