Dunstan et al v. comScore, Inc.

Filing 156

DECLARATION of Jay Edelson regarding memorandum in support of motion 154 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit s, # 20 Exhibit t)(Thomassen, Benjamin)

EXHIBIT K

HARRIS & DUSTAN v. COMSCORE, INC.

September 14, 2012

RANDALL McCASKILL

Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
______________________________
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of
a class of similarly situated
individuals,
vs.

Plaintiffs,

x
:
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:
:
:
:
:
:
:
:
x

COMSCORE, INC., a Delaware
corporation,

Case No. 1:11-5807
Hon. James F. Holderman

Defendant.
______________________________

Friday, September 14, 2012
Reston, Virginia
DEPOSITION OF:
RANDALL LYNN McCASKILL,
a witness, called for oral examination by counsel for
plaintiffs in the above-captioned matter, pursuant to
Notice and agreement of the parties as to time and date,
held at the offices of comScore, Inc., 11950 Democracy
Drive, Suite 600, Reston, Virginia 20191, beginning at
approximately 9:35 o'clock, a.m., before Patricia Klepp,
RMR, a court reporter and Notary Public in and for the
Commonwealth of Virginia, when were present on behalf of
the respective parties:

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 14, 2012

RANDALL McCASKILL

Page 27
1
2
3
4
5

marked for identification.)
BY MR. GIVENS:
Q.

McCaskill Exhibit 6.
A.

6
7

I am handing you what's been marked as
Take a moment to review it.

(Reading.)
Okay.

Q.

This is Bates No. 2669; it's a JIRA ticket,

8

the title of which is "Appsession and engaged duration

9

cache files should be standardized with syshawk delayed

10

post files."

11

Do you understand what this ticket is about?

12

A.

I think so.

13

Q.

Can you explain to me what it's about?

14

A.

We have cache files that we keep on the local

15

disk, and this was to standard -- you know, make them

16

all consistent, with the same compression, the same file

17

naming, with some other files that we had stored on the

18

disk, so it's just some housekeeping.

19

Q.

Does "s-y-s-hawk," here, refer to SystemHawk?

20

A.

Yes.

21

Q.

What is SystemHawk?

22

A.

SystemHawk is a process -- or -- process --

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 14, 2012

RANDALL McCASKILL

Page 28
1

it's not really a process.

It's a function we use to

2

collect information about the computer.

3

Q.

Does SystemHawk create cache files?

4

A.

Yes, it can.

5

Q.

What are in those cache files?

6

A.

It depends -- SysHawk is broken into multiple

7

processes.

There is one aspect of it, the file scan,

8

that actually creates a cache file so that if it gets

9

interrupted, it can resume.

10

Q.

If what gets interrupted?

11

A.

The file scan.

If the machine is rebooted,

12

you know, we don't want to start all over again, so we

13

will try to resume.

14
15

Q.

Every time a file scan is conducted, is that

cache file written?

16

A.

I think it has to go on for a certain period

17

of time -- there are some conditions; it's not every

18

time.

19
20
21
22

Q.

Does that cache file contain information such

as file names?
A.

Actually, I don't remember what's in the

format; I'd have to look in the spec.

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 14, 2012

RANDALL McCASKILL

Page 78
1

here, so it's -- and it's not fresh in my memory; that's

2

for sure.

3
4

Q.

Do you have any reason to believe you didn't

write this ticket?

5

A.

No.

6

Q.

What is this ticket about?

7

A.

That there was a page -- PDF that was

8

converted to HTML, and some of the fields were not being

9

fuzzified.

10

Q.

Explain what secure PDF collection is.

11

A.

Secure being HTTPS.

12
13
14
15
16

PDF is file format.

So we're trying to collect some information
from a -- secure PDFs.
Q.

Give me an example of when a user might

encounter a secure PDF.
A.

Bank statement?

That's -- this one here is

17

Bank of America, so I assume it's a bank statement -- or

18

a credit card statement, one of the two.

19

Q.

In your description, you write, "It appears

20

that 4 lines of a PDF are not going through the

21

fuzzification logic."

22

What do you mean by that?

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 14, 2012

RANDALL McCASKILL

Page 79
1
2
3
4
5

A.

Those four lines did not get fuzzified

properly.
Q.

What kind of information was contained in

those four lines?
A.

It has account number, there's a credit and

6

payment, and credit line.

7

really valid is account numbers.

8

important, but ...

9

Q.

The only thing I think is
I think it's

In the last paragraph of that description, you

10

write, "These rules have been there since April 2005 so

11

we are expecting these items to not be fuzzified."

12
13

What do you mean by that?
A.

Meaning that -- the rules had been there for

14

awhile and that these items are falling outside of our

15

rules.

16
17
18

(Whereupon, Deposition Exhibit No. 16 was
marked for identification.)
BY MR. GIVENS:

19

Q.

I am handing you what's been marked as

20

McCaskill --

21

A.

Are you done with this one?

22

Q.

I'm done; you can set that aside.

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221