Campbell et al v. Facebook Inc.
Filing
183
EXHIBITS re 181 Administrative Motion to Seal Documents Accompanying Class Certification Briefs and Evidentiary Objections filed by Facebook Inc.. (Attachments: # 1 Exhibit 29 (Unredacted), # 2 Exhibit 30 (Redacted), # 3 Exhibit 31 (Unredacted), # 4 Exhibit 32 (Redacted), # 5 Exhibit 33 (Unredacted), # 6 Exhibit 34 (Redacted), # 7 Exhibit 35 (Unredacted), # 8 Exhibit 36 (Redacted), # 9 Exhibit 37 (Unredacted), # 10 Exhibit 38 (Redacted), # 11 Exhibit 39 (Unredacted), # 12 Exhibit 40 (Redacted), # 13 Exhibit 41 (Unredacted), # 14 Exhibit 42 (Unredacted), # 15 Exhibit 43 (Unredacted), # 16 Exhibit 44 (Unredacted), # 17 Exhibit 45 (Unredacted), # 18 Exhibit 46 (Unredacted), # 19 Exhibit 47 (Unredacted), # 20 Exhibit 48 (Unredacted), # 21 Exhibit 49 (Unredacted), # 22 Exhibit 50 (Unredacted), # 23 Exhibit 51 (Unredacted), # 24 Exhibit 52 (Unredacted))(Related document(s) 181 ) (Chorba, Christopher) (Filed on 3/28/2016) Modified on 3/29/2016 (kcS, COURT STAFF).
EXHIBIT JJ
HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
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,
Plaintiffs,
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No. 4:13-cv-05996-PJH
vs.
FACEBOOK, INC.,
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
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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PAGES 1 - 124
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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.
So
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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
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A.
(c)?
I reviewed the source code for EMMEN.
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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.
This is the
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source code,
and the other files in this directory are associated
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JavaScript enabled, the JavaScript functions monitor
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the individual key strokes in a manner often used
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for things such as type ahead search looking for
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similar patterns as to what
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extract, specifically the -- the public Internet
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standards governing the format of URLs or domain
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names.
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might try to
That is code which runs entirely on the
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user's machine, and when it detects such a string,
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it will make an asynchronous HTTP call to our
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service to team to generate a preview.
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And at that time while attempting to
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generate the preview, we would consult
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internal on Facebook's server.
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I believe you said that the JavaScript
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uses key strokes to generate things such as type
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ahead?
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Q.
A.
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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What are the relevant features that
has to take into account?
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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.
?
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
call in this?
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A.
MMEMMEMMEMMEMMEMMEMMEM MEM.
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Q.
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.
141111111111
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A.
I would say that is
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Q.
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Okay.
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A.
Those would be the ones we previously
discussed:
Q.
,
et cetera.
Which, what's the name of the
that is called here?
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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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check?
And what does that function
perform?
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A.
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A.
Uh-huh.
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Q.
States "Various message statistics,
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including all three formats for storing URL share
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data-message-specific information, user-specific
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share objects, and the global share object, were
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part of a universe of data available to the site
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security abuse- and security-related platforms for
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URL classification and other security efforts."
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Is that correct?
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A.
That is correct.
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Q.
What are the message statistics that are
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being referred to here?
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Message statistics for site integrity and
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abuse- and security-related purposes would refer to
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things like the number of messages a given user had
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sent over various periods of time, the number of
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specific recipients they have sent, the number of
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messages they sent containing URLs or attachments or
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other statistics that helped form a profile that
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identifies abuse vectors.
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A.
Q.
Where is the source code that carries out
this functionality?
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A.
he
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Q.
What sort of statistics would be from the
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global share object would be available to the
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integrity and abuse- and security-related platforms?
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A.
The sorts of statistics that -- and I'm
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not sure that "statistics" is quite the correct
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word, it's probably just more like data would be
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available would be things that like the date the URL
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was first shared on Facebook or perhaps the number
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of people who have shared it.
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Q.
What format was the user specific share
object information stored in?
A.
I believe it would be stored as a share
FBobject.
Q.
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Okay.
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get stored?
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A.
And where does that share FBobject
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Facebook objects are typically stored in a
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MySQL database and in a cache system for quick and
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easy access.
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Q.
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stored?
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I'm sorry, withdrawn.
What's the format in which the global
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And where are the global share objects
share objects are stored?
A.
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They are similar to user specific share
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I,
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the undersigned, a Certified Shorthand
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Reporter of the State of California, do hereby
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certify:
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.
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.
IN WITNESS WHEREOF,
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subscribed my name.
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Dated:
I have this date
10/30/2015
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COREY W. ANDERSON
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CSR No. 4096
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Errata
Case: Campbell et al. v. Facebook, Inc.
Case No. 13-CV-05996-PJH
Date of Deposition: October 28, 2015
Name of Deponent: Michael Adkins
Reason codes:
To clarify the record.
To conform to the facts.
3. To correct transcription errors.
Page
Line
Reads
Should Read
Reason
Global
1
Global
1
Global
1
Global
sigma
Sigma
1
13
12
at - during my time at Facebook.
during my time at Facebook.
1
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18
some - some time ago, some
number of months ago.
some time ago, some number
of months ago.
1
16
23
there - that this case existed and
that we were on
this case existed and that we
were on
1
19
17
If - if I was notified of a case like
If I was notified of a case like
1
20
2
I can't remember precisely or
than that I
I can't remember precisely
other than that I
3
20
3
was looking for anything
specific. Mostly just
wasn't looking for anything
specific. Mostly just
3
24
19
I have - I have seen
I have seen
1
34
8
operational reasons why not such
as system outages
operational reasons why not,
such as system outages
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7
machine learned
machine-learned
1
38
17
building a
building the
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41
22
set to - to dictate
set to dictate
1
42
10
team, it
team. It
1
43
2-3
and Windows phones. If we need
a new feature -- each of which
and Windows phones, each of
which
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47
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checking cashes, we rely heavily
on cache items.
checking caches. We rely
heavily on cached items.
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Page
Line
48
20-23
50
6
54
Reads
Should Read
Reason
1
do the thing you are supposed to
do
"do the thing you are supposed
to do"
1
11
service to team to generate a
preview
service to attempt to generate a
preview
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details
detailed
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message's
Messages
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65
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post send
post-send
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68
10
message's
Messages
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69
11
pass
passed
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sender allowed to send
sender is allowed to send
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76
24
80
4
80
3
machine learned
machine-learned
3
24
,
that
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to black
to the black
1
83
21
miss behave
misbehave
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84
15
taken is
taken it is
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87
3
small attachments
small. Attachments
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89
19
is in sigma this is in
is in Sigma. This is in
3
101
9
sand attach reports
and attachments
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8
that
[remove]
1
121
9
Is it
It is
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Michael Adkins
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