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 C 63

Individual Inquiries Required to Ascertain whether Someone Is a Member of the Proposed Class
If the answer to ANY of the below questions is NO, then the person is NOT in Plaintiffs’ proposed class as written.

Is the person located in the
United States?

Did the person send or receive
a Facebook message?

Were both the message sender
and the message recipient a
Facebook user?

Was the message sent on or
after December 30, 2011?

Was the message sent from the
Facebook website?

Did the sender copy and paste
a URL into the draft message?
Or
Did the sender type a URL
into the message and press the
space bar?

Was the sender using a
browser with JavaScript
enabled?

Did the software code running
in the sender's browser request
a URL preview from a
Facebook server?

Did the sender wait for a
preview to be generated (i.e.,
the sender did not send the
message too quickly, such that
a URL preview was not
generated)?

Did Facebook's site integrity
and security platform allow
the preview (i.e., it did not
"block" generation of the
preview attachment)?

Did the URL preview function
successfully generate a
preview (i.e., it did not time
out, return an error, return
blank, require login at the
destination website, etc.)

Did the message contain a
URL when it was sent (i.e., the
sender did not delete the URL
in the text after the preview
was generated)?

Did the URL included at time
of send match the preview
(i.e., the message body did not
only include a different URL)?

Is the person a Facebook user?

1

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to Share Object Creation
If the answer to ANY of the below questions is NO, then a share object was NOT created in the class period.

Was the message sent on or after
December 30, 2011?

Were both the message sender and the
message recipient a Facebook user?

Was the message sent from the Facebook
website?
Or
Was the message sent from a Facebook
Share Plugin (by choosing to send "In a
private message")?

Was a URL preview generated?
(See p. 3, URL Preview slide)

Did the message have a URL preview
when it was sent (i.e., the sender did not
delete the URL preview before sending)?

Did the URL included at time of send
match the preview (i.e., the message body
did not only include a different URL)?

Did Facebook's site integrity and security
platform allow the message and
attachment (i.e., it did not "block" receipt
of the message body or preview
attachment)?

Was the URL to a non-Facebook
webpage?

2

Individual Inquiries Required to Ascertain whether a URL Preview Was Generated
If the answer to ANY of the below questions is NO, then a URL preview was NOT generated in the class period.

Were both the message sender and the
message recipient a Facebook user?

Was the message sent from the Facebook
website?
Or
Was the message sent from a Facebook
Share Plugin (by choosing to send "In a
private message")?

If sent from the Facebook website:
Did the sender copy and paste a URL into
the draft message?
Or
Did the sender type a URL into the
message and press the space bar?Was the
sender using a browser with JavaScript
enabled?

Did the software code running in the
sender's browser request a URL preview
from a Facebook server?

Did the sender wait for a preview to be
generated (i.e., the sender did not send the
message too quickly, such that a URL
preview was not generated)?

Did Facebook's site integrity and security
platform allow the preview (i.e., it did not
"block" generation of the preview
attachment)?

Did the URL preview function
successfully generate a preview (i.e., it did
not time out, return an error, return blank,
require login at the destination website,
etc.)

3

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Internal Counter Incrementing in the Global Share Object (and thus
FQL Table)
If the answer to ANY of the below questions is NO, then the share_count in the global share object
(and
FQL table) was NOT incremented during the class period.

Was the message sent on or after
December 30, 2011?

Were both the message sender and the
message recipient a Facebook user?

Was the message sent from the Facebook
website?
Or
Was the message sent from a Facebook
Share Plugin (by choosing to send "In a
private message")?

Was a URL preview generated?
(See p. 3, URL Preview slide)

Did the URL included at time of send
match the preview (i.e., the message body
did not only include a different URL)?

Was a share object created?
(See p. 2, Share Object slide)

Were the conditions such that each share
of that URL could be counted separately?
(i.e., there were not simultaneous shares
being counted as only a single share, "race
conditions")

Were the databases handling and storing
the counters operational and in proper
alignment (i.e., no database faliure or
contention)?

4

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Social Plugin Count Incrementing
If the answer to ANY of the below questions is NO, then the count on a third-party social plugin was NOT incremented during the class period.

Was the message sent from the
Facebook website?
Or
Was the message sent from a
Facebook Share Plugin (by
choosing to send "In a private
message")?

Was a URL preview generated?
(See p. 3, URL Preview slide)

Was the internal counter in the
global share object
incremented?
(See p. 4, Internal Count slide)

Was the message sent between
December 30, 2011 and
December 19, 2012?

Were both the message sender
and the message recipient a
Facebook user?

Did the URL included at time
of send match the preview (i.e.,
the message body did not only
include a different URL)?

