Campbell et al v. Facebook Inc.

Filing 219

NOTICE of Refiling re Motion to Compel Discovery and Supporting Documents by Matthew Campbell, Michael Hurley re 218 Order on Administrative Motion to File Under Seal. (Attachments: # 1 Exhibit 1 - Replacement for Dkt. 205-4, # 2 Exhibit 2 - Replacement for Dkt. 205-6, # 3 Exhibit 3 - Replacement for Dkt. 205-8, # 4 Exhibit 4 - Replacement for Dkt. 205-10, # 5 Exhibit 5 - Replacement for Dkt. 205-12, # 6 Exhibit 6 - Replacement for Dkt. 205-16, # 7 Exhibit 7 - Replacement for Dkt. 205-17, # 8 Exhibit 8 - Replacement for Dkt. 205-18, # 9 Exhibit 9 - Replacement for Dkt. 205-19, # 10 Exhibit 10 - Replacement for Dkt. 205-15, # 11 Exhibit 11 - Replacement for Dkt. 205-21)(Gardner, Melissa) (Filed on 10/18/2016) Modified on 10/19/2016 (kcS, COURT STAFF).

EXHIBIT 4

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Michael W. Sobol (State Bar No. 194857)
[e-mail]
David T. Rudolph (State Bar No. 233457)
[e-mail]
Melissa Gardner (State Bar No. 289096)
[e-mail]
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP
275 Battery Street, 29th Floor
San Francisco, CA 94111-3339
Telephone: [phone]
Facsimile: 415.956.1008

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Hank Bates (State Bar No. 167688)
[e-mail]
Allen Carney
[e-mail]
David Slade
[e-mail]
CARNEY BATES & PULLIAM, PLLC
11311 Arcade Drive
Little Rock, AR 72212
Telephone: [phone]
Facsimile: 501.312.8505

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Attorneys for Plaintiffs and the Class

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MATTHEW CAMPBELL and MICHAEL
HURLEY, on behalf of themselves and all
others similarly situated,

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Plaintiffs,

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DECLARATION OF DR. JENNIFER
GOLBECK IN SUPPORT OF
PLAINTIFFS’ MOTION TO COMPEL
CONFIGURATION TABLES

v.

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Case No. C 13-05996 PJH (SK)

FACEBOOK, INC.,

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Defendant.

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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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I.

QUALIFICATIONS AND BACKGROUND
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As indicated in my curriculum vitae, I have been a professor in the College of

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Information Studies (“The iSchool”) at the University of Maryland since 2007 (assistant professor

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from 2007-2013, associate professor with tenure to present), where I have focused my research

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and teaching efforts on aspects of social media and the web.
2.

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I have previously submitted two expert reports in this case, both in support of

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Plaintiffs’ motion for class certification. My qualifications are described in detail at paragraphs

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1-10 of my opening report and in my curriculum vitae, attached thereto as Exhibit A.
3.

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In forming my opinions below, I have reviewed source code which I understand

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was provided by Facebook’s counsel and which was represented as containing the relevant source

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code between some time in 2009 and December 2012. Additionally I have reviewed numerous

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internal Facebook documents produced in this litigation, as well as certain public materials.

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These materials are listed in Exhibit B to my opening report.

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II.

SUMMARY OF ASSIGNMENT
4.

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I have been asked by the Plaintiffs through their counsel to provide the following,

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which I understand to be in support of Plaintiffs’ request to the court to compel certain types of

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discovery:

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a.

An explanation of the term “configuration table” as it relates to this case;

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b.

A description of why, in my opinion, I need to review certain of

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Facebook’s configuration tables in order to fully opine on the issues that I understand are relevant

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to this case; and

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c.

A description of the particular relevant configuration tables I have

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identified thus far, along with the information that I understand to be contained in them.

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III.

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CONFIGURATION TABLES
5.

Databases, in the most general sense, are systems that store data. That data is

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often divided into tables. A database table is analogous to one sheet in a spreadsheet. A table is a

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collection of related data in a database, and it contains rows and columns. Rows typically store

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the data about a particular entity, and the columns each represent a different attribute.
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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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6.

For example, an e-commerce website might have a table for products that had a

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row for each item and columns for attributes like name, price, SKU, description, etc. The website

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might also have a separate table for customers, with each row representing a customer and

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columns for user ID, password, name, street address, etc.

