Bradburn et al v. North Central Regional Library District

Filing 32

DECLARATION by Paul Resnick in Support re 28 MOTION for Summary Judgment filed by North Central Regional Library District. (Attachments: # 1 Exhibit Exhibit A, Pages 13-28, # 2 Exhibit Exhibits B & C, Pages 29-43, # 3 Exhibit Exhibits D & E, Pages 44-67)(Adams, Thomas)

Bradburn et al v. North Central Regional Library District

Doc. 32

1 The Honorable Edward F. Shea
2

Thomas D. Adams

3 Celeste Mountain Monroe

4 KARR TUTTLE CAMPBELL
5 1201 Third Avenue, Suite 2900

Seattle, Washington 98101-3028

6 [phone]

7 Attorneys for North Central Regional Library District
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON AT SPOKANE
SARAH BRADBURN, PEARL CllERRNGTON, CHARLES I-llINLEN, and THE SECOND AMENDMENT FOUNDATION,
Plaintiffs,
v.
)

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) ) NO. CV-06-327-EFS )

) DECLARATION OF PAUL ) RESNICK
) ) )

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NORTH CENTRAL REGIONAL LIBRARY DISTRICT,

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) ) )
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Defendant.

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I, Paul Resnick, declare as follows:
1. I am over the age of 18 and competent to testify to the matters set

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forth herein.

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DECLARA TION OF PAUL RESNICK 1

La", Offices

CV -06-327-EFS
11658040 v i /42703-00 i

KARR TUTTLE CAMPBELL
A pJ"~fes.'ional Senice COJpora/ion
12111 Third A\'cniic, Suiic 291m, ScatHe. Washin~lCln 98101-)1I2H TclclJliunc (2UG) 223.1313, Facsimile (2UG) 6H2~71UIl

Dockets.Justia.com

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2. I am a Professor at the University of Michigan School of

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Information. (Attached hereto as Ex. A is a true and correct copy of my
curriculum vitae.)
3. In 2002, I conducted an assessment of the error rates on health-

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related websites of several commercial Internet filters. That study was

published in lAMA, the flagship peer reviewed journal of

the American Medical

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Association. (Attached hereto as Ex. B is a true and correct copy of the abovereferenced lAMA article.)
4. A subsequent paper abstracting what I had learned about the

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methods for conducting tests of filtering software was published in the
Communications of the ACM, the flagship publication distributed to all
members of the Association for Computing Machinery. (Attached hereto as
Ex. C is a true and correct copy of the above referenced ACM article.)

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5. I was retained by NCRL to serve as an expert in the current
litigation.
6. I was asked to explain how the NCRL filtering software works. I

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was also asked to assess the methods used in studying the error rates in the
filtering software NCRL uses as reported by Plaintiffs' expert, Mr. Bennett
Haselton.

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DECLARATION OF PAUL RESNICK2
CV -06-327-EFS #658040 v l /42703-001
Law Offices

KARR TUTTLE CAMPBELL
A Proje,\'.\ional Se/ï1ice Corpora/ion
1211 I Third A\'cnuc. Suile 29Ull. ScliUlc, W;ishin~iun 9811)1-3028 Tclc(llinnc (2116) 223-13 13, Fiicsiniilc (2116) 6RZ-71111l

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7. I was also asked to conduct a study of my own if I thought it would

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yield greater insight into whether the NCRL filter block more than the content
they intended to block. I did conduct such a study and report on the methods

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and results in a formal report. (Attached hereto as Ex. D is a true and correct
copy of my formal report, without appendices.)

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8. NCRL computers make use of the FortiGuard Web Filtering
Service offered by Fortinet, Inc.
9. FortiNet maintains a database of websites. Fortinet reports that it

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includes more than 30 milion sites, covering more than two bilion individual

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pages (URs).
10. FortiNet assigns each web page to one of 76 categories based on its

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dominant content, or to none of those categories Some pages are additionally
assigned one of seven classes.

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11. When a web site contains pages having content with different
dominant categorizations, each page is separately categorized.

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12. The customer selects classes or categories to block or leave
unblocked.

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DECLARATION OF PAUL RESNICK3
CV -06-327-EFS #658040 v 1/42703-001
Lmi' Offces

KARR TUTTLE CAMPBELL
A ProfesJional Service Corporation
1201 Third A\'cnuc, Suile 2911U, Seattle, Washington 98WI-J1I28 Telephone [phone], Facsimile (2116) 6R2w71l11