Was a share object created?
(See p. 2, Share Object slide)

Was the URL to a third-party
website?

Did the third-party website
display a plugin counter?

Was the third-party website
configured to display the
share_count from the global
share object (i.e., not
configured to display the
fan_count)?

Was the URL typed into the
message exactly the URL
passed to the plugin?

5

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Logging Share Scrapes in Nectar
If the answer to ANY of the below questions is NO, then the share scrape for the message was NOT logged in Nectar during the class period.

Was the message sent after
December 30, 2011?

Were both the message sender
and the message recipient a
Facebook user?

Was the message sent from the
Facebook website?
Or
Was the message sent from a
Facebook Share Plugin (by
choosing to send "In a private
message")?

Was the sender using a browser
with JavaScript enabled?

Did the software code running in the
sender's browser request a URL
preview from a Facebook server?

Did the sender wait for a preview to
be generated (i.e., the sender did not
send the message too quickly, such
that a URL preview was not
generated)?

Did Facebook's site integrity and
security platform allow the preview
process (i.e., it did not "block"
generation of the preview
attachment)?

Did the URL preview function
successfully scrape the URL
website?

Did the scraped URL have a URLspecific Nectar scrape logging
sampling rate, and if so, was this
scrape event sampled?

If the scraped URL did not have a
URL-specific Nectar scrape logging
sampling rate, was the scrape event
sampled in the default sampling
rate? (For Dec. 30, 2011 to June 20,
2011, 1%, and thereafter 0.01%)

Did the preview generation process
require scraping the website at the
URL?

6

If sent from the Facebook website:
Did the sender copy and paste a
URL into the draft message?
Or
Did the sender type a URL into the
message and press the space bar?

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Inclusion in Insights and Related API Accessed by Domain Owners
If the answer to ANY of the below questions is NO, then the message was NOT in Insights viewed by a domain owner during the class period.

Was the message sent after
December 30, 2011 and before
October 11, 2012?

Was the message sent from the
Facebook website?
Or
Was the message sent from a
Facebook Share Plugin (by
choosing to send "In a private
message")?

Did the URL included at time
of send match the preview (i.e.,
the message body did not only
include a different URL)?

Was a share object created?
(See p. 2, Share Object slide)

Did the domain owner
authenticate ownership of the
domain?

Did the domain owner access
Insights or call the API
between December 30, 2011
and October 11, 2012?

7

Was a URL preview generated?
(See p. 3, URL Preview slide)

Was the URL to a third-party
website?

Were both the message sender
and the message recipient a
Facebook user?

Was the internal counter in
Insights incremented? (i.e.,
were the server and other
conditions such that the share
was properly counted?)

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Inclusion in Link_Stats, Graph API and Related APIs Accessed by Third-Parties
If the answer to ANY of the below questions is NO, then the message was NOT in link_stats,
Graph API, or related APIs viewed externally during the class period.

Was the message sent between December
30, 2011 and October 16, 2012?

Were both the message sender and the
message recipient a Facebook user?

Was the message sent from the Facebook
website?
Or
Was the message sent from a Facebook
Share Plugin (by choosing to send "In a
private message")?

Was a URL preview generated?
(See p. 3, URL Preview slide)

Did the URL included at time of send
match the preview (i.e., the message body
did not only include a different URL)?

Was a share object created?
(See p. 2, Share Object slide)

Was the URL to a third-party website?

Was the share_count in
FQL
table incremented?
(See p. 4, Internal Counter slide)

Did anyone access the share_count in
link_stats, Graph API, or related APIs
between December 30, 2011 and October
16, 2012?

8

Individual Inquiries Required to Ascertain whether Each Message Was Subjected to:
Inclusion in Aggregate Counts Considered in Recommendations or Activity Feed Plugins
If the answer to ANY of the below questions is NO, then the message was NOT included in counts actually
considered by the Feeds during the class period.

Was the message sent between
December 30, 2011 and July 9,
2014?

Were both the message sender
and the message recipient a
Facebook user?

Was the message sent from the
Facebook website?
Or
Was the message sent from a
Facebook Share Plugin (by
choosing to send "In a private
message")?

Did the URL included at time
of send match the preview (i.e.,
the message body did not only
include a different URL)?

Was a share object created?
(See p. 2, Share Object slide)

Was the share_count in the
"share_stats " FQL table
incremented?
(See p. 4, Internal Count slide)

Did the third-party website
display a Recommendations
Feed or Activity Feed
configured to backfill with
Recommendations?

Did the primary backend
system (Taste) fail to work?

9

Was a URL preview generated?
(See p. 3, URL Preview slide)

Was the URL to a third-party
website?