Campbell et al v. Facebook Inc.
Filing
184
EXHIBITS re 181 Administrative Motion to Seal Documents Accompanying Class Certification Briefs and Evidentiary Objections filed by Facebook Inc.. (Attachments: # 1 Exhibit 53 (Redacted), # 2 Exhibit 54 (Unredacted), # 3 Exhibit 55 (Redacted), # 4 Exhibit 56 (Unredacted), # 5 Exhibit 57 (Redacted), # 6 Exhibit 58 (Unredacted), # 7 Exhibit 59 (Redacted), # 8 Exhibit 60 (Unredacted), # 9 Exhibit 61 (Redacted), # 10 Exhibit 62 (Unredacted), # 11 Exhibit 63 (Redacted), # 12 Exhibit 64 (Unredacted), # 13 Exhibit 65 (Redacted), # 14 Exhibit 66 (Unredacted), # 15 Exhibit 67 (Redacted), # 16 Exhibit 68 (Unredacted), # 17 Exhibit 69 (Redacted), # 18 Exhibit 70 (Unredacted), # 19 Exhibit 71 (Redacted), # 20 Exhibit 72 (Unredacted), # 21 Exhibit 73 (Redacted), # 22 Proof of Service)(Related document(s) 181 ) (Chorba, Christopher) (Filed on 3/28/2016) Modified on 3/29/2016 (kcS, COURT STAFF).
EXHIBIT 12
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UNITED STATES DISTRICT COURT
2
NORTHERN DISTRICT OF CALIFORNIA
3
OAKLAND DIVISION
4
5
MATTHEW CAMPBELL, MICHAEL HURLEY, )
6
and DAVID SHADPOUR,
7
)
Plaintiffs,
)
8
9
10
) Case No.
vs.
FACEBOOK, INC.,
11
12
) C 13-05996 PJH
)
Defendant.
)
_________________________________ )
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VIDEOTAPED DEPOSITION OF BENJAMIN GOLDBERG, PH.D.
18
Palo Alto, California
19
February 2, 2016
20
21
22
Reported by:
23
KELLI COMBS, CSR No. 7705
24
Job No. 2224913
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"There was substantial,
2
inherent variability based on the
3
evolution of features and the
4
software over time."
5
What do you mean by "substantial" there?
6
A
11:56:44AM
11:56:56AM
Meaning that it's simply not possible to
7
conclude that all messages in the Facebook system
8
were handled the same and resulted in the same
9
processes being performed and provided the same
10
experience to the users, and -- and that the users
11
interacted the same way with the Messaging system.
12
Q
11:57:22AM
Well, you say:
13
"It's simply not possible to
14
conclude that all messages in the
15
Facebook system were handled the
16
same."
17
But what do you mean by "substantial" in
18
the context of this paragraph?
19
20
21
11:57:51AM
MR. JESSEN:
Objection; asked and
answered.
11:58:05AM
THE WITNESS:
I don't know how to quantify
22
that for you other than "substantial" meaning not
23
"insubstantial"; that it is the case that there was
24
sufficient variability that one cannot conclude that
25
the system worked the same way for -- for everybody,
11:58:33AM
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and that there would be lots of people for whom the
2
Messaging operated in a way other than what
3
Dr. Goldbeck has claimed to be in violation of the
4
statutes.
5
BY MR. RUDOLPH:
6
7
Q
11:58:36AM
11:58:59AM
Other than defining "substantial" as
meaning not "insubstantial," can you quantify it?
8
A
I don't have numbers to give you for that.
9
Q
Okay.
10
A
Because I don't -- I don't have access to
Why not?
11
statistics regarding, for example, database
12
failures, race conditions.
11:59:22AM
13
14
I'm not sure anybody --
(Reporter clarification.)
THE WITNESS:
Race, R-A-C-E, conditions,
15
corruption of data, and it's not true that -- I'm
16
not -- sorry.
17
statistics on -- on that in the system, the size and
18
complexity of Facebook's.
19
11:59:40AM
It's not clear to me that anybody has
My understanding is that no statistics
20
were kept on, for example, the number of users who
21
typed a URL and then deleted the preview or typed
22
the URL without hitting a space so that no preview
23
was generated.
24
tremendous variation among the way that users use
25
the system and the way the system behaved for which
11:59:57AM
There's -- there's going to be
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no statistics are gathered.
Q
12:00:27PM
You say you didn't have access to
3
statistics regarding, for example, database
4
failures, race conditions, corruption of data.
5
Did you ask for access to those
6
statistics?
