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 N

HARRIS & DUSTAN v. COMSCORE, INC.

September 13, 2012

MICHIKO CHAND

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
:
:
:
:
:
:
:
:
:
:
x

COMSCORE, INC., a Delaware
corporation,

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

Defendant.
______________________________

Thursday, September 13, 2012
Reston, Virginia
DEPOSITION OF:
MICHIKO AVANTIKA CHAND,
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 9:30 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 13, 2012

MICHIKO

CHAND

Page 28
1

Q.

The discussion we've just had about the

2

collection of HTTP HTML page data, do the same rules

3

apply if it's HTTPS HTML page data?

4
5
6

MS. BOWLAND:

Objection; vague.

BY MR. GIVENS:
Q.

You just described the process of how

7

personally identifiable information is fuzzified and

8

then sent to comScore servers in situations when a user

9

is on an HTTP HTML website.

10

Do those rules apply

equally if the user is on a secure site, HTTPS?

11

A.

Do you mean the rules of fuzzification?

12

Q.

Yes.

13

A.

Yes.

14

Q.

Okay.

15

capturing HTTP HTML post data.

16
17

How does OSSProxy want HTTP HTML post data to
collect?

18
19
20
21
22

Let's talk about the process for

MS. BOWLAND:
A.

Objection.

Yes, a little more detail.

BY MR. GIVENS:
Q.

What HTTP HTML post data does OSSProxy

collect?

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 13, 2012

MICHIKO

CHAND

Page 29
1

A.

If it's typed text HTML, it will collect it.

2

Q.

It will collect all post data?

3

A.

Yes.

4

Q.

Does it fuzzify all post data?

5

A.

Yes.

6

Q.

Is there any post data that's not fuzzified?

7

A.

All post data goes through a fuzzification

8
9

route.
Q.

10

That didn't answer my question.
So is all post data fuzzified?

11

A.

Yes.

12

Q.

All right.

13
14

MR. GIVENS:

Let's take a quick five-minute

break.

15

(Whereupon, a recess was taken.)

16

MR. GIVENS:

17
18

Back on.

BY MR. GIVENS:
Q.

Okay.

Before we took a break, we were

19

discussing fuzzification of post data, and you said that

20

all post data is fuzzified.

21

A.

Yes.

22

Q.

Are there -- there's no instances when post

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221

HARRIS & DUSTAN v. COMSCORE, INC.

September 13, 2012

MICHIKO

CHAND

Page 41
1

BY MR. GIVENS:

2

Q.

What's an example of a discernible field name?

3

A.

Name.

4

Q.

And so can you think of an example of a

5

non-discernible field name?

6

A.

XYZ.

7

Q.

Am I accurately describing the problem as when

8

the software sees the field name as XYZ, it doesn't

9

understand that it needs to fuzzify that information?

10
11
12
13
14

MS. BOWLAND:
A.

Yes.

BY MR. GIVENS:
Q.

This ticket was created in February, 2009; the

top right of the first page lists its creation date.

15

MS. BOWLAND:

16

MR. GIVENS:

17
18
19

Objection; vague.

Sorry; is that a question?
It's coming.

BY MR. GIVENS:
Q.

The very last comment is on May of 2009, and

it appears that that's when the issue was fixed.

20

Does that seem correct to you?

21

MS. BOWLAND:

22

Objection; mischaracterization.

Also vague.

CAROL J. THOMAS STENOTYPE REPORTING SERVICES, INC.

www.carolthomasreporting.com

800-322-9221