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“Configuration tables” are a specific type of database table. They store data that

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configures functionality of the system. Storing data in a configuration table rather than putting it

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directly in the system’s code has the benefit of allowing easy changes to the system’s

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functionality without requiring any code changes. Configuration tables essentially allow the

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system to be more flexible and adaptable, since changes can be made once in the configuration

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table, and then every place in the system that uses that information can easily access the change.

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8.

Continuing the simple example above, the e-commerce company may want to

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offer a discount to customers when they visit the site. They could offer a particular discount, say

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10% off, and a coupon code that the customer has to enter when they checkout, say

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“SUMMER2016.” A message with the discount and code can appear in many places. For this

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example, say it will be on the homepage and the Shopping Cart page. The data representing the

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coupon code can be stored in a configuration table. Then, the website code simply requests the

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discount value and the coupon code from the database, and uses them. On the home page, it may

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be in a banner message that says “New Customers: Receive <discount> off your order with the

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coupon code <coupon code>”, replacing the values in brackets with the data retrieved from the

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configuration table. The values can also appear on the Shopping Cart page in the message

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“Remember to use code <coupon code> for <discount> off!” If the company decides to change

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tactics, and offer 15% off with the coupon code “SUNSHINE1”, they simply update the

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configuration table. Both messages would be updated and no one needs to change the actual code

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that runs the website.

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Configuration tables can also be used to dictate what code is executed in a system.

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For example, say the e-commerce company wants to test a new site design. They may send some

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of their customers to the original version of the site (call this option A) and others to the new

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version (option B). The code for these site designs may change over time as the e-commerce
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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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company makes updates. While all of the code for every option could be embedded in the home

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page, it is much more efficient to keep the homepage code simple and consistent. It can simply

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choose if the viewer will see option A or B. Then, it can refer to a configuration table to find

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exactly which code to execute for each option. If either option changes, the homepage code can

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remain the same, and the configuration tables can simply be updated to point to the newest code.

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In cases like this, a code reviewer cannot know what code will be executed by the system unless

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they have access to the configuration tables. Without those tables, she would only know that

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there are two versions of the system, but it would be impossible to know what code corresponds

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to each version.

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The use of configuration tables reduces errors because a programmer does not

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have to find every place in the code where a value appears (e.g. they don’t have to search for

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every place a coupon code is used and update it).

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Configuration tables hold information that is critical for the system to function. It

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is essentially part of the source code, since it stores values and instructions that make the source

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code run. The instructions they contain can be much more complicated than the simple example

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given here. Configuration tables may list where data should be stored, which attributes to store,

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what is displayed, etc.

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12.

While “configuration table” is not a formal database term, the concept is well

known, widely used, and quite common.1

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1

See, e.g., Knight’s Microsoft SQL Server 2012 Integration Services 24-Hour Trainer, By Brian
Knight, Devin Knight, Mike Davis, Wayne Snyder. Chapter 44 “Easing Deployment with
Configuration Tables”; The Programmers’ Guide to OsCommerce: the Nuts and Bolts of
OsCommerce, By Myles O’Reilly. Chapter 2; Modern Industrial Automation Software Design,
By Lingfeng Wang, Kay CHen Tan, Chapter 13; Wingerd, Laura, and Christopher Seiwald.
“Constructing a large product with Jam.” International Workshop on Software Configuration
Management. Springer Berlin Heidelberg, 1997; “Dynamic adaptive display design based on
wireless sensor networks”, Zheng Wei Wang , Xiao Shi Zheng , Lin Wang , Ping Tang , Ru Liang
Zhang , Guang He Cheng , Qing Long Meng , Rang Yong Zhang , and Yang Wan. Proceedings
of the 2015 International Conference on Computer, Intelligent Computing and Education
Technology (CICET 2015), April 11-12, 2015, Guilin, P.R. China; Hallin, Peter F., and David W.
Ussery. “CBS Genome Atlas Database: a dynamic storage for bioinformatic results and sequence
data.” Bioinformatics 20.18 (2004) 3682-3686; Souyris, Jean, et al. “Computing the worst case
execution time of an avionics program by abstract interpretation.” OASIcs-OpenAccess Series in
Informatics. Vol. 1. Schloss Dagstuhl-Leibniz-Zentrum für Informatik, 2007; Watkins,
Christopher B., and Randy Walter. “Transitioning from federated avionics architectures to
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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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IV.

FACEBOOK’S USE OF CONFIGURATION TABLES
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I have reviewed source code which I understand was provided by Facebook’s

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counsel and which was represented as containing the relevant source code between some time in

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2009 and December 2012. I have provided my opinions, based on my review of the code thus far,

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on the functioning of Facebook’s source code with respect to Facebook’s redirection and

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interception of Private Message content in my opening and rebuttal reports in support of

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Plaintiffs’ motion for class certification.

