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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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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some - some time ago, some
number of months ago.

some time ago, some number
of months ago.

1

16

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there - that this case existed and
that we were on

this case existed and that we
were on

1

19

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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

3

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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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

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6

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Reads

Should Read

Reason

1

do the thing you are supposed to
do

"do the thing you are supposed
to do"

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11

service to team to generate a
preview

service to attempt to generate a
preview

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61

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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

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pass

passed

3

72

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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

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83

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miss behave

misbehave

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84

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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

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101

9

sand attach reports

and attachments

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119

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that

[remove]

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121

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Is it

It is

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Michael Adkins