7
A
12:00:45PM
The -- the declarations actually talk
8
about that these kinds of grounds for variability
9
are not, in fact, tracked within Facebook and that
10
11
there's no way to -- to generate the statistics.
Q
12:01:06PM
Are you saying that in the declarations,
12
one of the declarants states that there are no
13
statistics on database failures?
14
15
MR. JESSEN:
Objection; documents speak
for themselves.
16
THE WITNESS:
12:01:33PM
No.
What I said was that
17
the -- one of the Facebook's declarants talked about
18
at least one source of variability for which
19
Facebook had no way of gathering statistics or did
20
not gather statistics.
21
BY MR. RUDOLPH:
22
23
Q
12:01:50PM
And I'm asking specifically about database
failures.
24
A
I don't recall.
25
Q
Okay.
12:01:58PM
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What about race conditions?
2
MR. JESSEN:
3
4
12:01:58PM
What's your question?
BY MR. RUDOLPH:
Q
Do any of the declarants discuss whether
5
or not Facebook has any statistics on things like
6
race conditions?
7
A
I don't recall.
12:02:08PM
I know one of the
8
declarants discusses race conditions.
9
recall exactly what he says.
10
Q
I don't
Do any of the declarants discuss whether
11
or not Facebook has statistics on database
12
corruption?
13
A
I don't recall.
14
Q
12:02:23PM
Did you look at any internal studies or
15
statistics related to race conditions?
16
A
I did not.
17
Q
Did you ask for those?
18
A
No.
19
Q
And for data corruption?
20
A
I did not.
21
Q
And for database failures?
22
A
I did not.
23
Q
12:02:55PM
And did you speak to anyone at Facebook to
24
25
12:03:07PM
determine the rate of these problems?
A
No.
12:03:25PM
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Q
12:03:28PM
the rate of these implementation issues?
3
4
Did you do anything at all to ascertain
MR. JESSEN:
Object to the form.
Asked
and answered.
5
THE WITNESS:
No.
My experience in
6
teaching and doing research in the area of
7
distributed and parallel computing is con- -- a
8
substantial rate of variability, and these kinds of
9
12:03:38PM
failures is consistent with my experience.
10
11
BY MR. RUDOLPH:
Q
12
12:04:02PM
Okay.
You can't quantify what you mean by
13
"substantial"?
1 percent of the time, 5 percent of
14
the time, 10 percent of the time?
15
MR. JESSEN:
16
THE WITNESS:
17
Correct.
12:04:13PM
I do not have a
number for you.
18
Object to the form.
BY MR. RUDOLPH:
19
20
Q
Is there a number below which you would
say the variability is not substantial?
21
MR. JESSEN:
22
Are you just talking about the
23
12:04:22PM
parenthetical or the other parts of that sentence?
24
MR. RUDOLPH:
25
MR. JESSEN:
Objection.
No.
It's unclear, because you've
12:04:35PM
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been talking about race conditions, data corruption,
2
but that's not the whole sentence, so...
3
MR. RUDOLPH:
Well, fair enough.
4
variability related to race conditions, data
6
corruption or database failures.
7
THE WITNESS:
Right --
right now, I'm -- I'm -- I'm asking about
5
12:04:36PM
8
And just restate the
question.
9
12:04:44PM
BY MR. RUDOLPH:
10
Q
Is there a number below which you would
11
say these issues:
12
corruption, database failures, leads to variability
13
12:04:57PM
Race conditions, database
that is not substantial?
14
MR. JESSEN:
15
THE WITNESS:
Object to the form.
I can't give you a -- a
16
number that delineates when it is and when it is not
17
substantial.
18
12:05:15PM
BY MR. RUDOLPH:
19
20
Q
And -- and by "number," I'm -- I'm asking
for a -- a percentage of -- of the time.
21
A
I understood that.
22
Q
Right.
12:05:28PM
23
Okay.
So with respect to variability related to
24
race conditions, data corruption or database
25
failure, you really don't have any basis to say that
12:05:50PM
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variability related to those issues is substantial,
2
then; is that correct?
3
4
MR. JESSEN:
12:05:54PM
Objection; misstates the
testimony.
5
THE WITNESS:
Well, let me -- the basis
6
includes the sworn statements of the declarants and
7
an understanding of the complexities and the
8
difficulties in maintaining a system the size of
9
Facebook's.
12:06:00PM
And so my experience, my knowledge of
10
the technology and the sworn statements of the
11
people who built the system are the bases for my
12
conclusions.
