Campbell et al v. Facebook Inc.

Filing 199

NOTICE by Facebook Inc. Joint Notice of Refiling of Documents Accompanying Class Certification Briefs and Evidentiary Objections (Attachments: # 1 Ex. 1 - Replacement for Dkt. 178-1, # 2 Ex. 2 - Replacement for Dkt. 183-4, # 3 Ex. 3 - Replacement for Dkt. 179-1, # 4 Ex. 4 - Replacement for Dkt. 184-3, # 5 Ex. 5 - Replacement for Dkt. 179-2, # 6 Ex. 6 - Replacement for Dkt. 179-3, # 7 Ex. 7 - Replacement for Dkt. 179-4, # 8 Ex. 8 - Replacement for Dkt. 179-5, # 9 Ex. 9 - Replacement for Dkt. 179-6, # 10 Ex. 10 - Replacement for Dkt. 179-7, # 11 Ex. 11 - Replacement for Dkt. 179-10, # 12 Ex. 12 - Replacement for Dkt. 179-11, # 13 Ex. 13 - Replacement for Dkt. 179-12, # 14 Ex. 14 - Replacement for Dkt. 179-13, # 15 Ex. 15 - Replacement for Dkt. 179-14, # 16 Ex. 16 - Replacement for Dkt. 179-15, # 17 Ex. 17 - Replacement for Dkt. 179-16, # 18 Ex. 18 - Replacement for Dkt. 179-17, # 19 Ex. 19 - Replacement for Dkt. 179-18, # 20 Ex. 20 - Replacement for Dkt. 179-20, # 21 Ex. 21 - Replacement for Dkt. 180-2, # 22 Ex. 22 - Replacement for Dkt. 180-3, # 23 Ex. 23 - Replacement for Dkt. 184-9, # 24 Ex. 24 - Replacement for Dkt. 180-7, # 25 Ex. 25 - Replacement for Dkt. 180-9, # 26 Ex. 26 - Replacement for Dkt. 180-12, # 27 Ex. 27 - Replacement for Dkt. 180-17, # 28 Ex. 28 - Replacement for Dkt. 180-18, # 29 Ex. 29 - Replacement for Dkt. 180-19, # 30 Ex. 30 - Replacement for Dkt. 180-20, # 31 Ex. 31 - Replacement for Dkt. 180-21, # 32 Ex. 32 - Replacement for Dkt. 180-22, # 33 Ex. 33 - Replacement for Dkt. 180-23, # 34 Ex. 34 - Replacement for Dkt. 178-5)(Chorba, Christopher) (Filed on 6/15/2016)

EXHIBIT 21

HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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MATTHEW CAMPBELL, MICHAEL HURLEY,

)

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and DAVID SHADPOUR,

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Plaintiffs,

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vs.

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FACEBOOK, INC.,

C 13-05996 PJH

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Defendant.

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Case No.

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)

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)

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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
VIDEOTAPED DEPOSITION OF JIAKAI LIU
Palo Alto, California

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June 30, 2015

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Volume I

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Reported by:

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KELLI COMBS, CSR No. 7705

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Job No. 2094258

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Pages 1 - 256

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Page 1
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of communication did you primarily use?

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A

In what context?

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Q

10:52:01AM

In terms of electronic communication.

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I'll withdraw the question.

Did you typically e-mail other members of

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So

10:52:13AM

the Software Engineering team between 2010 and 2012?

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A

Yes.

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Q

Other than e-mail, did you use any other

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form of electronic communications such as Chat or
some sort of internal e-mail system, et cetera?

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A

Yes.

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Q

10:52:31AM

And tell me about those other means of

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communication you used.
A

Facebook Messages, that includes Chat and,

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like, non-chat Message.

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think.

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recall at this point.

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Q

That's 10:52:47AM that,
primarily

I

I might miss some other tool, but I couldn't

What was -- what was your e-mail address

between 2010 and 2012, your Facebook?

