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)

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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RAY HE

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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 2173701B

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Q.

Okay.

Can you please point us to the

source code that performs that functionality?

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A.

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A.

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(Pause)

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Yes.

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So at a high level, the code I have loaded

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here will render markup that will instruct the

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browser to fetch the image and render it.

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would be line 54.

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Q.

That

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And is this the source code that says

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?

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A.

Yes.

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Q.

A few lines below that there is code that

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says

?

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A.

Yes.

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Q.

What function does that code perform?

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A.

I believe show privacy warning instructs

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UI share states to display a message to the user

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that people who can see their share cannot see the

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original content and thus it won't be rendered as an

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attachment.

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Q.

What is a share in the context of the

answer you just gave?
A.

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A share is a object created by a Facebook

user that represents something that the user has

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shared as an attachment.

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Q.

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What did you mean by people who can see

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the share cannot see the original content and thus

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it won't be rendered as an attachment?

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that mean?

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A.

What does

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So for instance, you have -- let's say you

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share something, say I can see this, but Josh can't,

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it's a photo.

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it.

You have made it so only I can see

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Now, if I share it, this is the code which

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will say that hey, you can share this, but some

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people won't be able to see the attachment.

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I share, Josh still won't be able to see the photo.

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Q.

So when

In section 1 (b) the response states "The

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JavaScript may provide a brief description of the

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URL."

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Do you see that?

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A.

Yes.

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Q.

Where is the information that informs the

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brief description of the URL obtained from?
A.

That would be part of the data eventually

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returned by the sharescape dispatcher we were just

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looking at.

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Q.

Does this code instruct the JavaScript in

the user's browser to return that information, or

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A.

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on the left.

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Q.

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So at the -- at a high level it's the code

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Okay.

And this is -- which file is this

again?
A.

This is

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Q.

Okay.

And what lines are you referring

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A.

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render this.

So the entire file kind of is needed to
But in particular where we call in to

our rendering code is this

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.

to?

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.

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In the context of 1 (y), what exactly was

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the data regarding URL attachments to messages that

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was obtained?

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Q.

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A.

So if a share object was previously

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created in the process that we referred to, the

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aggregate -- sorry, the global share objects counter

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field would be incremented, or part of the counter

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field would be incremented.

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Q.

Can you point to the code that incremented

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the global share object's field when a share object

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was created?

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A.

Yes.

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(Pause)

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So the code I have on the left is code

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A.

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couple of questions talking about the dif set

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modified the tracking info.

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MR. RUDOLPH:

Yes.

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THE WITNESS:

Just want to paint a picture

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of what actually changed.

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So the tracking info is just five or six

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numbers, each of which is a counter for things like

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attachment, Facebook feed posts, likes, comments,

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stuff like that.

And there is no way to like go

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back from these counters to the original objects

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that caused their incrementing.

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BY MR. RUDOLPH:

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Q.

Okay.

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A.

That was it.

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Q.

If you can go back to 1 (v), please?

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A.

Yes.

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Q.

1 (v) states "The message event was logged

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Is there anything else?

on a number of ways."

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Do you see that?

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A.

Yes.

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Q.

And you, we discussed that the logs that

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you are aware of in which the message event was

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logged are the impressions log and the ODS log?

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A.

Yes.

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Q.

Okay.

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Are there other logs in which this

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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 administered an oath; that

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a record of the proceedings was made by me using

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machine shorthand which was thereafter transcribed

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under my direction; that the foregoing transcript is

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a true record of the testimony given.

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Further, that if the foregoing pertains to

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the 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 was not requested.

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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 any party to this action.

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IN WITNESS WHEREOF, I have this date

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subscribed my name.

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Dated:

10/30/2015

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<%signature%>

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COREY W. ANDERSON

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CSR No. 4096
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