13
BY MR. RUDOLPH:
14
Q
12:06:19PM
But you didn't do anything to investigate
15
the actual rate of things like race conditions, data
16
corruption or database failures, correct?
17
A
That's correct.
18
Q
12:06:38PM
In paragraph 15, you are discussing what
19
you characterize as Dr. Goldbeck's distinction
20
between memory and storage.
21
Did you do anything to investigate whether
22
or not such a distinction exists within the field of
23
12:07:15PM
computer science?
24
25
A
Well, I -- I cited that the Microsoft
dictionary definition of "memory," which makes clear
12:07:52PM
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table in the Hive database and any data
2
that it -- it contained.
3
2:35:03PM
BY MR. RUDOLPH:
4
5
6
Q
Do you have any understanding of what the
structure of the
A
table was?
2:35:15PM
I think there was some -- something that
7
was produced and attached to Dr. Goldbeck's report
8
that gave information about the
9
I don't remember the specifics.
10
Q
table.
And what is your basis for your
11
understanding that in 2011 the
12
2:36:00PM
its data were deleted?
13
A
Two things:
table and
One is the sworn statement
14
from Mr. Himel.
And I did a search in the code, the
15
2012 code, looking for use of this table, and I did
16
not find it.
17
Q
What do you mean by "use of the table"?
18
A
2:36:25PM
Adding data to the table, retrieving the
19
table, retrieving data from the table.
20
Q
21
data to it?
22
A
Both.
23
Q
And what sort of search did you perform to
24
25
Retrieving data from the table or adding
2:36:45PM
determine that?
A
I looked for code that accessed the
2:37:02PM
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table, specifically database code for
accessing the
Q
table.
And describe specifically how you looked
for code that accesses the
A
2:37:04PM
table.
Doing a search on the -- on the source
6
code computer using standard tools for searching
7
2:37:27PM
code such as Grep, G-R-E-P.
8
Q
What is Grep?
9
A
It's a program in which you can specify
10
text to be searched for in files and directories.
11
It includes the ability to specify what -- specify
12
wildcards which match lots of different possible
13
strings of characters.
14
Q
15
2:37:56PM
You say:
"I looked for code that
2:38:28PM
16
accessed the
17
specifically database code for
18
accessing the
19
What -- what is database code?
20
A
table,
table."
Code in files that, for example, in this
21
case, have an HQL or a similar file extensions as
22
2:38:40PM
well as PHP code that would invoke database queries.
23
Q
Are you confident that if such code
24
existed, it would have been on the source code
25
computer that you were provided?
2:39:26PM
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There was lots of database code for
2
accessing other database tables.
3
amount of code on the source code computer, so I
4
feel -- I feel confident that if it was part of the
5
code base and in use, that it would have been on
6
2:39:38PM
that source code computer.
7
8
9
10
11
Q
12
13
14
table?
I believe that was on my second trip to
Cooley, so mid-January.
Q
2:39:55PM
When did you perform the search of the --
for code that uses the
A
There was a huge
2:40:23PM
Okay.
Why is the fact that you performed that
search not mentioned in your report?
A
No particular reason.
If I thought of it
15
while I was drafting the text -- sitting here, I
16
probably would have mentioned it.
17
just confirmed what Mr. Himel had stated.
18
Q
But it really
I believe you said you searched in code
19
from 2012.
20
you searching?
21
A
2:40:56PM
What -- what time period in 2012 were
2:41:18PM
It was the -- the last version of the code
22
on the source code computer, which was
23
December 2012.
24
25
Q
Okay.
It's possible that the code that used
2:41:33PM
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would have shown up in a search for
2
previous iterations of the code from previous time
3
2:41:36PM
periods, correct?
4
5
6
7
MR. JESSEN:
BY MR. RUDOLPH:
Q
2:41:51PM
You did a search for all of the class
period?
8
9
Objection.
MR. JESSEN:
Objection; calls for
speculation.
10
THE WITNESS:
I did not search, but, of
11
course, Mr. Himel has stated under oath that that
12
table did not exist during the class period.
13
2:41:56PM
BY MR. RUDOLPH:
14
15
Q
So I want to go back to, you were saying
you used tools like you call it Grep?
16
A
Grep (pronounced differently).
17
Q
Grep.
18
using Grep?
19
A
I searched for the string
20
Q
Okay.
2:42:18PM
21
22
What exactly did you search for
2:42:39PM
And that would have returned what?
A
It would have returned the list of all
23
files containing that -- that string, along with the
24
line where that string appeared in each file.
25
Q
And so, in other words, you searched for
2:43:16PM
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the word
the name of the table, and
2
that didn't return any results?