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A

It's

10:53:21AM

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Q

If you'd turn back to Exhibit Number 2 and

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you look on the second page, do you see the heading

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"Understanding Cells"?

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A

Yes.

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Q

And do you see the third bullet point

10:53:54AM
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send her a message and what's going to happen, like,

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after the request enters the first, like, Facebook

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MTA server.

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Q

5
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diagram.
A

11:44:49AM

And -- so let's -- let's walk through this
What does "MTA" mean?

11:45:06AM

MTA is a commercial -- I think it's a

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commercial software we bought to receive the -- to

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handle the external e-mail requests and also, like,

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we use it for internal message sending/receiving

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purpose as well.
Q

11:45:34AM

And then how about that next box, "Spam

Detection"; what does that mean?
A

Spam Detection means we detect whether a

message is a spam message or not.
Q

And did you play any role in creating the

11:45:47AM

Spam Detection functionality?

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A

No.

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Q

Who was primarily responsible for that?

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A

We call it Site Integrity on Facebook.

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Q

And did you have a primary point of

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contact in the Site Integ- -- on the Site Integrity

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11:46:05AM

team between 2010 and 2012?

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A

I didn't personally.

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Q

Did you write any code that dealt with

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I couldn't remember.

spam detection in the Messages product?

11:46:23AM
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2

A

User Snapshot was the blob of metadata we

1:22:09PM

saved to HBase.

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Q

Let's -- let's turn just for one few more

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questions back to Exhibit Number 3.

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go to the -- that diagram on the second page, the

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"Incoming Flow" diagram.

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about spam detection earlier, and you indicated that

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Site Integrity was primarily responsible for that.

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And I want to
1:23:34PM

And we talked a little bit

Do you know whether Facebook does any
malware detection on incoming messages?

1:24:02PM

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A

I don't know.

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Q

Don't know?

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A

I don't.

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Q

And just so we're clear, do you know

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whether they did any malware scanning of incoming

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messages between January 1st, 2010, and January 1st,

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2013?

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A

I don't have firsthand knowledge.

1:24:15PM

Yeah, I

don't have firsthand knowledge.
Q

Do you ever recall having any discussions

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with anyone about any malware scanning that Facebook

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1:24:36PM

was doing?

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MR. JESSEN:

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THE WITNESS:

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Object to form.
I couldn't recall now.

It

might, but because it's, like, four, five years ago,

1:24:52PM
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I couldn't recall now.

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BY MR. CARNEY:
Q

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Do you recall whether you were -- ever

wrote any code dealing with malware scanning?
A

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1:24:55PM

I couldn't remember at this point.

I

1:25:15PM

couldn't remember.
Q

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Do you know whether Facebook does any

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scanning to protect the site from hackers?

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that.

Strike

Do you know whether Facebook did any

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scanning to protect the site from hackers between

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1:25:34PM

January 1st, 2010, January 1st, 2013?

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A

I think that's what Site Integrity team

does -- did; that's their job detail.
Q

Did you have any discussions with anyone

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at the Site Integrity team regarding their efforts

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to prevent or protect the site from hackers related

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1:25:52PM

to the Messages product?

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A

I couldn't remember the exact
I might be in some e-mail thread or

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conversation.

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1:26:10PM

something, but I couldn't remember.

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Q

Do you recall whether you wrote any code

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dealing with efforts to protect the site from

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hackers?

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A

I couldn't remember.

1:26:31PM
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HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
I,

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the undersigned, a Certified Shorthand

Reporter of the State of California, do hereby certify:
That the foregoing proceedings were taken

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4

before me at the time and place herein set forth; that

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any witnesses in the foregoing proceedings, prior to

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testifying, were administered an oath; that a record of

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the proceedings was made by me using machine shorthand

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which was thereafter transcribed under my direction;

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that the foregoing transcript is a true record of the

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testimony given.

Further, that the foregoing pertains to the

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original transcript of a deposition in a Federal Case,

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before completion of the proceedings, a review of the

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transcript [X] was

[

]

was not requested.