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14.

Facebook’s source code makes extensive use of configuration tables. These were

not produced as part of the source code, but I have found evidence of their existence throughout

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the source code, as I describe in more detail in the following section of this declaration. They

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describe and control what data is stored, how certain systems function, and connections between

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different parts of the code.

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15.

At a general level, within Facebook’s source code, when a person shares a URL in

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a private message, data is created about that action (e.g. the URL preview information, the

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EntShare, the data that is in the EntShare, etc.). This data is stored. In order to understand where

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it is stored and any subsequent use, I require a list of all the places it is stored (e.g. database

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tables, objects, etc.) and the metadata and schemas for every place. This information would

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include field names and descriptive information for the database tables, attributes for any objects,

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etc. This information is contained in the configuration tables.

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16.

The web-facing source code that Facebook produced has a number of places

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where, in the execution of the process of a user sharing a URL in a private message, the code

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relies on databases or other external information for configuration. This includes values for

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variables and other configuration data. These variables and configuration tables are contained in

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Facebook’s configuration tables.

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integrated modular avionics.” 2007 IEEE/AIAA 26th Digital Avionics Systems Conference. IEEE,
2007.
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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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V.

SPECIFIC RELEVANT CONFIGURATION TABLES
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Because I have not been given access to these tables, it is impossible for me to say

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exactly how they function. Similarly, I cannot know all the relevant configuration tables that

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exist just like I could not know all the Facebook php files (i.e., source code) that existed before I

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could see them. However, there are some specific tables that I have seen evidence of that I know

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are relevant to this case. I describe some of these below, but this is in no way a complete list of

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the relevant tables. There are likely many more configuration tables that are important but I

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simply cannot know what they are until I am given access and allowed to inspect them.

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A.

and
database)

tables (in the
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18.

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The

and
tables (in the

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database) appear to contain

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. Logging is a major sub-system involved in, among other things,

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storing information for later processing. Based on review of the code, one example of such

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logging occurs for log calls that result in the production of the “

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log call has the user ID of the user sending a private message, and also the URL of the URL

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preview. This log call gets transformed at some point into the “

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information in it. The configuration tables may have the link between that log call and the

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“

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described in by rebuttal report, I have also identified a log call, “scribeh_share_stats,” that

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appears to perform the same logging as the “

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ongoing as of the final version of the code I reviewed from December 2012.

” table. That particular

” table with the same

” table, and may also lead to additional use being made of the user ID and URL. As

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B.

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19.

” log call, and which appears to have been

” and “

” tables (in the “f

” database)

“Associations” are one of the two fundamental database-based features of the

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Facebook system. Associations are used to associate one object to another object. They link

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people to other people, people to URLs, etc. Based on review of the code, it appears the

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” and “

” tables (in the “

” database) determine

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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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.

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One of the issues in this case is how Facebook connects users to the URLs they

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share in Private Messages. That data could be stored as an association, and these tables may

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contain information showing how the association is created. These configuration tables may also

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show other code that is executed as part of the association process.

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C.

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,

, and

tables (in the

database)
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All of the data within Facebook is stored in databases, in other tables besides the

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configuration tables this declaration discusses. These tables include all the data generated during

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the process of sending a private message with a URL attachment and the generation of the URL

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preview.

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I am not requesting access to this data, but rather to the configuration tables that

describe the structure of those databases. Based on review of the

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appear to be configuration tables that
contain this configuration data.
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That includes the names of each data point and the type of data associated with it.

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This information is necessary for me to know what data is being stored – for example, if user IDs

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and URLs sent in private messages are being stored together and where.

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D.

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24.

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table (in the

database)

, and I have seen many references to this information in the
source code.
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One particularly significant and directly relevant use is in the use of
to configure the operation of

checks.

is run during the

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generation of a URL preview in a private message. Access to this configuration table is critical to

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know what code is executed as part of the

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being sent in a private message go in to the

system. I know that the user’s ID and the URL
system. What the system does with that data is
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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)

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hidden in the configuration tables. I cannot know how it is being used or stored without the

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configuration tables that define the next steps within

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.

I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.
Executed this 1st day of August, 2016, in Silver Springs, Maryland.

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__________________
Jennifer Golbeck

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DECLARATION OF DR. JENNIFER GOLBECK IN
SUPPORT OF PLAINTIFFS’ MOTION TO COMPEL
C 13-05996 PJH (SK)