Ceglia v. Zuckerberg et al
Filing
50
DECLARATION signed by Gerald R. McMenamin re 44 MOTION to Expedite - Notice of Motion for Expedited Discovery filed by Mark Elliot Zuckerberg, Facebook, Inc. filed by Mark Elliot Zuckerberg, Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Snyder, Orin)
EXHIBIT B
1
EXHIBIT B
Style Markers in QUESTIONED vis-à-vis KNOWN-Zuckerberg
1.
2.
3.
4.
5.
Spelling:
Spelling:
Spelling:
BACKEND
INTERNET
CANNOT
6.
7.
8.
9.
10.
Syntax:
Syntax:
Syntax:
Syntax:
Syntax:
RUN-ON SENTENCES
SINGLE-WORD SENTENCE OPENERS
SENTENCE-INITIAL "SORRY" [similarity]
DISTANT OR AMBIGUOUS PRONOUN-REFERENT
NO COMMA AFTER IF-CLAUSE
11.
1.
Punctuation: APOSTROPHES
Punctuation: SUSPENSION POINTS
Discourse:
MESSAGE-FINAL "THANKS!" [similarity]
Punctuation: APOSTROPHES
Apostrophes indicating contraction and possession are sometimes absent in QUESTIONED,
but always present in KNOWN-Zuckerberg.
Questioned
010604Z
doesnt
010604Z
parents [parents']
020604Z
sites [site's = site is]
020604Z
sites [site's = possessive]
Known-Zuckerberg
All apostrophes in contractions and possessives are present.
2.
Punctuation: SUSPENSION POINTS
Suspension points appear in threes and are spaced in QUESTIONED. Three suspension
points appear in KNOWN-Zuckerberg but are never spaced between each other or away from
words.
Questioned
073003Z
. . . I’ve been tweaking the search engine today
010104Zb I’ll just get this site online as quickly as I can ...”
Known-Zuckerberg
So let me know... (3x)
boxes...there (3x)
2
3.
Spelling: BACKEND
The technical term "backend" is written as two words in QUESTIONED. "Backend" and its
parallel "frontend" are always written as one word in KNOWN-Zuckerberg and appear as one
word multiple times.
Questioned
010104Z
the back end of the site
Known-Zuckerberg
backend (6x)
frontend (5x)
4.
Spelling: INTERNET
The word "internet" starts with a small-i in the QUESTIONED writing but with a capital-I in
KNOWN-Zuckerberg.
Questioned
090203Z
internet
Known-Zuckerberg
Internet (2x with cap I)
5.
Spelling: CANNOT
The word "cannot" appears as two words in the QUESTIONED writing but appears multiple
times as a single word in KNOWN-Zuckerberg.
Questioned
020604Z
can not [2 words]
Known-Zuckerberg
cannot [1 word] (6x)
6.
Syntax: RUN-ON SENTENCES (2 sentences with no separating-punctuation)
Run-on sentences constitute a strong and relatively frequent pattern in the QUESTIONED
writings. The even more extensive sample of KNOWN-Zuckerberg writings does not
demonstrate run-on sentences.
Questioned
073003Z
I’d like to --- Face Book], I think it will really help
090203Z
I have been away --- internet, during that time I revised
010604Z
you would be seriously violating --- by doing so, I have done
010604Z
Please do not contact them --- issue, they would probably just
020204Z
Paul, I have --- to discuss with you, according to --- I owe you
020404Z
‘thefacebook.com’ opened --- today, when you get a chance take a
020604Z
Sorry it’s --- to respond, (sic) Now that --- live I feel I must
020604Z
I don’t care about --- right now, I just want to see if people
3
072204Z
I still don’t have --- build our site, I understand that I
Known-Zuckerberg
No run-on sentences
7.
Syntax: SINGLE-WORD SENTENCE OPENERS
It has been shown that words introducing sentences (sentence openers) group as a habituallyused set for individual writers. The set of sentence openers present in the QUESTIONED
writings is wholly distinct from that of the KNOWN-Zuckerberg writings.
Questioned
090203Z
Further,
090203Z
Additionally,
010104Z
Thus,
010604Z
Again[,]
020204Z
First[,]
020204Z
Mostly though
040604Z
Paul,
Known-Zuckerberg
Okay
And
Anyhow, (2x)
Also,
But
But regardless,
Then
However,
8.
Syntax: SENTENCE-INITIAL "SORRY" [similarity]
Both the QUESTIONED and the KNOWN-Zuckerberg writings demonstrate sentence-initial
apologies starting with "Sorry".
Questioned
020604Z
Sorry
Known-Zuckerberg
Sentence-initial "Sorry" in Known-Zuckerberg (4x)
9.
Syntax: DISTANT OR AMBIGUOUS PRONOUN-REFERENT
A pronoun2 will refer back to a noun1 previously used, as in, I painted the door1 because it2
needed attention. If there is more than one preceding noun, the pronoun will refer back to one
of those, one which cannot be too far back, as in, I painted the door and my nails, and they
needed attention. However, sentences like the latter or sentences with a too-distant nounreferent can result in awkward ambiguity: I painted the door and the table, which really needed
attention. This type of problematic ambiguous or too-distant reference occurs in the
QUESTIONED writings but not in the KNOWN-Zuckerberg writings.
4
Questioned
090203Z
... during that time I revised the business plan for the Harvard
site. I would like to talk to you on the phone about it in
detail.
090203Z
As you mentioned last week, the issue we must resolve is how to
produce a revenue stream from the users. My conclusion this past
week is .... With this in mind, ... we could ... expand to other
colleges. Further, since the plan involves more than one
college, the name can’t have Harvard in it and [no pronoun]
remains unresolved.
010104Z
Thus, I am requesting a written waiver on your part
exempting me from the obligation to give you additional
ownership in the project that is outlined in our original
contract.
020204Z
First I want to say that I think that is completely unfair
because I did so much extra work for you on your site that
caused those delays ....
Known-Zuckerberg
[No too-distant pronoun referents in KNOWN-Zuckerberg]
10.
Syntax: NO COMMA AFTER IF-CLAUSE
A long if-clause is separated from its preceding or following main clause by a comma. Such a
comma is absent in the QUESTIONED writings, but most often present in the KNOWNZuckerberg writings.
Questioned
112203Z
if you could send another $1000 for --- project _ it would allow
010104Z
if there is any way you can --- funding _ I believe we will be
020604Z
If I had the rest --- that extra work I did _ I wouldn’t even
Known-Zuckerberg
Comma present 13x before or after if-clause in KNOWN-Zuckerberg
Comma absent 2x before or after if-clause in KNOWN-Zuckerberg
11.
Discourse: MESSAGE-FINAL "THANKS!" [similarity]
Both sets of writings contain an example of "Thanks!" used to conclude the writing.
Questioned
073003Z
Thanks!
Known-Zuckerberg
Thanks! (1x)
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?