I further certify I am neither financially

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16

interested in the action nor a relative or employee of

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any attorney or any party to this action.
IN WITNESS WHEREOF,

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I have this date

subscribed my name.

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Dated:

July 7,

2015

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KELLI COMBS
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CSR No. 7705
Page 256
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In the Matter of:

Campbell et al. v. Facebook, Inc.
Case No. 13-CV-05996-PJH

Date of deposition:

June 30, 2015

Witness:

Jiakai Liu

Reason codes:
1.
2.
3.

To clarify the record.
To conform to the facts.
To correct transcription errors.

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Should Read

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Street address is
.
Q. And what type of software did you build at
Google?
A. It varies. For example, I worked on Google
Book Search for a while and then because the
Web -- because the Web is like the photo service
and a few other things.
Q. Can you tell me what their names are?
A. One of them was Hary Wang, H-A-R-Y WA-N-G.
A. Kannan, K-A-N-N-A-N; Karthic, Karthic.
Q. Who was your boss on the Home team?
A. It was Tom Addison.
Q. Is Mr. Addison still your boss?
A. No.
Q. Why did you write it?
A. Same reason as, like, this block post.
And when the reviewers are happy, like,

Street address is
.
Q. And what type of software did you build at
Google?
A. It varies. For example, I worked on Google
Book Search for a while and then Picasa Web
which is like the photo service and a few other
things.
Q. Can you tell me what their names are?
A. One of them was Harry Wang, H-A-R-R-Y WA-N-G.
A. Kannan, K-A-N-N-A-N; Karthik.
Q. Who was your boss on the Home team?
A. It was Tom Alison.
Q. Is Mr. Alison still your boss?
A. No.
Q. Why did you write it?
A. Same reason as, like, this blog post.
And when the reviewers are happy, like, satisfied,

Reason
Code
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94

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106

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108

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121

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123

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164

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197

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satisfied, they can accept the change, and then
you can lend the change, commit the change to
the repository.
A. Uh-huh. Index is -- it’s generally you can
imagine it as a mapping from a stream, from,
like, some – something, from some entities.
It maps to a collection of some other ID or
streams.
Q. What’s a memcache tier?
A. Memcache tier is a common cache service
using Facebook.
their Facebook e-mail address, by the time team
we support e-mail address for Facebook users,
and that message will start an e-mail-originated
thread.
A. I think that’s what Site Integrity team does –
did; that’s their job detail.
Q. How about Michael Adkins?
A. Michael Adkins, I heard his name, but I
don’t know him personally or worked with him,
no.
A. Andrew Bosworth, the boss, Andrew
Bosworth I mentioned earlier.
So, to me, it’s like two independent concepts.
One, it’s the implementation for Facebook
Messages, which I had worked on and continue
to work on, like, is the patent worth filing.
The memory cache dirty service and posted
processing -The memcache dirty service and posted
processing

2

they can accept the change, and then you can land
the change, commit the change to the repository.
A. Uh-huh. Index is -- it’s generally you can
imagine it as a mapping from a string, from, like,
some – something, from some entities.
It maps to a collection of some other ID or strings.

3
3

Q. What’s a memcache tier?
A. Memcache tier is a common cache service
used in Facebook.
their Facebook e-mail address, by the time we
support e-mail address for Facebook users, and
that message will start an e-mail-originated thread.

3

A. I think that’s what Site Integrity team does –
did; that’s their job duty.
Q. How about Michael Adkins?
A. Michael Adkins, it’s a guy I know on Messages
team and had some work relationship.

3

A. Andrew Bosworth, the Boz, Andrew Bosworth
I mentioned earlier.
So, to me, it’s like two independent concepts.
One, it’s the implementation for Facebook
Messages, which I had worked on and continue to
work on, like, while the patent was filing.
The memory cache dirty service and post
processing -The memcache dirty service and post processing

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3

1

3

3
3