3
A
4
right.
5
if I had found it, I would have noted it, and I did
6
2:43:21PM
not.
7
Q
To the best of my recollection, that's
I don't recall exactly what happened.
But
2:43:35PM
And why does the fact that that search
8
returned no results demonstrate that no code within
9
Facebook was using
10
A
It was using that table because in the
11
code you specify the table you want to access by the
12
2:43:55PM
name of the table.
13
14
Q
table itself
have been stored within Facebook's system?
15
16
Where would the
MR. JESSEN:
Objection; calls for
2:44:28PM
speculation, lacks foundation.
17
THE WITNESS:
My understanding is it's in
18
their Hive database, which is a particular, very
19
large database that they maintained.
20
BY MR. RUDOLPH:
21
22
Q
2:44:48PM
Was -- were any of Facebook's databases
made available to you as part of your analysis?
23
A
The data itself, no, I don't believe so.
24
Q
You say in paragraph 45 of Nectar:
25
"I understand that it is one
2:45:38PM
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Messaging software is itself a device as one of
2
skill would understand it, as computer scientists
3
would understand it.
4
that's erroneous.
5
6
Q
3:33:53PM
And that's -- and I believe
You're not offering a legal opinion on
3:34:11PM
whether or not software can constitute a device?
7
A
Within a statute, for example?
8
Q
Uh-huh.
9
A
Yes, I am not offering that opinion.
10
Q
Are you aware of allegations against
11
Volkswagen that they, let's say, doctored their
12
3:35:05PM
software to get around environmental regulations?
13
14
MR. JESSEN:
Objection; outside the scope,
outside the case.
15
THE WITNESS:
From what I hear from the
16
popular press, right, they customize their software
17
so that it could detect when a test is being
18
performed and change the pollution emissions for the
19
3:35:29PM
purpose of that test.
20
21
MR. RUDOLPH:
Can you mark this as the
3:35:49PM
next exhibit.
22
(Deposition Exhibit 6 marked for
23
identification.)
24
25
BY MR. RUDOLPH:
Q
Dr. Goldberg, can you read what the title
3:36:18PM
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3
4
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of this article is?
A
3:36:20PM
"Volkswagen's Software Was 'Illegal Defeat
Device' German Regulator Says."
Q
This is an example of software being
referred to as a "device"; is that correct?
6
MR. JESSEN:
7
THE WITNESS:
3:36:41PM
Objection; lacks foundation.
Let me just take the time to
8
read the article so I can get the context.
9
BY MR. RUDOLPH:
10
Q
Sure.
11
A
Okay.
12
Q
This is an example of software being
13
14
3:36:54PM
So what was your -- your question?
referred to as a "device"; is that correct?
A
Well, it's software that was running on a
15
computer within the car, and in conjunction with
16
the -- with the piece of the car that -- that
17
determines the emissions -- it was in here
18
somewhere -- activating the special Eco friendly
19
mode of lower emissions.
20
And so the software running on the
21
change the emissions, is what I believe is being
23
3:39:06PM
computer in the car, together with the ability to
22
3:38:42PM
referred to as a "illegal defeat device."
24
Of course, it's in German, so it's hard to
25
know -- it's a German law, so it's hard to know what
3:39:23PM
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the words actually mean.
Q
3:39:27PM
Would it surprise you if a governmental
3
organization defined a certain type of software as a
4
"device"?
5
6
MR. JESSEN:
Objection; lacks foundation,
3:39:52PM
incomplete hypothetical, calls for speculation.
7
THE WITNESS:
It would surprise me if the
8
government characterized software on its own without
9
actually being -- without running on something as a
10
device, but...
11
BY MR. RUDOLPH:
12
13
14
Q
3:40:12PM
All software has to run on something to
function, correct?
A
15
Correct.
MR. RUDOLPH:
Okay.
Next exhibit.
16
(Deposition Exhibit 7 marked for
17
3:40:19PM
identification.)
18
19
20
21
22
BY MR. RUDOLPH:
Q
So can you read the -- what the title of
this document is, Dr. Goldberg?
A
3:40:55PM
(Reading):
"EPA, California Notify
23
Volkswagen of Clean Air Act
24
violations.
25
used software that circumvents
Carmaker allegedly
3:41:11PM
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emissions testing for certain air
2
pollutants."
3
4
5
Q
3:41:13PM
Can you read the first line of the article
after the word "Washington"?
A
(Reading):
6
3:41:28PM
"Today, EPA is issuing a
7
notice of violation of the Clean
8
Air Act to Volkswagen AG, Audi AG,
9
and Volkswagen Group of America,
10
Inc., collectively referred to as
11
Volkswagen."
12
Q
13
Okay.
And then can you read the first sentence
14
of the fourth paragraph.
15
described in the NOV"?
16
3:41:43PM
A
It starts with "as
3:41:54PM
(Reading):
17
"As described in the NOV, a
18
sophisticated software algorithm on
19
certain Volkswagen vehicles detects
20
when the car is undergoing official
21
emissions testing and turns full
22
emissions controls on only during
23
the test."
24
25
Q
3:42:05PM
Okay.
And then can you read the last sentence of
3:42:16PM
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that paragraph.
A
3:42:18PM
(Reading):
3
"The software produced by
4
Volkswagen is a 'defeat device' as
5
defined by the Clean Air Act."
6
Q
3:42:33PM
So would you agree that the EPA is
7
defining software produced by Volkswagen as a type
8
of device --
9
10
11
MR. JESSEN:
Objection.
BY MR. RUDOLPH:
Q
12
3:42:49PM
-- within the meaning of a statute?
MR. JESSEN:
Objection; lacks foundation,
13
calls for speculation, document speaks for itself,
14
also irrelevant.
15
if you want.
16
But you can certainly read this,
THE WITNESS:
3:43:01PM
I -- I read this as them
17
saying that the software running on the Volkswagen
18
computer is a defeat device.
19
being -- perhaps being imprecise, but the software
20
on its own can't defeat anything.
21
BY MR. RUDOLPH:
I think they're
22
Q
Imprecise by whose lights?
23
A
3:43:20PM
Meaning who would consider this imprecise,
24
25
this press release?
Q
Uh-huh.
3:43:36PM
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Someone in computer science would
3:43:38PM
2
consider -- might consider this imprecise.
3
clear from the context they're talking about the
4
software running on the Volkswagen computer.
5
Q
It's
So the statement:
6
3:44:03PM
"In my 33 years as a computer
7
scientist, I have never heard the
8
term 'device' used to refer to
9
software."
10
Is that statement still true?
11
MR. JESSEN:
12
THE WITNESS:
3:44:11PM
Object to the form.
Well, it's certainly true
13
when I -- I wrote it.
14
refer to software as a device, it's -- it's an odd
15
characterization, but the way I read it is as
16
software running on the Volkswagen computer was a
17
device, which I don't disagree with.
18
this language is not language you would see in
19
computer science itself.
20
BY MR. RUDOLPH:
21
22
Q
To the extent that this does
3:44:30PM
But this --
3:44:47PM
So you say:
"But the way I read it is as
23
software running on the Volkswagen
24
computer was a device, which I
25
don't disagree with."
3:44:55PM
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Why does the fact that the software was
2
running on the device lead you to not disagree with
3
the statement that "The software produced by
4
Volkswagen is a defeat device"?
5
MR. JESSEN:
3:45:00PM
Objection.
I'll just object
6
to this entire line as lacking foundation, calling
7
for speculation.
8
3:45:17PM
BY MR. RUDOLPH:
9
10
Q
I'm sorry.
Yeah.
Thanks.
Why does the fact that the software was
11
running on a computer lead you to not disagree with
12
the statement that "the software produced by
13
Volkswagen is a defeat device"?
14
MR. JESSEN:
15
THE WITNESS:
3:46:08PM
Object to the form.
Because lots of devices run
16
software, and so if you read that as I do, that what
17
they're saying is that the software, when it runs on
18
the -- on the computer, constitutes a device because
19
there's something physical there, then that would be
20
a normal use of the term "device" because you have
21
3:46:25PM
an actual, physical device.
22
23
24
25
MR. RUDOLPH:
3:46:47PM
How long have we been going?
Let's take a break.
THE VIDEOGRAPHER:
This marks the end of
Disk 3 to the deposition of Dr.
Benjamin Goldberg,
3:47:11PM
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I, the undersigned, a Certified Shorthand
Reporter of the State of California, do hereby certify:
That the foregoing proceedings were taken
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
11
testimony given.
Further, that the foregoing pertains to the
12
original transcript of a deposition in a Federal Case,
13
before completion of the proceedings, a review of the
14
transcript [ ] was [X] was not requested.
15
I further certify I am neither financially
16
interested in the action nor a relative or employee of
17
any attorney or any party to this action.
18
19
IN WITNESS WHEREOF, I have this date
subscribed my name.
20
21
Dated: 2/3/16
22
23
24
<%signature%>
KELLI COMBS
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